Subject: Great House Farm, Llandough From: Sion Buckler Direction: sent Date: Sat, 26 Sep 2026 19:09 UTC Institution: HM Land Registry (Independent Complaints Reviewer) Refs: none Archive id: gm-1a0df1f896c4122a ------------------------------------------------------------ Dear Sirs, I am seeking an independent review of HM Land Registry's handling of my complaint concerning the historic registration of land belonging to the Williams/Buckler family at Great House Farm / Tŷ Mawr, Llandough, Cardiff, and the subsequent registered title history, including WA231076, WA240304 and the later woodland title WA735527. HM Land Registry has now replied to my MP and has maintained, in essence, that it does not accept that a mistake was made. My concern is not simply that HM Land Registry reached a conclusion with which I disagree. It is that the conclusion appears to leave fundamental documentary questions unanswered and relies heavily upon historical proceedings which did not determine the underlying documentary root of the family's ownership claim. I have spent approximately twenty years researching this matter and have assembled a substantial body of documentary, archival, court, Land Registry and family evidence. I am not asking ICR to determine ownership itself. I am asking it to review whether HM Land Registry properly investigated and answered the complaint put before it, whether it addressed the evidence I supplied, and whether the reasons given for its conclusion adequately explain how the disputed registration was accepted and subsequently maintained. 1. The underlying family ownership claim The family's position is that our historic Parcel A was a distinct parcel of land around the farmhouse and woodland and that our underlying freehold interest was never lawfully extinguished. My grandmother, Mary Williams, consistently asserted ownership of the family parcel. The documentary history presently available to me raises a substantial question as to whether Parcel A was ever conveyed to Western Ground Rents in the manner subsequently assumed. There is an important distinction between: - the family-occupied Parcel A surrounding the farmhouse; and - the eastern agricultural Parcel B which was the subject of the later agricultural tenancy arrangements. The 1939 revised agricultural tenancy documentation which I have located appears to concern Parcel B and its associated land. The accompanying plan does not appear to include the family-occupied Parcel A. This raises a basic documentary question: What instrument actually conveyed Parcel A to Western Ground Rents, if it was ever conveyed to them at all? I have not yet obtained a document which satisfactorily answers that question. 2. The 1928 / 1938 / 1939 documentary sequence The present reconstruction begins with the 1877 arrangements involving the Marquess of Bute and Daniel Thomas & Son and the subsequent quarrying arrangements. My understanding from the evidence presently assembled is that the relevant quarrying arrangements were completed by 1928 and that the family thereafter continued in occupation of Parcel A as its own land. The later 1938 conveyancing from the Bute estate to Western Ground Rents therefore requires close examination as to precisely what land was conveyed. This is particularly important because the 1939 revised agricultural tenancy record naming Western Ground Rents as landlord appears, from its plan, to concern Parcel B rather than Parcel A. That record was brought to my attention by the clerk for Llandough Town, who directed me to the archive material shortly before his retirement earlier this year. If Parcel A was not conveyed to Western Ground Rents in 1938, and was not included in the 1939 agricultural tenancy, the subsequent legal narrative by which the family's occupation came to be treated as permissive requires considerably more examination than HM Land Registry's present response appears to have given it. 3. The successive attempts to characterise the family occupation as permissive The historical evidence reveals a sequence of events which I believe needs to be examined as a whole rather than in isolation. These include: *1949* — an attempted tenancy arrangement concerning Parcel B which appears to have sought to include my grandmother in the tenancy and thereby connect her occupation of Parcel A with the agricultural tenancy of Parcel B; *1951* — the disappearance of important family papers, including the family's title documentation, which my grandmother reported as stolen; *1955* — possession proceedings in which the language concerning the “whole farm” requires comparison with the actual definition of the agricultural holding and its separate parcels. The order also expressly excluded the “house and garden” and referred to my grandmother's “condition and resistance”; *1959* — an offer of a tenancy of the farmhouse and garden, which my grandmother rejected while continuing to assert an ownership claim; *1962* — a possession order concerning the farmhouse and garden, the legal effect and subsequent enforcement history of which require examination; *1965* — a further attempt to place “Mrs Williams” into a weekly tenancy, again rejected; *1974* — an ownership action was adjourned; leave to enforce the 1962 possession order was obtained but the warrant was not pursued; and BP subsequently relied upon the two letters of 31 October 1974 as establishing a licence relationship. The family interpretation is that these were not independent, isolated events but a succession of attempts to convert or present an allegedly proprietary occupation as permissive. I appreciate that this is an interpretation requiring documentary testing. That is precisely why I believe HM Land Registry should have engaged with the underlying documents rather than treating the later registered position and the 1987 Court of Appeal judgment as effectively resolving the matter. 