Subject: Request for Internal Review — 26FOI 103 — response dated 22 September 2026 From: Sion Buckler Direction: sent Date: Mon, 28 Sep 2026 21:41 UTC Institution: Wales Office Refs: 26FOI103 Archive id: gm-1a0e9f79f658c66c ------------------------------------------------------------ Freedom of Information Team Wales Office Gwydyr House Whitehall London [postcode redacted] [email redacted] cc: [email redacted] — the mailbox that sent the acknowledgement and the response Dear Sir or Madam, Request for Internal Review — 26FOI 103 — response dated 22 September 2026 Requester: Sion Buckler I request an internal review of the handling and substance of 26FOI 103. This is an FOI review only. I am not asking the Wales Office to determine title, to reopen BP Properties Ltd v Buckler, or to adopt any party's case on the land. I am asking whether the letter of 22 September 2026 answered the request that was made, and whether the search described in it was adequate. A. What is already on this file 1. 29 August 2026 — I asked the Wales Office for recorded information about Great House Farm. Your letter of 22 September quotes the request as five points. I adopt that quotation. The points were: - records of any communication or outreach between Cadw, or its predecessor functions, and the Office of the Secretary of State for Wales / Welsh Office concerning Great House Farm during July–December 1988; - records of any recommendation, briefing, submission, notification or formal appeal concerning the protection or listing of Great House Farm submitted to the Secretary of State; - records of any communications with the occupiers and owners of the property before the refusal decision of 5 December 1988; - any surviving destruction, disposal, transfer or accession documentation relating to the Great House Farm 1988 assessment file, including certificates, dockets, lists, database entries, retention schedules, disposal authorities or other contemporaneous records held by the Welsh Office, its predecessors, Cadw, or any repository to which relevant records were transferred; - information regarding a decision made in relation to Great House Farm in 1988, including the evidence that was used to support that decision. 2. 8 September 2026 — acknowledgement from NIO FOI ([email redacted]), recording the request date as 29/08/26. It named no officer and described no search. 3. 22 September 2026 — covering email from the same NIO FOI mailbox, attaching “26FOI 103 - Buckler - Response.pdf”. The covering email contained no substance. The letter is signed Freedom of Information Team, Wales Office, and directs any review to [email redacted]. This review is within the two calendar months stated in that letter. The deadline you gave is 22 November 2026. B. What the letter actually says, and what it does not The operative paragraph is this: “We have carried out a search of our digital records and have determined that the Wales Office does not hold the information requested. Any paper files previously held by the former Welsh Office relating to this matter would have been transferred to the National Assembly for Wales in 1999, and subsequently to the Welsh Government in 2007.” That paragraph does not answer the request. The gaps are these. 1. Digital records only. The letter says a search of digital records. It does not say that paper, microfilm, card indexes, transfer lists, accession registers, or destruction schedules were searched. A 1988 Welsh Office file is a paper file. A search confined to current digital holdings cannot find it, and cannot find the transfer or destruction docket that the fourth bullet asked for. 2. “Would have been transferred” is not a search result. It is an assumption about devolution. It is not a statement that a transfer list was consulted, that a file for this house appears on that list, or that the file was received in Cardiff. “Would have been” covers three different outcomes: transferred, destroyed, or still here under another description. The letter does not distinguish them. 3. The fourth bullet asked for the transfer, disposal and accession records themselves. Those records, if they exist, are Wales Office records of what left the building. They are not the assessment file. Pointing me to the Welsh Government does not answer a request for the docket, the list, the database entry or the disposal authority. Those may still be held here even if the file went to Cardiff. The letter does not say they were searched for. 4. The five bullets are not answered one by one. There is no finding on communications with Cadw; no finding on any briefing or appeal to the Secretary of State; no finding on communications with occupiers and owners before 5 December 1988; no finding on the evidence said to have supported a 1988 decision. A single sentence that digital records do not hold “the information requested” does not show that each limb was searched. 5. The letter uses “the refusal decision of 5 December 1988” only because I used it. It does not say whether that decision is recognised, whether a file for it was identified, or whether the decision is one of the papers “which would have been transferred”. Silence on a dated decision is not a not-held finding. 6. “You may therefore wish” is not section 16 advice. Section 16 requires advice and assistance so far as reasonable. A reasonable step, where the department asserts a transfer, is to give the receiving body's file reference, the date of transfer, and the series. None is given. If the intention was section 21 (information reasonably accessible elsewhere), that exemption is not named, and the conditions are not addressed. A suggestion that I write to [email redacted] is not a section 21 notice. 7. “Does not hold” is stated as a conclusion. The search described cannot support it. A not-held finding under section 1 requires a search capable of finding the information. A search of digital records, plus an assumption about 1999, is not that search. 8. The request was answered from a Northern Ireland Office mailbox. The letter is in the name of the Wales Office. The review must be of the Wales Office search. Please confirm it will not be taken by the person who signed the 22 September letter. C. What the reviewing officer is asked to determine 1. What was searched, by name: digital systems, paper series, transfer lists, accession registers, destruction schedules, Gwydyr House holdings, and any index of files passed to the National Assembly in 1999 or to the Welsh Government in 2007. If a location was not searched, say so. 2. For each of the five bullets, a separate finding: held, not held after the searches at (1), transferred (with date, recipient and reference), or destroyed (with date and disposal authority). 3. Whether any transfer, disposal or accession record relating to a Great House Farm 1988 assessment file is held by this department, as distinct from the assessment file itself. 4. Whether any record of a decision on or about 5 December 1988, or of communications with the occupiers or owners before that date, was identified even as an index entry. 5. If information is held and is not to be disclosed, a section 17 notice naming the exemption. Do not replace that notice with a referral. 6. If the review maintains that the file went to Cardiff, the transfer reference. Without it, the referral is an assertion. D. Scope, so the review is not narrowed again The window is July–December 1988. Possession of Great House Farm / Tŷ Mawr, Llandough, adjoining St Dochdwy's, was taken on 29 November 1988. Demolition of the farmhouse began on 6 December 1988. The refusal date in the request is 5 December 1988. Those dates fix the search. They do not ask you to decide the land. I have made a parallel request to the Welsh Government, following the referral. That does not discharge 26FOI 103. A file can have been transferred and the transfer docket can still be here. Both questions were asked. Only one was gestured at. E. Why these records are in scope, without asking you to decide title The public index is https://greathousefarmwiki.wordpress.com/ The investigation distinguishes Parcel A (farmhouse, garden, buildings and yard — the family's maintained freehold interest out of the Bute estate) from Parcel B (eastern fields). Later papers use “whole farm”. BP Properties Ltd v Buckler [1987] EWCA Civ 2 decided possession, limitation and the October 1974 letters. It did not decide the documentary root of Parcel A. Whether the Secretary of State or Cadw looked at this house in the week it was refused and pulled down is a records question. It is not a request that you adopt the family's case. F. Preservation Please preserve any record that may fall within 26FOI 103 while this review is open, including transfer lists, destruction schedules and anything due for routine disposal. Do not transfer or destroy in-scope material without a written receipt that can be disclosed on the review. G. Reservation This letter does not waive any position on title, registration, concealment, limitation, or any later reopening. It is an internal review under the Freedom of Information Act 2000. It is not a claim form and is not service of proceedings. Please acknowledge receipt, give the review reference, and state the date by which the review will be completed. ICO guidance is that an internal review should normally be completed within 20 working days. Yours faithfully, Sion Buckler (Ret'd Sergeant) Royal Signals [email redacted]