CLAIM NO: HC/2015/001906

IN THE HIGH COURT OF JUSTICE

CHANCERY DIVISION
BETWEEN:
LEIGH RAVENSCROFT
Claimant
and

CANAL and RIVER TRUST

Defendant

------------------------------------------------------------------------------------------------------------WITNESS STATEMENT OF CLAIMANT

-------------------------------------------------------------------------------------------------------------

This witness statement is made by the Claimant in response to the submissions

both of Ms Barry and Mr Stoner for the Defendant, in the matter of their:

a) opposition to allow Mr Moore right of audience, &

b) application to strike out my Statement of Case, alternatively,
c) application to strike out part of my Statement of Case.

Opposition to Right of Audience

1.

Paragraph 16 of Ms Barrys statement claims that Mr Moores

involvement has changed the issues I was seeking to resolve into more
general issues of claimed only tangential relevance to me. The
statement appears to postulate that the only problem I asked him to help
with, was getting my boat back [paragraph 17].

2.

Insofar as this is a correct analysis of her position, it is false. I will refer

the Court to the videos of the boats seizure at Newark Marina. I told the
police officer in the hearing of CaRTs Enforcement Officer Mr Garner,
and their unidentified Debt Collector, that I would take this matter to the
Queens Bench as a matter of theft facilitated by him.
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3.

The police officer had refused to query CaRTs authority to take my boat
and told me to take it up in law as a civil matter which he [the police
officer] was not going to involve himself with.

4.

As I had told Mr Garner, I was going to sue them for theft, criminal
damage and acting without due process, by which I meant that they
were seizing my boat for an alleged debt of 4 years licence fees without
obtaining a court warrant to do so, and having absolutely no paperwork
to establish either their claims or their rights to take the action they did. I
explained this to the police officer, and as I said at the time, I was never
going to let this one drop.

5.

I told CaRT and the police officer also, from the beginning, that I needed
no licence where I was moored on the private property of my moorings
provider. My father was prepared to pay the alleged debt for this
regardless, to prevent them taking the boat away, but was told by Mr
Garner that the full sum of more than 8,000 would need to be paid for
that to happen, inclusive not only of the 4 years alleged licence arrears
but also the estimated cost of removal and transportation even though
the boat had not at that stage left the marina

6.

I note at this point that Ms Barrys paragraph 8 relating to the Trusts

stance that . . . a licence was required for my boat and that I had
previously held a licence for it, is knowingly false. CaRT are very clear
[as Shoosmiths Ms Barry must be] that no licence is required for boats
on the Trent, and that at most a registration certificate needs to be
maintained [I had previously had a Pleasure Boat Certificate, not a
Licence as claimed by Ms Barry].

7.

This is not a mere matter of careless drafting; it has potential to mislead

the Court over the central core of my case. CaRTs understanding is set
out in their response to an FoI request, dated 2 August 2013
https://www.whatdotheyknow.com/request/river_licence_a_percentage_
of_fu#comment-40388
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There is no technical difference between a 'Boat licence' and the

'Registration Certificate'. The canal licence (which includes use of rivers)
is distinctly a licence this is because we own the canals and the
device for granting permission to use is via a licence. Rivers are
different. There is a statutory right of navigation and we dont own them,
so all that people have to do is to register to use them (subject to a fee
which the statutes allow for subject to the percentage condition we
covered in the last query). So technically, it is not a river only licence
but a river registration. [my bold]
8.

This is a very muddled and technically inaccurate answer; the ownership

of the canals and lack of ownership of rivers has nothing to do with the
right to grant permission it is the effect of the 1968 Transport Act that
abolished conferred rights of navigation on the canals, combined with
the 1976 Byelaws, that makes pleasure boat licences on the canals
compulsory, not the ownership of the canals.

9.

Nor are the navigation rights on rivers conferred by statute as suggested

here, and the first sentence contradicts the last - however, the
difference between canals and rivers re: the right of navigation is
pertinent, and the answer correctly identifies that no licence is
required to keep boats on the rivers; it is simply that there is a
statute-imposed requirement to maintain a paid up certificate of
registration for so long as a boat is kept or used within the main
navigable channel of the listed rivers.

10.

