Particulars of Claim

PRELIMINARY STATEMENT

1. These Particulars of Claim are necessarily incomplete due to the ongoing process of obtaining crucial information through Subject Access Requests (SARs) from various defendants. The Claimant anticipates providing a more comprehensive and detailed account, including a full chronology of events, once this information is received and properly analysed.
2. The Claimant emphasizes the extreme urgency of this matter. The ongoing lack of suitable housing and support has placed the Claimant in a state of crisis, severely impacting their mental and physical health. Each day without appropriate intervention exacerbates the Claimant’s vulnerability and increases the risk of irreparable harm. The Court’s immediate attention and action are crucial to prevent further deterioration of the Claimant’s condition and to address the persistent violations of their fundamental rights.
3. However, the Claimant submits these initial Particulars now due to the urgent need for interim relief. The current situation poses an immediate and ongoing risk to the Claimant’s wellbeing, necessitating prompt court intervention.
4. The Claimant respectfully requests the Court’s permission to supplement and amend these Particulars once all relevant SAR data has been obtained and reviewed. This additional information is expected to further substantiate the claims made herein and provide a more complete picture of the systemic failures and discrimination experienced by the Claimant.
5. Despite the incomplete nature of these Particulars, the Claimant contends that the information provided herein is sufficient to demonstrate the pressing need for the interim orders sought and to establish a prima facie case against the defendants.
6. The Claimant undertakes to provide a full chronology and any additional pertinent information to the Court and all parties as soon as practicable following the receipt and analysis of the SAR data.
7. In light of these circumstances, the Claimant respectfully requests that the Court consider the urgent nature of the reliefs sought, particularly the interim orders, while allowing for future elaboration and specification of the claims as further information becomes available.
8. The Claimant acknowledges the use of AI assistance in preparing these Particulars of Claim. This technology was essential in enabling the Claimant, as an autistic individual facing significant challenges, to articulate and organize the complex details of this case. The content and experiences described herein are entirely the Claimant’s own. Please note, the point of view changes on some sections from myself to claimant because of this.
9. A. Local Councils and Housing Authorities

1. Failure to Provide Appropriate Housing:

1. The councils involved, specifically Richmond, Bristol, Bath, and Croydon, have failed to offer suitable housing that accommodates my disabilities, such as autism, misophonia, cPTSD, and others. The cumulative burden placed upon me by their discriminatory practices has had a profound and detrimental impact on my life, potentially engaging my right to life under the Human Rights Act.
2. Despite numerous requests and documentation of my specific needs, these councils have either placed me in environments unsuitable for my conditions or ignored my needs entirely, causing significant harm to my mental and physical well-being. This constitutes a breach of their duty to accommodate disabled individuals under the Equality Act 2010.
3. I believe that when securing housing, the councils have failed to give due regard to the needs of people with disabilities. The failure to provide appropriate housing has left me unable to find a suitable place to live and work for over a decade.
4. Multiple councils have used the local connection criterion to deny me assistance, despite my homelessness and the Homelessness Code of Guidance stating that this should not prevent councils from assisting those in need. This criterion has also been used to deny helping me with emergency food payments, or other financial assistance. Even in the council area where I was born I was told I am not “local”.

2. Failure to Conduct Care Act Assessments:

1. The councils involved have consistently failed to conduct proper Care Act assessments, either by delaying housing until I am forced to seek accommodation elsewhere, directly refusing to conduct assessments, or by claiming to have informed adult care departments without any follow-up.
2. This failure to conduct timely and appropriate Care Act assessments has left me without the necessary support and accommodations, exacerbating my difficulties and contributing to my ongoing homelessness.
3. Specifically the failure for me to have an advocate to speak for me is one of the most damaging things that has happened.
4. I have now been trying to formulate my care plan for many years and still nothing has been done.

3. Failure to Make Reasonable Adjustments:

1. The councils have not made reasonable adjustments to their procedures, communications, and housing offers to account for my disabilities, unless under duress. They have consistently demanded phone communication, failing to understand that as an autistic individual, I engage in phone communication with very few people.
2. In Bristol’s second Care Act attempt, they immediately demanded I travel to meet someone in person, despite my request for an alternative method of assessment. After this, they simply ignored me.
3. This failure to make reasonable adjustments and accommodate my communication needs constitutes a violation of the Equality Act 2010. The Equality Act is often only adhered to when significant pressure is applied, such as involving a Member of Parliament or other external advocates. There are too many instances of the equality act being broken to take them all to court within 6 months. This time limit is completely unrealistic and I can only imagine how many disabled people it has denied rights to.
4. There is widespread mismanagement and Confusion among council staff regarding what anticipatory adjustments should be made, leading to ineffective and harmful outcomes. This includes failing to provide necessary advocacy services, accessible communication methods, and accommodations for my sensory sensitivities and mental health conditions.
5. The council has repeatedly failed to make reasonable adjustments as required under the Equality Act 2010. Despite my clear requests for an advocate and for assistance in communicating my situation to the DWP, these requests have been consistently ignored or inadequately addressed. The council’s failure to confirm whether they have informed the DWP of my circumstances, coupled with their lack of response regarding potential financial assistance, has effectively denied me access to vital support and benefits. This breakdown in communication and lack of appropriate advocacy has significantly impaired my ability to navigate the system and access the support to which I am legally entitled. As a result, I have been left in a precarious financial situation, unable to effectively communicate with the DWP, and denied my rights to proper support and reasonable adjustments.