4. The 1987 judgment does not answer the documentary provenance question A particularly important part of my complaint concerns the way HM Land Registry has relied upon *BP Properties Ltd v Buckler* [1987] EWCA Civ 2. I do not dispute that this was an important Court of Appeal decision. However, the case concerned the adverse-possession and possession issues concerning the farmhouse and garden. The Court considered the registered/paper-title position relied upon by BP, the previous possession proceedings and the legal effect of the 1974 letters upon the character of Mrs Buckler's occupation. The judgment itself records that Mary Williams had asserted that she had a title to Great House Farm through her grandfather and believed that documents existed establishing that title, but that such documents were not produced. The point is therefore not that the Court of Appeal “never touched title”. It plainly considered BP's registered/paper-title position. The point is narrower and, in my view, fundamental: The 1987 judgment is not itself the conveyance, plan, root deed or other documentary instrument establishing how the woodland and the family's historic Parcel A entered BP's registered title. Nor did it adjudicate the validity of Forest of Cardiff's separate 1994 acquisition of the woodland. I am concerned that HM Land Registry's present response treats the 1987 judgment as though it answers a documentary provenance question which it did not determine. 5. The 1969 conveyance and 1971 abstract HM Land Registry has also told me that BP supplied a title chain extending back to 1969. That raises another substantial documentary issue. There were only thirteen years between the 1969 conveyance and BP's first registration in 1982. The 1969 conveyance from Western Ground Rents to BP Pension Trust therefore requires examination as to exactly what proprietary interest was being conveyed. I understand the later title documentation to recite the 1969 conveyance as a root document, while the 1971 abstract refers to the 1962 possession order and an OS plan. If the underlying title to Parcel A was never conveyed to Western Ground Rents, the critical question is how an asserted interest arising from possession proceedings could subsequently be treated as though it were documentary title to the parcel itself. The 1971 abstract is therefore particularly important. HM Land Registry's own correspondence has recorded that such an abstract was lodged. The 30 July 2026 schedule of surviving first-registration documents does not identify the 31 December 1969 conveyance itself, nor does it resolve the evidential gap concerning the 1971 abstract. I am continuing to pursue those underlying records. 6. The 1982–83 registrations My principal concern is that BP may have registered not the family's actual historic Parcel A, supported by a lawful root title, but a later constructed or “synthetic” parcel derived from the succession of possession, tenancy and licence documents which had been used to characterise the family occupation as permissive. I use “synthetic parcel” as a description of the issue I am investigating, not as a statement that this is already legally established. The essential question is: What precise land did BP apply to register in 1982–83, what documentary instrument entitled BP to register that land, and did that land correspond to the land actually conveyed to BP's predecessors? The later amalgamation of the BP titles is also significant because what may have originated as separate parcels or interests appears subsequently to have been brought together within the registered estate. It is necessary to establish whether that process merely recorded an existing lawful title or whether it caused an underlying proprietary boundary to disappear within a later registered estate. 7. HM Land Registry's response HM Land Registry has now maintained that it was correct to register the land and has relied, in part, upon the 1987 judgment. I respectfully submit that this does not answer the complaint. An administrative conclusion that a registration was “correct” cannot itself reconstruct a missing conveyance, establish the precise boundary of land conveyed decades earlier, or demonstrate that a later registered proprietor had documentary title to a distinct parcel where the underlying conveyancing remains disputed. Nor does the existence of the 1987 judgment establish the documentary provenance of WA735527 or the validity of the separate 1994 transfer to Forest of Cardiff. I am particularly concerned that HM Land Registry appears to regard its reliance upon the 1987 judgment as effectively validating the 1982–83 registration, when the registration itself pre-dated the judgment. The chronology matters. The registration came first. The litigation came afterwards. I therefore cannot see how a later judgment concerning possession and adverse possession can, without further analysis, resolve whether the earlier registration accurately represented the documentary title existing at the date of registration. 8. Notification and my grandmother's death Another issue which requires consideration is notification. To my knowledge, the family was not notified that BP had applied to register the relevant land in 1982. My grandmother died on 14 March 1983, shortly after the first registration and within the period in which the registration would have been capable of being challenged had she known of it. She had spent decades rejecting attempts to characterise her occupation as permissive and consistently maintaining an ownership claim. The fact that she died shortly after the registration is not itself proof of wrongdoing. It is, however, a material chronological fact when considering whether she had a meaningful opportunity to challenge the registration and whether HM Land Registry appropriately considered the notification history. I ask the ICR to consider whether HM Land Registry has adequately addressed: - what notice was given of the 1982 application; - to whom it was given; - what information was supplied to the persons potentially affected; - whether any competing ownership claim was disclosed by the applicant; - and what records exist showing how HM Land Registry assessed those matters. 