The distinction is not merely technical; it is vitally important in the

present context, wherein reliance is placed on the absence of a lawful
authority to keep the boat on the river. The river registration certificate
is a superimposed statutory obligation on those exercising the right to be
on the river, breach of which is subject to specific [and criminal]
penalties; it does not form any lawful authority as in permission for
the boat to be left or moored, even within the river waterway as
defined. The section 8 powers are therefore inapplicable.

11.

It is pertinent to quote from the Witness Statement of Stuart Garner

[paragraph 17] which Ms Barry has attached:

On 3 September 2014 I served a Patrol Notice to Grandma

Molly/Three Wise Monkeys advising the Boat was on CRT waterways
without permission and failing to display a current licence. [my bold]

12.

As CaRT were quoted in paragraph 7: the device for granting

permission to use is via a licence. Rivers are different. Not needing a
licence there is no device for granting permission respecting the rivers.
While CaRTs enforcement officers have been known to be abysmally
ignorant &/or casual in their use of the law, and to lie in evidence under
oath, still, the enforcement management; legal department, and CEO,
have all approved of Mr Garners actions and this Statement.

13.

It is quite understandable for the authority to loosely use the term

licence in the general context of public references for convenience; it is
not so understandable for them to use this inapplicable term in a
misleading way within the context of these legal submissions. If my boat
had been kept within the main navigable channel, then I would have
been guilty not of being there without permission, but - of failing to
abide by a statutory requirement while exercising the permission we all
have under common law.

14.

After videos were posted on YouTube, Ms Tracy Thomas came along to

help me start off with court proceedings to prevent CaRT from selling or
disposing of my boat, which we had been led to believe they could do if
not paid the outlandish sum of more than 8,000 inclusive of the 4 years
alleged licence arrears. She spent many hours before and after,
attempting to get specific sums identified and justified.

15.

Following internet publicity, Ms Thomas was put in touch with Mr Moore

who had been posting details of the legislation controlling CaRTs rights
of removing boats. Mr Moore advised on the content of emails and
letters sent by her, and also advised writing to the legal department to
suggest that I could drop the Injunction hearing as unnecessary, if they
only agreed in writing that they would not dispose of my boat while we
were attempting to sort matters out to retrieve the boat.

16.

[They refused to do this, despite their last minute admission that they
had no right to do what my injunction sought to forbid.]

17.

I believe that there could never have been any doubt that CaRT were
aware that I was going to take matters into the High Court. Mr Moore
only advised on the specific legal reasons why my already stated
intention to do so was justified; the right to demand tolls for use of the
river being contrary to Ms Barrys suggestion a matter that County
Courts lack jurisdiction to determine.

18.

I would note that it was I who introduced Mr Moore to the applicability of

the Statute of Marlborough, which forbids seizure of goods without Court
Warrant; seizing goods in the highway, and removing them from the
County.

19.

Ms Barry suggests [as I understand] in her paragraphs 20 & 21 that the

email of 24 April 2015, despite my reference to preparing for these
proceedings, indicates no desire to do so, because I had said I wanted
nothing more to do with keeping the boat. In making that claim she is
confusing what I wanted to do with the boat with what I wanted to do
about their unlawful seizure of the boat.

20.

My intention had always been to sell the boat as soon as it was finished
as I had told them in the videos: I had already advertised it on ebay,
and I had in fact agreed a sale immediately prior to the seizure. The
intent had been to make a bit of income from the renovation project.

21.

Being refused return of the boat unless it stayed off their water [despite
being made to pay for it to be there], it has since been in a farmers field
costing me the same as if I was paying for moorings, and yet being
unable to sell easily from there. At this stage, even if I sell it for what I
wanted, I will end up out of pocket.

22.

Paragraph 22 itself illustrates that I was fully engaged in preparing for

this current action, even while negotiating for the return of the boat
through payment under protest of the illegal demands.
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23.

In light of their recognition of this, the contradictory nature of the

preceding claims is incomprehensible.

24.

The reliefs that I am seeking from the court can never be described as
academic as the videos amply demonstrate, I want not only
compensation for all the monies illegally extracted from me, I want
satisfaction that only the Courts can provide, in declarations affirming
that everything [well mostly] of what I said to CaRT and police at the
time, was fully justified.

25.

Besides which, I need to establish that my claims over the criminality of

their actions

are

justified,

in

order to

justify repayment and

compensation for all the money they have both charged and cost me.

26.