4. Hostile Environment and Undue Burden:

1. The actions of all the councils involved have contributed to a pervasive hostile environment, where I am treated as a database entry rather than an individual with unique needs. I believe this is because council are relying on databases and scripts too much and are more concerned with legal liability than actual care. This leaves me feeling unwelcome, unsupported, and forces me to relocate to yet another area.
2. The council tax exemption provided is insufficient and places an undue financial burden on me, leaving me with inadequate benefits to secure appropriate housing and support.
3. The discriminatory practices, lack of appropriate accommodations, and failure to conduct proper assessments have trapped me in a cycle of homelessness and distress, effectively denying me my basic rights as a disabled person.
4. The defendants have consistently employed evasive communication tactics, including using ambiguous language, deflecting responsibility between departments, and refusing to provide single points of contact. This approach creates unnecessary complexity and barriers for vulnerable individuals seeking assistance. The current system appears designed to discourage pursuit of legal remedies, disproportionately affecting those with disabilities or in crisis situations. This systemic approach may result in a significant number of eligible individuals, particularly those with autism or other disabilities, being effectively denied their legal rights and proper support, potentially leading to severe consequences including self-harm or suicide.
5. The amount of tasks the council expect you to do during a relief duty and to find a home is a full time job, for someone with issues with amounts of tasks, this is a further undue burden. e.g. joining the Bristol homechoice website required a huge amount of tasks and it said on the front page that it is likely you would not get housed.
6. The council’s approach to housing assistance during the relief duty period imposes an undue and discriminatory burden on individuals with disabilities, particularly those with executive functioning challenges. The multitude and complexity of tasks required, such as navigating the Bristol HomeChoice website, effectively amount to a full-time job. This approach fails to make reasonable adjustments for individuals with disabilities, as required by the Equality Act 2010. Moreover, the council’s own admission on the HomeChoice website that housing is unlikely to be secured through this process raises serious questions about the efficacy and legality of their approach. This combination of onerous requirements and extremely low probability of success creates a system that is particularly inaccessible and potentially discriminatory towards individuals with disabilities.

This systemic failure:

1. Violates the council’s duty to make reasonable adjustments under the Equality Act 2010
2. Potentially breaches the public sector equality duty by failing to eliminate discrimination and advance equality of opportunity
3. Exacerbates the claimant’s existing disabilities and vulnerabilities
4. Creates additional barriers to accessing essential services, potentially engaging Article 8 (right to private and family life) of the Human Rights Act 1998

The claimant contends that this approach is not only unreasonable but actively harmful, particularly to those with disabilities that affect task management and executive functioning. It represents a fundamental misunderstanding of the challenges faced by vulnerable individuals seeking housing assistance and may amount to indirect discrimination.

5. Prioritisation of Legal Liability Avoidance Over Comprehensive Care:

• The pervasive compartmentalisation of departments within the council and other relevant institutions has resulted in a system driven primarily by databases and software designed to avoid legal liability rather than to provide comprehensive, person-centred care.
• This fragmentation of services and the emphasis on legal risk mitigation has created a bureaucratic environment that fails to prioritize the holistic needs of individuals, particularly those with complex disabilities and support requirements.
• The council’s focus on adhering to rigid, software-driven processes and categorizations has led to a dehumanizing approach that treats individuals as mere data points rather than as human beings with unique circumstances and needs.
• This compartmentalized, liability-focused system has resulted in a failure to provide integrated, coordinated support that addresses the full spectrum of an individual’s needs, leading to gaps in care and a lack of continuity in service provision.
• The prioritisation of legal liability avoidance over comprehensive care has had a disproportionately negative impact on individuals with disabilities, who often require a more holistic and adaptable approach to support that takes into account their specific challenges and requirements.
• This system has perpetuated a culture of bureaucratic indifference, where the primary concern is meeting the minimum legal requirements rather than ensuring the well-being and quality of life of the individuals served.
• I urge the court to recognize the fundamental flaws in this compartmentalised, local and liability-focused approach and to compel the council and other relevant institutions to prioritize the delivery of comprehensive, person-centred care that addresses the full range of an individual’s needs, including homeless people that are forced to move around.
• I ask the court to hold the council and government accountable for its failure to provide an integrated, responsive system of support and require the implementation of reforms that prioritise the well-being of individuals with disabilities over the avoidance of legal liability.