9. Possible fraud, concealment and institutional involvement Through my research I have also identified matters which I consider may warrant investigation for possible fraud, deliberate concealment, misrepresentation, mistake and institutional involvement. I want to be precise about this. I am not asking the ICR to find that fraud occurred. I am asking the ICR to consider whether HM Land Registry adequately investigated evidence raising those questions, particularly where the evidence concerns missing historic documents, the distinction between Parcel A and Parcel B, the provenance of the 1969 title, the 1971 abstract, the 1982–83 registrations and the subsequent amalgamation of titles. I have deliberately distinguished established documentary facts from matters which remain hypotheses requiring investigation. There are also serious questions concerning the destruction or absence of historical records and the later treatment of the land. Those matters are being pursued through separate archival and documentary channels. 10. The human and public-interest dimension This is not merely an abstract registration dispute. My grandmother was a disabled widow and amputee who maintained an ownership claim to the family land through decades of litigation and repeated attempts to characterise her occupation as permissive. The family was ultimately removed from the property in 1988. The historic farmhouse, which had been our family home and which we believe had significant architectural and historic importance, was subsequently demolished. I was a child when we were removed. Family possessions and historic material were lost or dispersed, while the land was subsequently developed and altered. The family's connection with the site is recorded as extending back to the seventeenth century, and I was born at Great House Farm. There are also wider heritage and archaeological questions concerning the site and its subsequent development, which I am investigating separately. I mention these matters because they explain why I have continued the investigation for approximately twenty years and why the accuracy of the underlying land record matters so profoundly to my family. My professional background is in military cyber and electronic warfare, and much of my research has involved reconstructing fragmented documentary histories and identifying discrepancies between records. I have approached this as an evidential investigation rather than simply as a family grievance. 11. Why I am approaching the ICR I therefore ask the ICR to review HM Land Registry's handling of my complaint and, in particular, whether it: 1. adequately investigated the distinction between historic Parcel A and Parcel B; 2. adequately considered the 1938 conveyance and 1939 revised tenancy plan; 3. adequately addressed the documentary provenance of the 1969 conveyance and the 1971 abstract; 4. adequately examined the precise land comprised in the 1982–83 registration applications; 5. relied upon the 1987 *BP v Buckler* judgment for a proposition which the judgment itself did not determine; 6. adequately considered the chronology whereby the 1982–83 registration preceded the 1987 judgment; 7. adequately investigated the notification given to persons asserting ownership of the land; 8. adequately addressed the missing or unavailable historic documents and the evidential gaps I have identified; 9. adequately considered the evidence I supplied rather than simply reaffirming the existing registered position; and 10. provided reasons sufficient to explain why, notwithstanding those unresolved documentary questions, HM Land Registry considers that no mistake or registration error occurred. I am not asking the ICR to adjudicate the family's ultimate title claim. I am asking for an independent examination of whether HM Land Registry's investigation and reasoning were adequate, proportionate and properly responsive to the evidence and issues actually raised. 12. Documents and evidence I can provide the relevant correspondence with HM Land Registry, the response to my MP, registration material, historical conveyancing, court records, archival plans, family evidence and other documents relied upon in my complaint. I also maintain a detailed chronology of the matter, including: 1916 — agricultural tenancy; 1928 — completion of the relevant quarrying arrangements; 1938 — Bute / Western Ground Rents conveyancing; 1939 — revised agricultural tenancy and plan; 1949 — tenancy attempt; 1951 — missing/stolen title documentation issue; 1955 — possession proceedings; 1959 — farmhouse and garden tenancy offer; 1962 — possession order; 1965 — further tenancy attempt; 1969 — Western Ground Rents → BP Pension Trust conveyance; 1971 — abstract and plan material; 1974 — ownership proceedings, possession enforcement history and licence letters; 1975 — BP Pension Trust → BP Properties transfer; 1982 — first registration; 1983 — subsequent registration and title dealings; 1987 — *BP Properties Ltd v Buckler* Court of Appeal judgment; 1988 — final removal from the farmhouse and demolition; and 1994 — subsequent acquisition of the woodland by Forest of Cardiff. The chronology is significant because it demonstrates why I do not consider the 1987 judgment, standing alone, capable of answering the earlier registration question. 13. What I am asking for I respectfully ask the ICR to accept this as a request for independent review of HM Land Registry's handling of the complaint. In particular, I ask that the reviewer consider whether HM Land Registry has actually answered the documentary questions raised, rather than merely reaffirming the registered position. I would also ask that the underlying Land Registry records relevant to the 1982–83 registration, notification, supporting title documents, plans, the 1969 conveyance and the 1971 abstract be considered where they remain available. I am not seeking a finding against individual Land Registry staff. I am seeking an independent assessment of whether the institution's handling of this matter has been adequate and whether the reasons given for refusing to recognise a possible mistake are properly supported by the underlying record. The issue remains live because the disputed land is now being dealt with through subsequent titles and, in the case of the woodland, is presently subject to a proposed disposal by Forest of Cardiff. I therefore respectfully ask the ICR to consider this matter on the basis of the documentary chronology and evidence rather than treating the existence of the current register as dispositive of the historical question. I am willing to provide a structured evidence bundle and chronology to assist the review. Yours faithfully, Sion Buckler (Ret'd Sergeant) Royal Signals Cyber/Electronic Warfare Professional and Life Member