For all the above reasons, I maintain that contrary to the claims of Ms
Barry, my stated intention had always been to both retrieve my boat and
to sue them in the High Court on the grounds outlined in my Statement
of Case. All that Mr Moore has contributed is the specific waterways
legislation that confirmed the correctness of my allegations; he has also
provided the history of such of the Defendants past activities that have
demonstrated that they are as criminal in enacting their own unlawful
policies as I repeatedly accused them of at the time.

27.

I submit that objecting to Mr Moores involvement and assistance in

preparing my case, most especially in view of my unfamiliarity with the
waterways specific legislation; my inability to communicate effectively in
writing; my verbal dyslexia, and my lack of any knowledge of court
procedures, is entirely unwarranted. They had no objection to Ms
Thomas assisting in exactly the same way.

28.

I am unclear as to what constitutes conducting litigation. I note that the

Practice Guidance: McKenzie Friends exhibited to Ms Barrys
Statement refers to: the provision of reasonable assistance in court or
out of court by, for instance, carrying out clerical or mechanical
activities, such as photocopying documents, preparing bundles,
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delivering documents to opposing parties or the court, or the provision of

legal advice in connection with court proceedings. This is no more than
what both Ms Thomas and Mr Moore have provided for me.

29.

I cannot speak to the claims made about Mr Moores conduct over his
own litigation, which I will have to leave to him. What I, as anybody can
say, is that in the principal case that addresses much of the same issues
I have, over the use of s.8 Notices, he succeeded. That they wasted a
quarter million pounds in fruitlessly arguing the issues and ended up
ordered to pay 75% of his costs besides, is only testimony to the lengths
they will go to pursue boaters even when it is they who are in the wrong.

30.

For the judge whose judgment was overturned to class resolute defence
of an eventually justified claim as indicative of being stubborn and
relentless and obstinate [as quoted by Ms Barry] is singularly
inappropriate. From the outset I put CaRT on notice that I will be equally
as resolute in seeking redress in the cause of justice for the criminal
actions they took against me.

31.

Ms Barrys paragraph 30 protests that I am following the same strategy

as Mr Moore in pursuing my case at CaRTs expense. As with Mr
Moores situation, I cannot see why impecuniosity should debar anyone
from fighting for their rights in the Courts in circumstances where grave
injustice has been perpetrated against them by the Defendant.

32.

There is no unnecessary multiplication of issues by reason of my

straightened circumstances; there are, as CaRT have readily identified,
only 3 major issues, any and all of which involve the authority in criminal
offences which they have an established history of perpetrating.

33.

As to the objection to CaRT having to engage in this litigation at their

own expense, there are several good answers.

34.

In the first place, and most importantly, they need never have decided to
engage in litigation with me at all.

35.

They summarily dismissed my letters before action, and it was entirely

their decision to reject my repeated offers to withdraw from litigation if
they refunded my money and acknowledged the wrongs done.

36.

In the second place, the employment of external professionals to

prepare elaborate defences at disproportionate cost is a tactic of their
choice when they have their own more knowledgeable in-house legal
officers with full right of audience.

37.

In the third place, in an example of extravagant expenditure in the

Defence that they prepared to object to my application for an injunction,
the 4,500 spent was not aimed at the injunction to neither sell nor
destroy my boat, but instead involved a detailed defence of their right to
seize the boat in the first place. The preparation of that Defence, with
the accompanying witness statement and exhibits, involved the matters
that are raised in this action rather than that of the injunction
application, such that the work required for preparation of a defence in
the instant case has already been largely [and pointlessly] undertaken
anyway.

38.

The Defendants argument on this score boils down to a claim that I

should accept going into debt to pay their unlawful extortion of money
from me to retrieve my possessions, and that my lack of funds should
preclude my being able to seek justice for that.

39.

What the point is of Ms Barrys paragraphs 33 & 34 I do not know. I

attended at Nottingham County Court in company with Mr Moore
because I was interested in the case, and to support yet another CaRT
victim.

40.

Having discussed that case with him beforehand, I knew that Mr Moore
had written an amended Defence for them that the solicitors were
postponing looking at in the belief that the hearing would be only for
directions. He did not submit that to the Court, but to the solicitor only.

41.

It was Mr Moores belief [correct as it turned out] that the hearing would
be dispositive, and so he helped Mr Wingfield file a short witness
statement instead of the unused Defence.