6. Systemic Failure to Provide Accessible and Accommodating Bureaucratic Processes:

1. The council has created a convoluted and labyrinthine bureaucratic system that forces me, an autistic individual with significant communication challenges, to navigate a maze of departments and personnel, despite my clearly stated inability to engage in verbal communication with large crowds of people.
2. When I express my need for alternative modes of communication, I am continually passed from one person or department to another, with each transition exacerbating my distress and frustration. This practice shows a blatant disregard for my disability and the accommodations I require.
3. Attempts to seek clarity or obtain answers to my questions are met with a pervasive pattern of buck-passing, with each department or individual deflecting responsibility and directing me to “ask the other department.” This creates an inescapable cycle of futility and despair, as I am left without any meaningful support or resolution.
4. The legal framework that has been constructed to justify this bureaucratic nightmare is fundamentally flawed and morally reprehensible. It demonstrates a complete lack of consideration for the unique challenges faced by individuals with disabilities, particularly those with autism and communication difficulties.
5. This systemic failure to provide a clear, streamlined, and accessible process for seeking assistance is not merely an inconvenience; it actively undermines my ability to secure the support and accommodations I am legally entitled to, and it exacerbates the psychological harm I have already endured.
6. The council and governments construction of this bureaucratic maze, coupled with their failure to implement reasonable adjustments and accommodations, constitutes a form of institutional discrimination and ableism that disproportionately affects individuals with disabilities.
7. I implore the court to recognise the profound injustice and harm caused by this bureaucratic nightmare and to hold the council accountable for their failure to provide a simple, accessible, transparent, and equitable system for individuals like myself to seek the support we so desperately need.
8. I ask the court must compel the council to dismantle this discriminatory bureaucratic structure and replace it with a system that prioritizes the needs of disabled individuals, ensures clear lines of communication and responsibility, and provides the necessary accommodations and support to navigate the process effectively.

The current organisational structure of the main defendants, characterised by excessive compartmentalisation and siloed departments, appears to hinder rather than enhance efficiency. This fragmentation, likely driven by software systems and legal constructs, creates artificial barriers to effective service delivery.

Anecdotal evidence from industry insiders suggests that this departmental division frequently leads to delays, miscommunication, and a failure to provide cohesive support. In the context of serving vulnerable individuals, this system appears particularly detrimental.

The claimant contends that this structure:

1. Obfuscates accountability, making it difficult to identify responsible parties
2. Creates unnecessary delays in service provision
3. Increases the burden on service users, particularly those with disabilities, to navigate complex systems
4. May be in breach of the public sector equality duty by creating additional barriers for disabled individuals

This systemic issue exacerbates the specific failures detailed elsewhere in this claim and should be considered as part of the overall pattern of inadequate service provision and potential discrimination.

7. Systemic Discrimination and Institutional Ableism:

• The repeated failure of all the councils involved to address my needs, despite clear evidence and repeated requests, demonstrates systemic discrimination and institutional ableism within the council system.
• Councils have persistently required my physical presence for assessments, despite lacking the medical expertise to properly evaluate my conditions. They have also failed to effectively manage my contact information, particularly during periods of homelessness, often requiring me to provide the address of others simply to satisfy database requirements.
• Assessments are conducted by individuals without relevant expertise, highlighting the inadequacy of current council practices. Recent reports of a “toxic environment” within councils, such as Croydon, further underscore the institutional issues at play
• The council’s failure to provide clear, direct responses to my questions has caused me severe psychological distress.
• I have been unjustly excluded from accessing council services due to the way I communicate and my emotional responses, which are directly related to my disabilities, my place of birth and my social class.
• The council’s failures have left me at risk of street homelessness, as I am unable to directly communicate with them without an advocate.
• The Local Housing Allowance (LHA) rate is inadequate to secure suitable accommodation in the current market. Its usually about £300 below the average rate of obtaining a one bedroom property, which is nearly my entire PIP payment.
• The government’s attempt to ban “No DSS” policies has been circumvented by estate agents and landlords through insurance contract requirements, creating a de facto discrimination against benefit recipients and disabled individuals. This practice potentially violates the Equality Act 2010 and exacerbates housing accessibility issues for vulnerable groups.
• Bristol Councils’ reliance on credit unions for rent advances and deposits demonstrates the systemic failure of current housing benefit policies.
• These combined factors make it virtually impossible for individuals with specific needs, such as the requirement for independent living, to secure appropriate housing.
• This situation represents a systemic failure to provide adequate housing support, particularly discriminating against those with disabilities who require specialised accommodation.
• The cumulative impact of the councils’ discriminatory and negligent actions has been to trap me in a cycle of homelessness, vulnerability, and distress, denying me my basic rights as a disabled person.

8. Ignoring of safeguarding referrals:

Bristol council has ignored multiple safeguarding referrals made within the last two months, including from my doctor, putting my safety and well-being at risk. The previous “investigation” they made caused me to attempt to end my own life through the obfuscated and intermittent and confusing communications across many departments. I also had to visit my friend in Bath and made another safeguarding self-referral there which was entirely ignored. The deterioration in my well-being is significant and the damage from not looking after myself is very serious. These issues are also stopping me from self-care right now and I have emergency issues I should be going to hospital for (particularly my mouth). The council’s conduct has had a devastating impact on my life, leaving me homeless, vulnerable, and unable to access necessary support services.