42.

Neither of us were permitted to sit in on the hearing, but the transcripts

reveal

that

Mr

Wingfields

solicitors

had

failed

to

file

an

Acknowledgement of Service with the Court objecting to the Part 8

procedure, and handed up a draft Defence only at the hearing. The
judge accorded great latitude in allowing Mr Wingfields barrister to
address the Court at all in the circumstances, and paid no attention to
any legal argument in the Statement, addressing only the disputed facts
according to Mr Wingfield - which his barrister acknowledged as correct.

43.

It is hard to see why objection should be taken to Mr Moores assistance

in that instance when the judge himself allowed it in opposition to Mr
Wingfields own barristers request that it be dismissed.

44.

The only Defence filed with that Statement was an exhibited copy of a
relevant Defence that Mr Moore has also helped draft [together with a
couple of other boaters] for yet another boater who faced s.8
proceedings from CaRT earlier. In that prior instance they had
discontinued the case after reading the Defence, and having sight of it at
the Wingfield hearing, CaRT offered to restore the licence on a 3 month
probationary basis if he returned to his home mooring. It was only the
failure of Mr Wingfields representatives to take up that offer that led to
the hearing going ahead.

45.

I have talked at length with these and other boaters who have faced
similar issues and been assisted voluntarily by Mr Moore. I do not see
why I should be denied the same assistance just because he has been
effective in helping others.

46.

Neither I nor Mr Moore have any objection to any of the correspondence

being revealed concerning the attempt to resolve matters out of court;
there need be no legal argument about it. I have made no secret of my
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inability to prepare the case on my own, and it was at Mr Moores

insistence that I agreed to try resolving matters outwith litigation. If any
one item of the correspondence is to be exhibited, however, the whole
of it should be, so that the Court is able to form a balanced view.

47.

I asked CaRT to allow Mr Moore to conduct negotiations, and he

persuaded me to be content with far less than I had wanted. The
principal reason for failure in this was not, I believe, due to the sums
suggested but to my insistence on transparency, and on an
acknowledgement that errors in conduct had been made on at least one
of the grounds that I had initially insisted on before this started.

48.

Insofar as any point will be sought to be made from this correspondence

relating to the fact that buying my silence could not buy his, that would
be redundant, as the arguments involved had already been publicised
by Mr Moore beforehand in public forums which was how I came to be
put in touch in the first place. He has only remarked on the obvious.

49.

In summary, in the premises above, I submit that there is no substance

to the assertion that Mr Moores involvement has meant that my
Statement of Case includes issues that are merely peripheral to my
claim. His involvement has meant only that my claims, based as they
were on the general principles of law that I understood, were placed
within the specific context of the waterways legislation, with examples
from the authoritys history to back my claims of criminality in their
approach.

50.

I feel that it is important for the court to recognise that Mr Moores advice
to me, as indicated by the email he suggested over resolving the
application for an injunction, was to always seek resolution outside of
the Courts if possible, and the emails CaRT wish to exhibit demonstrate
that he repeatedly though fruitlessly - asked for personal discussion
with the Defendant in lieu of correspondence with their solicitors.

51.

It is unfortunate that they were unwilling to follow that route. Their

complaints over the expense of defending litigation rings hollow in the
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light of that approach. Even the judge in the County Court appeal
queried why they were unwilling to resolve our differences that way;
their stance being then that I should drop all claims entirely with no
unbending or concession on their part, even though admitting at the last
that they could not do as the injunction sought to forbid them anyway.

52.

For the reasons given in my Request, I firmly believe that I will be

severely prejudiced should I have to orally present my case myself.

Application to Strike out my Claim

53.

I submit that it would be a terrible miscarriage of justice to allow this

application to succeed. I gave reasons in my Reply to Defence.

54.

The points raised by reference to the absence of the required

Statement of Truth in the relevant documents have, I assume, been
addressed by the replacement ones now filed, sent in compliance with
the Chief Masters directions.

55.

The principal argument of Ms Barry as backed by Mr Stoner at the

hearing,

is

that

the

Statement

of

Case

is

too

prolix

and

disproportionate, which I take to mean that the Statement of Case is not

concise as the CPR demands.

56.