9. Mismanagement of Housing Benefit and Communications

Bath Council demonstrated a severe failure in their duty of care and communication responsibilities regarding the Claimant’s housing benefit. Specifically:

The Claimant seeks relief regarding an overpayment of housing benefit administered by Bath Council and the DWP. The circumstances are as follows:

1. The Claimant was forced to leave temporary accommodation in Bath due to excessive noise and unsatisfactory communications from Bath Council.
2. The Claimant made multiple attempts to inform Bath Council of this change in circumstances, explicitly requesting that they inform the DWP to stop housing benefit payments.
3. Despite these repeated notifications, Bath Council failed to act on this information or to inform the DWP, resulting in continued overpayments of housing benefit.
4. This failure caused the Claimant significant anxiety and distress, exacerbating existing mental health conditions.
5. The Claimant contends that this overpayment resulted from the Council’s negligence and failure to make reasonable adjustments for the Claimant’s known communication difficulties.

In light of these circumstances, the Claimant seeks:

(a) A declaration that the overpayment resulted from the Council’s negligence and not from any fraudulent action by the Claimant.

(b) An order that the Council and/or DWP waive any claim to recover this overpayment from the Claimant.

(c) Compensation for the anxiety and distress caused by this situation.

(d) An order requiring the Council to implement proper procedures for handling such notifications from vulnerable individuals in the future.”

This incident exemplifies the systemic failures in communication, lack of reasonable adjustments, and improper case management that the Claimant has experienced across multiple local authorities. It further demonstrates the detrimental impact of fragmented services and poor inter-departmental coordination on vulnerable individuals.

10. Brief overview of claims against specific councils

Bristol City Council’s Recent Conduct:

1. Bristol City Council has recently failed to provide an advocate to communicate with me, leaving me unable to ascertain whether they have transferred the relief duty to Richmond. I’ve asked Richmond to do the same and no advocate has contacted me.
2. Initially a friend was dong this job, but he no longer had time to deal with it because of a family issue and was also becoming bewildered and frustrated with the process and thought it was ridiculous.
3. This failure to provide an advocate and ensure clear communication has caused me significant distress and uncertainty, further exacerbating my already dire situation.
4. The council’s refusal to confirm whether they have any suitable accommodation for autistic people, and their use of evasive, corporate language when pressed on this issue, demonstrates a concerning lack of transparency and accountability. This suggests a failure to properly consider the needs of people with disabilities when procuring accommodation.
5. The cumulative impact of Bristol City Council’s actions has been to create a hostile environment, leaving me feeling unwelcome, unsupported, and forcing me to relocate to another area. Their conduct has had a devastating effect on my life, rendering me homeless, vulnerable, and unable to access necessary support services.
6. I have suffered significant harm, including a suicide attempt during the last safeguarding “investigation”, as a direct result of Bristol City Council’s failure to provide appropriate support and accommodation. Their actions have also prevented me from reporting recent domestic abuse, as I have been denied the necessary advocate support. This has left me in severe legal jeopardy.

Bath Council’s Disregard for Misophonia and Unsuitable Accommodation:

1. Bath Council has consistently ignored my specific needs, particularly those related to misophonia. In a housing review triggered by my friend at Shelter, the council displayed a shocking dismissive attitude towards my condition, near scoffing at the severity of my sensory sensitivities.
2. The council erroneously claimed that I had “settled” in a severely inadequate and rotting caravan in Scotland, which lacked basic amenities such as a toilet and running water. The unsuitability of this accommodation is difficult to overstate; during summer months, the caravan became dangerously hot, exacerbating my health concerns. I am generally afraid to venture outside so this became a problem.
3. Bath Council’s failure to recognise the impact of my misophonia and their willingness to deem such an uninhabitable dwelling as “settled” accommodation demonstrates a profound lack of understanding and a dereliction of their duty to ensure the well-being of vulnerable individuals under their care.
4. I request that the court take into account Bath Council’s disregard for my specific needs and their role in perpetuating my unsuitable living conditions when considering the systemic failures and discrimination I have faced.

Croydon Council’s Toxic Practices and Denial of Communication:

• Croydon Council’s conduct has been among the most toxic and detrimental to my well-being. On one occasion, they left me to starve and face street homelessness, showing a callous disregard for my basic human needs and dignity.
• The council instituted a policy of ignoring or abruptly terminating my phone calls and emails, effectively severing my lines of communication and denying me access to the support and services I desperately needed.
• When I attempted to gain insight into their internal communications regarding these incidents through a data freeze and Subject Access Request (SAR), Croydon Council ignored my requests. I strongly believe this refusal to provide transparency was motivated by a directive to staff to disregard my concerns and needs. The ICO found that they had indeed failed, but they still did not provide the data, instead wanting to tie me up in processes to prove my identity, which they already knew, since the only way they had ever heard from me was via email and I had never personally met any of them.
• The council cited their displeasure with my communication style, stating that it “creates them too much work.” This justification is not only deeply inappropriate but also highlights their failure to make reasonable adjustments for my autism and the communication challenges I face.
• These experiences with Croydon Council have significantly contributed to the cumulative harm and trauma I have endured. Every interaction repeatedly underscores the critical need for an advocate to communicate on my behalf and to protect my safety and well-being in the face of such institutional mistreatment.
• I acknowledge that my communication style may not always conform to neurotypical norms or bureaucratic expectations. However, this only serves to reinforce the necessity of providing me with an appropriate advocate who can bridge these gaps and ensure that my needs are effectively conveyed and addressed.
• I urge the court to consider Croydon Council’s toxic practices, their denial of my basic rights to communication and support, and their failure to accommodate my autism as key elements in the overarching pattern of discrimination and harm I have suffered.