I start by noting that the latest White Book commentary on CPR s.16 as
helpfully supplied by Mr Stoner begins by saying that Part 16 and the
Practice Direction supplementing it offers little guidance on drafting
statements of case . . .

57.

CPR 16.4(1) however, provides: Particulars of claim must include (a)

a concise statement of the facts on which the claimant relies. [my bold]

58.

I submit that the Particulars of Claim as attached to the Claim Form are
a concise outline of the relevant facts and the reliefs sought, comprising
a mere 5 pages of double-spaced 12 pt font with generous margins.

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59.

The White Book commentary states: The primary function of the

particulars of claim is to state concisely the facts on which the claimant
relies and The claimant should state all the facts necessary for the
purpose of formulating a completed cause of action. A claimant may
also: (1) refer in their particulars of claim to any point of law on which
their claim is based. [my bold]

60.

I submit that my Particulars of Claim meets the relevant rule perfectly,

having referred not only to the bare facts far more concisely than the
filed Defence, but including a bare mention of the relevant Acts, the
points of law within which are, on my argument, violated by the
Defendant and so giving rise to valid causes of action.

61.

With respect to the Statement of Case that I filed in addition to and in

elaboration of the concise Particulars, I acknowledge the applicability of
the Practice Direction 16.1.4, which provides: If exceptionally a
statement of case exceeds 25 pages (excluding schedules) an
appropriate short summary must also be filed and served. [my bold]

62.

My Statement of Case begins with just such a summary, being less

than a single page that sets out the three essential grounds, which the
Statement elaborates upon for the sake of complete understanding of all
parties as to how and why those grounds arise and are justified.

63.

Furthermore, the Statement concludes with a summary of just over 2

pages, summing up as succinctly as possible the foregoing material of
the statement.

64.

I refer to my comments respecting this in my Reply to Defence.

65.

I further note that the length of the additional Statement was

considered important in order to lay out as completely as possible for
the benefit of both Defendant and the Court, such material as is
illuminating of the issues and arguments, bearing in mind the potential
inadequacy of a litigant in person [including Mr Moore if permitted] to
present the case orally at trial.
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66.

As noted in the Reply to Defence, the Defendant has demonstrated in

their Defence that the essential core issues have been readily
appreciated. There can therefore be no legitimate claim of obfuscation
or difficulty of understanding. I submit that the detailing within the
Statement has been of considerable assistance to all parties rather than
otherwise, and so providing essential tools for just disposal of the
proceedings.

Application to strike out the Presumption of Probity section

67.

I note that the single most oft repeated accusation that I made to CaRT
at the time of seizure and thereafter, was that they were acting in a
criminal fashion contrary to law. This is very evident from the videos.

68.

Each of the three primary issues that I have raised embraces the
inevitable accusation of criminal action, each of them involving a
violation of either common law and/or Statute by the Defendant, which I
have claimed is a characteristic of CaRTs enforcement policy.

69.

As the White Book comments: Paragraph 8.2 of the Practice Direction

supplementing Pt 16 requires the claimant to specifically set out the
following matters in their particulars of claim where they wish to rely on
them in support of their claim: (1) any allegation of fraud; (2) the fact of
any illegality; (3) details of any misrepresentation; (4) details of all
breaches of trust; (5) notice or knowledge of a fact; (6) details of
unsoundness of mind or undue influence; (7) details of wilful default, and
(8) any facts relating to mitigation of loss or damage.

70.

It is submitted that there is therefore a two-fold requirement

necessitating inclusion of this section: rebuttal in this instance, of the
natural and officially stated presumption that authorities in the position of
exercising rights over the public should be considered to act at all times
lawfully and for the strict purposes of their administration, plus the CPR
requirement that any accusation that this is not the case, be backed by
factual example and any prior case history.
13

71.

The past actions of the Defendant as a corporation administering

enforcement against members of the public in ways contrary to the law,
involving criminal behaviour, are therefore not merely directly pertinent
to my claims [establishing that the grounds for them are not fanciful
despite being against common and legal presumption], but the citing of
examples both of general policy and of identical/similar actions as obtain
in my own case, is in fact mandatory.

72.

My claim that the Defendant has acted in a criminal fashion in denying

and obstructing the public right of navigation a right which they
acknowledge exists in this case is verified by the precedent of every
one of the past court actions to remove boats which involve Injunctions
against the boats being used on public navigable rivers, and is
specifically exampled in the cited case of Moore v British Waterways.