Richmond Council’s Denial of Communication:

1. Richmond Council and advocacy organizations in the Richmond area have failed to provide me with the necessary support and accommodations, despite my clear communication of my needs and rights under the Equality Act and Care Act. I have asked practically everyone in the area. I am either passed a list of contact details for other people that pass me other lists, or told I cannot be helped. In total I have probably spent weeks of my life trying to find an advocate, even pay for one, I cannot do it. The last paid one recommend by the National Autistic Society told me my case was too complicated for them, and I needed a solicitor, except the advocate is not there for legal advice. The advocate is to help me get my point across.
2. I have asked the relief duty to be passed to Richmond, since I am attempting to work with a friend there, however at this point I will go anywhere that is quiet, apart from Bristol. I am never going back to Bristol because of their behaviour, Bath would be suitable as long as the property was secluded, which is rare there. After so much moving, I am at a loss of where to go to find suitable accommodation, I ask for the courts help with this.

2. B. Government Departments and Agencies (e.g., DWP, PIP)
3. Imposition of Unreasonable and Discriminatory Conditions:
   • The DWP has imposed unrealistic financial targets and tasks on me without considering the impact of my disabilities, exacerbating my mental health conditions and making it impossible for me to meet these targets.
   • The DWP’s actions have caused extreme stress, leading to a deterioration in my ability to function and meet basic needs.
   • While self-employed in Leeds, I experienced severe financial hardship, living on a tiny amount per month after the council tax removed all my benefits. This extreme stress, combined with my PTSD, led to a complete breakdown. The trauma from this period was profound, characterised by daily emotional distress. Since then, I have been unable to maintain communication with the DWP, resorting to minimal contact only to request that they cease communication.

2. Failure to Provide Adequate Support:
   • Despite my clear eligibility and documented needs, the DWP has consistently failed to provide adequate financial and practical support.
   • This failure has contributed to my ongoing hardship and instability and represents a breach of the DWP’s duties under the Equality Act 2010 and other relevant legislation.
   • Failure to communicate about help with health costs, specifically in relation to the cannabis medication I have been prescribed. I have serious concerns about the efficacy of this program by itself, the clinic told me I can claim the costs back from PIP, so I had to fund this myself while I waited for them to respond, which they never did.
3. Contribution to a Hostile Environment:
   • The cumulative impact of the DWP’s unreasonable demands, lack of support, and disregard for my disabilities has created a hostile environment, significantly contributing to my distress and difficulties in securing stable housing and care.
   • Additionally, the treatment I have received from the DWP may constitute a breach of my human rights on multiple fronts. The extreme mental and emotional distress inflicted upon me, through their unreasonable demands and systemic neglect, may meet the criteria for torture as defined by the United Nations. The UN Convention Against Torture describes torture as any act by which severe pain or suffering, whether physical or mental, is intentionally inflicted for purposes such as coercion or punishment, which parallels the ongoing pressure and suffering I have endured. Moreover, this treatment may also represent a violation of my dignity and well-being under Article 8 of the Human Rights Act 1998, which protects the right to respect for private and family life. The cumulative impact of the DWP’s actions has severely compromised my ability to live with dignity and autonomy, further underlining the gravity of these violations.
   • The assessments that PIP or its private contractors made was negligent and another cumulative aspect of the harm caused against me. I was first thrown out for asking for qualifications then in the second attempt given 0 points by two people with no medical qualifications. I was then diagnosed autistic and I won the tribunal without participating in it, and people who have never met me or know anything about me, made decisions for the amount awarded based on complete guesswork. Regarding mobility, the most offensive thing they said was “Well, he must have no problem moving around because he does it so much”. I was incensed by this statement.
4. Failure in Benefit Administration Coordination

The housing benefit overpayment issue detailed in Section A(9) also implicates the DWP in its failure to properly coordinate with local councils and respond to changes in circumstances for vulnerable individuals. This incident further illustrates the DWP’s systemic failures in managing benefits for disabled claimants and highlights the need for improved communication processes between government agencies.

3. C. Healthcare Providers (NHS Trusts, GP Practices)

1. Neglect and Failure to Provide Timely Care:
   • Healthcare providers, including specific NHS trusts and GP practices, have consistently failed to provide timely and adequate care, particularly in response to mental health crises.
   • This neglect has left me without necessary medical and psychological support during critical periods, worsening my conditions and contributing to my overall vulnerability.
   • The new group that has taken over my doctors even tries to infringe my copyright in their privacy policy, and dictates that I cannot change a photo taken around their surgery. Since when do doctors surgeries have copyright on my face. Also putting the burden on me to contact them to tell them that I don’t want to be photographed is unreasonable, with yet more demands and forms.
2. Discriminatory Exclusion from Services:
   • I have been unjustly excluded from accessing healthcare services due to the way I communicate and my emotional responses, which are directly related to my disabilities.
   • I can show it makes no difference at all whether you are emotional or not anyway through the Atos recording which records my speech throughout and which shows them throwing me out of the building for asking for the professionals qualifications. In this recording they later claimed it was my own fault for my behaviour, the recording shows this is a lie. No complaint was ever answered despite multiple requests and as far as I know nobody was disciplined.
   • The exclusion from the Leeds practice effectively denied me access to essential medical care for years, further endangering my health and well-being.
3. Failure to Accommodate Communication and Sensory Needs:
   • The healthcare providers have failed to accommodate my specific communication and sensory needs, leading to increased distress during interactions and exacerbating my conditions.
   • These actions reflect a broader pattern of discrimination and neglect in the healthcare system.
4. D. Advocacy and Support Organizations
5. Failure to Provide Advocacy and Support:

1. Organizations such as Shelter, BASS, and other advocacy groups have failed to provide the necessary advocacy and support services, despite my clear need for assistance in navigating the complex systems I am dealing with. In Shelters case specifically ruling out mentioning or having anything to do with disability in my housing case, where I was left in an unsuitable property to endure extreme noise and had to leave the property at some points it was so bad.
2. Once again the local areas tie the advocacy places to only giving service to people e.g. KAG, within only Kingston. So anyone who is homeless is entirely unable to access them. I find myself in the position of being a mile away from them and im not in area. I told them I can walk there, and they tell me to go away. I also contacted every other advocacy place there and they all refused me.
3. This lack of support has significantly hindered my ability to secure housing, access healthcare, and address the ongoing discrimination I face.

2. Systemic Neglect and Inadequate Response:
   • These organizations have demonstrated systemic neglect in addressing my case, often failing to respond to requests for help or providing inadequate support when they do engage.
   • Their inaction has contributed to the worsening of my situation and has left me without the necessary resources to fight for my rights effectively to the point I cannot communicate with the councils or DWP at all for my own safety.
3. E. Legal Aid and CLA
4. Failure to Provide Adequate Support:

• Organizations such as Shelter and other advocacy groups have failed to provide necessary advocacy and support services, despite the Claimant’s clear need for assistance in navigating complex systems.
• This lack of support has significantly hindered the Claimant’s ability to secure housing, access healthcare, and address ongoing discrimination.
• Systemic Neglect and Inadequate Response:

• These organizations have demonstrated systemic neglect in addressing the Claimant’s case, often failing to respond to requests for help or providing inadequate support when they do engage.
• Their inaction has contributed to the worsening of the Claimant’s situation and left them without necessary resources to effectively fight for their rights.
• Barriers to Accessing Legal Aid:

• The current system for accessing legal aid creates insurmountable barriers, particularly for individuals with disabilities such as PTSD and autism.
• The multitude of tasks required by various bodies, coupled with the complexities of seeking legal assistance, imposes an unreasonable burden on vulnerable individuals.
• The arbitrary six-month time limit for initiating legal action is particularly discriminatory towards autistic individuals, who may require additional time to process information and seek appropriate support.
• Failure of Civil Legal Advice (CLA) Service:

• The CLA service failed to make reasonable adjustments as required by the Equality Act 2010 when the Claimant requested legal aid for this case.
• During a phone call, they refused to provide accommodations, denied the Claimant’s request to record the call, and the staff member’s unclear communication and inaccurate note-taking hindered the Claimant’s ability to access necessary legal support.
• Cumulative Impact of Legal Aid Failures:
• These systemic failures in the provision of legal aid and support services amount to: a) A breach of the right to access justice, potentially violating Article 6 of the Human Rights Act 1998 b) Discrimination against individuals with disabilities, contrary to the Equality Act 2010 c) A failure to make reasonable adjustments, as required by the Equality Act 2010 d) A de facto denial of legal representation for many vulnerable individuals, undermining the principle of equality before the law
• Impact on Broader Legal Issues:

• These barriers to accessing legal support have significantly impaired the Claimant’s ability to seek redress for numerous injustices, compounding the harm already suffered.
• This extends to other areas of the Claimant’s life, including potential exploitation in their music work, where lack of advocacy has hampered communications with major music industry entities.
• The prolonged period without stable housing further complicates the Claimant’s ability to address these issues within relevant limitation periods.

4. Urgency of Interim Relief:

Given the ongoing harm and imminent risk to my well-being, I urgently seek interim relief, including the immediate provision of suitable housing and the appointment of an advocate.

5. Request for Further Time:

I respectfully request the court’s permission to submit further particulars once I have obtained the necessary documentation, such as the Subject Access Requests (SARs), and have had the opportunity to organize the full extent of my claim. I would like to request the SAR data in electronic format, in one file, in a clear chronological format. I have had one from the DWP which was completely confusing and overwhelming in over 20 emails.