73.

It is all the more relevant that in that latter case, there had been a history
of many years of violating the rights of boats to use a public navigable
river, in demanding illegal tolls and evicting and threatening to evict
boats therefrom.

74.

Worse, the cited example of the Defendant still forcing boats from that
river using s.8 powers, even post the relevant judgment and
acknowledgement of its effect supported by the same regional
manager as publicly acknowledged that effect demonstrates that such
criminal actions are continued in the face of knowledge, with the
sanction of upper management.

75.

This is essentially pertinent as grounds to support my claims that the

nature of the actions I accuse them of is institutional in character and not
the inadvertent [CaRTs argument] behaviour of a single rogue
employee.

76.

The other examples cited in the section likewise demonstrate that the
general attitude is reflective of the attitude of the highest office holders,
as well as that of the enforcement and legal departments.
14

77.

There is no need, as I have stated in my Reply to Defence, for the

Defendant to respond to this section; the facts are matters of public
knowledge and publication, and of relevant Court judgments and orders.

78.

It is all the more inappropriate for the Defendant to demand their costs in
applying to have this section struck out, seeing that they have not in fact
addressed the details of the section at all. Indeed, they cannot deny the
facts; they can only hope to suppress them via this application.

79.

I submit that it is vital to my case that the general presumption of probity

is challenged, with unassailable examples demonstrating that I have
good and sufficient grounds of action that underlie the accusations I
have made.

80.

The effect of the presumption is nowhere more obvious than in the video
evidence of the police officer at the scene of the seizure.

81.

When it was forcefully put to him that the seizure was an act of criminal
nature which he ought to prevent, his response was: From my
untrained perspective in the rule of the river, or the laws of the river, its
no different to if someones left their car on a highway, and its been
abandoned . . . You guys are saying they need paperwork, wheres
your proof that this chap doesnt own the [boat?] . . . These guys, the
Canal and River Trust, know what theyre entitled to do . . .

82.

While there can be no disagreement with that last statement, the

obvious thinking of the officer in making the statement was to assert the
correctness of their actions that knowing what they were and were not
entitled to do, the fact that they did something was proof enough - for
him - of their entitlement to do it.

83.

When weighing up the conflicting claims of CaRT employees and a

member of the public, officialdom automatically [and understandably]
assumes that CaRT are in the right.

15

84.

As the same officer also said: Im not bothered about paperwork. Im

quite happy that the Canal and River Trust are acting lawfully.
This, without any knowledge, as quoted in the preceding paragraph, of
what the laws of the river actually were.

85.

When that understandable presumption exists, it is necessary to

demonstrate that CaRT and their predecessor [same legal personnel]
have done exactly opposite to what they knew themselves to be entitled
to - historically and to the present.

86.

The 29 examples of illegal s.8 actions against boats entitled under the
common law right of navigation to be on the Brent, as detailed in the
section objected to, speak directly to the readiness of the Defendant to
commit these crimes, as they have done in the other examples listed,
and with me.

87.

The example given of the CEOs dismissive attitude to crimes committed

by his senior staff serves to justify my accusations that the criminal
actions of the corporation are a result of carried-over corporate policy.

88.

The other itemised historical facts are similarly indicative of the abusive
approach of which I have accused them both verbally and in pleadings.
They serve to establish the validity of my claims as perfectly justified, so
providing reasonable grounds for bringing the claims that I have.

89.

What the Defendant is seeking to ask the Court to do in this strike-out

application, is to deny me the right to present the existing relevant
evidence to the Court of the validity of my claims; this being contrary to
the requirements of Practice Direction 16 paragraph 8.

90.

I refer also to paragraph 356 of my Statement of Case respecting the

need to justify opening the gate to look behind for the reasons for
CaRTs actions against me, in respect of the Human Rights aspect to
the offences claimed.

16

91.

In the premises I submit that the application to strike out this section
should be dismissed as wholly improper and inappropriate, and contrary
to the over-riding objective of dealing with the case justly . . .

Statement of Truth

I believe that the facts stated in this witness statement are true.

...........................

2 January 2016

Leigh Ravenscroft
c/- The Croft
Moor Lane
Newark
NG23 5QD

Email: midlandlogs@hotmail.com

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