6. Relief Sought:

The Claimant respectfully seeks the following relief:

(a) The interim orders as detailed in Section (9) of this claim, including but not limited to:

• Immediate provision of suitable housing
• Appointment of a qualified advocate
• Comprehensive medical assessments

(b) General damages for the distress, anxiety, and harm caused by the defendants’ actions and omissions

(c) Special damages for quantifiable financial losses incurred as a result of the defendants’ conduct

(d) Declaratory relief confirming that the defendants have breached their statutory duties under the Equality Act 2010, Care Act 2014, and Human Rights Act 1998

(e) Mandatory injunctions requiring the defendants to:

• Implement specific reasonable adjustments
• Provide appropriate support services
• Rectify discriminatory policies and practices

(f) Exemplary damages due to the defendants’ oppressive, arbitrary, and discriminatory conduct

(g) Costs

(h) Such further or other relief as the Court deems just and appropriate

The Claimant reserves the right to amend or supplement this relief sought as further information becomes available through disclosure and evidence gathering.

7. Value of the Claim:

Please note, I am unable to fully present the value of the claim until a significant amount of work is done, particularly the collection and analysing of years of bank statements and of relevant SAR data. However, I anticipate it being substantial given the prolonged distress and harm caused. I request the court’s permission to postpone submitting the final value of the claim until this data is received.

8. HUMAN RIGHTS AND UNDUE BURDEN

1. The Claimant contends that the collective failures of the defendants have placed an undue burden on the Claimant to secure their basic rights, in violation of: a) Article 2 (right to life) of the Human Rights Act 1998, as the Claimant’s physical and mental health have been put at serious risk. b) Article 3, as the treatment amounts to inhuman and degrading treatment. c) Article 8, as the Claimant’s private life and wellbeing have been severely impacted. d) Article 14 (prohibition of discrimination) in conjunction with Articles 2, 3, and 8, as the Claimant has been discriminated against on the grounds of disability.
2. The burden placed on the Claimant to navigate complex systems while dealing with significant disabilities and trauma is itself a form of discrimination and a failure of the defendants’ duties under the Equality Act 2010.
3. The Claimant asserts that the right to life (Article 2) has been engaged due to: a) Prolonged homelessness and exposure to unsafe living conditions b) Denial of necessary medical care and assessments c) Severe impact on mental health, including exacerbation of cPTSD, self-care and other conditions
4. The cumulative effect of these failures has created a situation where the Claimant’s very survival has been put at risk, necessitating urgent intervention by the Court.

9. INTERIM ORDERS AND HUMAN RIGHTS CONSIDERATIONS

The Claimant seeks the following interim orders on an urgent basis:

1. Medical Assessments a) The Claimant requires immediate comprehensive assessments for misophonia, cPTSD, and other conditions by appropriately qualified specialists, specifically a clinical psychologist and the Oxford misophonia clinic b) These assessments are crucial not only for the Claimant’s health but also to provide evidence for suitable housing and support needs. c) The failure to provide these assessments to date has significantly impaired the Claimant’s ability to access appropriate services, in violation of Article 8 (right to private and family life) of the Human Rights Act 1998.
2. Emergency / Temporary or Permanent Suitable Housing a) The Claimant requires immediate provision of suitable housing that meets their specific needs, including: i) A quiet, private environment essential for managing misophonia and cPTSD ii) Location away from areas associated with past trauma (specifically not in Bristol) iii) Accommodation that allows for autonomy and healing b) The current homelessness and unsuitable housing options offered violate the Claimant’s rights under Article 3 (prohibition of inhuman or degrading treatment) and Article 8 of the Human Rights Act 1998. A recent abusive relationship and its impact on my well-being has been significant. The court should understand that any form of supported or communal living could be re-traumatising and detrimental to my recovery. My primary need is for a safe, private environment where I can heal and recover without interference, especially from any council. Being left alone in my own quiet and dark space is crucial for my mental health and recovery.
3. Appointment of Permanent Advocate a) The Claimant requires immediate appointment of a permanent advocate to assist with all communications with public bodies and service providers and to support me through exhausting court processes. b) This advocate should have the authority to act across different local authority areas to ensure continuity of support. c) The lack of appropriate advocacy support to date has effectively denied the Claimant access to services and justice, in violation of Article 6 (right to a fair trial) of the Human Rights Act 1998.
4. Protection from Further Transfers after Richmond The Claimant seeks an order to prevent further transfers between local authorities without explicit consent and unless demonstrably in the Claimant’s best interests, on the following grounds:
   
   

a) Repeated transfers have caused significant distress and disruption, violating the Claimant’s rights under Article 8 of the Human Rights Act 1998.

b) Each transfer necessitates re-establishing local connections and re-navigating complex bureaucratic processes, causing undue hardship and impeding access to consistent healthcare and support services.

c) The transient nature of these arrangements has exposed the Claimant to unsafe living conditions, including assault in temporary accommodation and prolonged exposure to harmful noise levels.

d) The ‘local connection’ requirement creates a six-month limbo period in each new location, leaving the Claimant without adequate support or stability.

e) This cycle of transfers and temporary accommodations has severely impacted the Claimant’s mental and physical health, exacerbating existing disabilities and creating new vulnerabilities.

f) The cumulative effect of these transfers constitutes a failure to make reasonable adjustments under the Equality Act 2010 and violates the Claimant’s right to adequate housing.

5. Disclosure of Subject Access Requests a) Immediate disclosure of all Subject Access Request information from all defendants is required. b) This information is crucial for the Claimant to fully present their case and has been wrongfully withheld, potentially in violation of Article 6 of the Human Rights Act 1998 and GDPR.
6. Order to Prevent Further Harm and Trauma: To protect my well-being during this process. I request that the court orders the council and any other relevant authorities to ensure that any interactions with me are conducted in a manner that does not re-traumatise me, with a focus on providing the necessary support without undue stress or bureaucratic burden and with extreme attention to clarity.
7. Requirement for Bristol City Council to Provide Clarification on Autism-Specific Housing: I respectfully request that the court compels Bristol City Council to provide a clear, direct, and unambiguous answer to the question I have repeatedly posed: “Has the council procured any housing specifically designed to meet the needs of autistic individuals requiring a quiet, autonomous living environment?”. The council’s persistent avoidance of this question has caused me significant distress and has actively consumed my cognitive resources. As an autistic individual, the lack of a clear response creates an ongoing mental burden that interferes with my ability to focus on other critical matters. Furthermore, I request that the council clarify whether they have made any genuine efforts to procure or allocate housing with the specific needs of autistic individuals in mind. It appears that the council may be outsourcing this responsibility to third-party companies, a practice which I believe to be detrimental to the effective provision of suitable accommodations. Attempts to seek clarity directly from these third-party providers have been met with dismissive and unprofessional conduct, including abruptly terminating phone calls when basic questions were asked. The council’s failure to provide transparency on this matter, despite numerous requests, not only violates the principles of good governance but also contributes to the hostile environment experienced by autistic individuals seeking appropriate housing and support. I urge the court to recognise the profound impact that the council’s evasiveness has had on my well-being and my ability to progress with my life. By compelling the council to provide a clear, substantive response to this fundamental question, the court can alleviate a significant source of ongoing distress and enable me to focus on other critical aspects of my case and my personal circumstances.
8. Financial Assistance for Property Retrieval a) The Claimant urgently requires financial assistance to retrieve personal belongings left at a previous location due to sudden homelessness. b) Despite requests to the council for help, including asking them to explore all possible avenues and to inform the DWP, no assistance has been provided. c) The Claimant seeks an order for immediate financial support to facilitate the safe return of these belongings, on the following grounds: i) The inability to access personal possessions is causing significant daily distress, further impacting the Claimant’s mental health and ability to function. ii) This situation is directly impeding the Claimant’s ability to do any potential work and maintain stability. iii) The council’s failure to respond to this request or to explore potential solutions represents a further failure in their duty of care. iv) The continued separation from personal belongings exacerbates the Claimant’s sense of displacement and instability, contrary to the aims of the Care Act 2014 and the council’s obligations under it. d) The Claimant requests that the court compel the relevant authorities to provide immediate financial assistance for the retrieval of these belongings, or to facilitate their return through other means.
9. Completion of Care Act Assessment by Qualified Professional a) The Claimant demands an immediate and thorough Care Act assessment, to be conducted by a qualified medical professional with expertise in autism and complex needs, rather than council staff who lack the necessary qualifications. b) This assessment has been pending for over 5 years, constituting a severe breach of the council’s statutory duties under the Care Act 2014. c) The Claimant contends that the current assessment practices employed by the council are inadequate, potentially medically negligent, and particularly ill-suited to identifying and addressing “hidden disabilities”. d) The assessment must be comprehensive, taking into account all aspects of the Claimant’s needs, including but not limited to autism, misophonia, cPTSD, and any other relevant conditions. e) The results of this assessment should be used to inform and guide the provision of appropriate support and accommodations across all relevant services. f) The Claimant requests that this assessment be conducted without direct contact between the Claimant and council staff, to prevent further distress and potential re-traumatization.

Conclusion

The Claimant respectfully submits that the evidence presented in these Particulars of Claim demonstrates a pervasive and systemic failure by multiple public bodies to meet their legal obligations towards a vulnerable individual with complex needs. The cumulative impact of these failures has resulted in prolonged homelessness, deteriorating physical and mental health, and a persistent denial of basic rights and dignity.

The urgency of this situation cannot be overstated. Each day that passes without appropriate intervention further jeopardizes the Claimant’s well-being and exacerbates the harm already suffered. The Claimant contends that only through immediate and decisive action by this Court can their fundamental rights be protected and the cycle of institutional neglect and discrimination be broken.

The Claimant therefore implores the Court to grant the interim relief sought as a matter of utmost urgency, and to recognize the gravity and systemic nature of the failures outlined in this claim. Swift and comprehensive judicial intervention is not just necessary, but critical to prevent further irreparable harm and to uphold the principles of justice, equality, and human dignity that our society purports to value.