Subject: Z084NQV / N610CGV – WA240304 and WA231076 – application to alter the register (Schedule 4 LRA 2002) and follow-up on the 1983 first registration
From: Sion Buckler
Direction: sent
Date: Thu, 15 Oct 2026 23:00 UTC
Institution: HM Land Registry
Refs: ICR/090/26, N610CGV, Z084NQV
Archive id: gm-1a141cb5de1ebfc1
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Dear HM Land Registry,

References: N610CGV; Z084NQV (error investigation application); enquiries 260917-6718215, 260928-6762800, 260929-6766714, 261007-6799563.
Titles: WA240304 (closed) and WA231076.
Land: north side of Leckwith Road, Llandough (Great House Farm / Tŷ Mawr).

1. What this email is

(a) It asks the Registrar to consider alteration of the register under Schedule 4 to the Land Registration Act 2002, and indemnity under Schedule 8. Please add it to Z084NQV.
(b) It supplements my emails of 30 July, 12 August, 16 September (points 1 to 14), 18 September, 27 September and 7 October 2026. Where a point repeats an earlier question I say so. Those questions remain unanswered. Points marked NEW have not been put to the Registry before.
(c) It is limited to the first registration of WA240304 in 1983 and what followed to 1987. It does not deal with the 1982 application or the eastern land, and I waive nothing on either.

Your enquiry 260917-6714796 says the Registry can no longer service mail sent to individual addresses. Please treat this email as received on the date sent and confirm receipt against Z084NQV.

Copies go to the Independent Complaints Reviewer (ICR/090/26), Stephen Doughty MP, who raised this matter with the Registry, and Llandough Community Council, which holds related local records.

I am not asking you to decide who owns the land. I am asking what the Registry examined, what it relied on and what its records show. The dates come from your schedule of 30 July 2026, your letters of 23 March, 19 April and 25 May 2026, and the WA231076 register accessed on 19 September 2026.

Public working evidence catalogue: https://greathousefarmwiki.wordpress.com
Title and chronology index: https://dartboard.bucklerfamily.estate and https://bpvsbuckler.bucklerfamily.estate
Long-term archive: https://wayback.bucklerfamily.estate

2. The 1983 record on your own schedule

- 23 February 1983: form 1C application from Linklaters & Paines (WA240304 item 11), and a register edition of the same date (item 10).
- 26 March 1983: Mary Williams, the occupier of the farmhouse, died.
- 8 April 1983: form D23 ("inside exam") and a Linklaters & Paines letter (WA240304 item 7).
- 12 April 1983: customer correspondence (item 4), plus undated letters (item 5).
- 12 May 1983: several letters between Linklaters & Paines and the Registry (WA231076 item 16).
- 13 January 1984: form A3 application (item 15) and a new register edition (item 23).
- 22 May 1984: BP's writ for possession. This is chronology only, not evidence of what the Registry knew in 1983.
- 2 February 1987: application to amalgamate (WA231076 item 14). Your schedule says the WA240304 copy of the form has "no annotation on it".

3. Points arising

3.1 Root of title and class of title. Raised before: my email of 16 September (points 10 and 13) and my ICR referral. NEW detail: your stage one letter says a full documentary title commencing with a good root at least 15 years old should normally establish title. It then concluded a good root was shown and that BP Pension Trust acquired the land in 1969. That conclusion rests on the recital in the 1975 conveyance, which refers to a conveyance of 31 December 1969. The 1969 deed itself is not on your schedule. The recited root was about 13 years 2 months old on 23 February 1983. The letter also quotes the 1975 recital as giving the year as "One thousand One hundred and sixty nine". Please confirm the original reads 1969. Please say which documents the Registry relied on as the root, whether any exception or alternative procedure was used (and under which provision of the 1925 Act), why absolute title was accepted, and the class of title first entered for WA240304.

3.2 The 1971 abstract. Raised before: 30 July, 12 August and 16 September (points 1 and 8). Your letter says a 1971 abstract was lodged with the WA231076 application and that the Registry "had sight of" one for WA240304. Neither schedule lists it. NEW: a 1971 abstract cannot evidence a conveyance of 1975. What evidenced that conveyance?

3.3 Extent and plans. Raised before in part: 18 September. NEW: WA240304 item 1 is a plan to the conveyance of 23 May 1975, but item 13 is a plan "to conveyance dated 23 February 1975". Please reconcile those dates and say which plan governed the registration. The WA231076 register records that the 1975 conveyance plan is "filed under WA240304", which is now a closed title. Please supply the original title plan (item 9) and both plans. Please also identify the land conveyed in 1975 and the vendors' "Retained Land", the capacity in which each vendor conveyed, and how the extents of the two titles related immediately before amalgamation, including any overlap. The register also records that a new filed plan was substituted on 5 January 1995. Please supply the plan it replaced and confirm the extent did not change.

3.4 The occupier and what the Registry knew. Raised before in part: 16 September (points 4 and 12), 27 September, and ICR/090/26. Mary Williams was in actual occupation of the farmhouse in February and March 1983. The history includes the 1955 order against Frederick Buckler alone, the 1962 order against Frederick and Mary for the farmhouse and garden (not enforced), and the 1974 county court action in which Mary pleaded ownership, which was part-heard and never concluded. NEW: stage two says the Registry "were unaware of any dispute that was possibly ongoing". Yet WA240304 holds an inside examination (D23) and letters of 8 and 12 April 1983, and WA231076 holds letters between the applicant's solicitors and the Registry of 12 May 1983. Please say what enquiry was made of the occupier (Land Registration Act 1925 s.70(1)(g)), what inspection was done, and what those letters said about occupation, possession proceedings or the 1974 action. Please supply the D23 examination record.

3.5 The solicitors' certificate. Raised before: 30 July and 16 September (points 2 and 9). Stage one relied on certificate wording from form FR1. The 1983 application was on form 1C. Please supply form 1C as lodged and say what it certified about any question or doubt affecting title.

3.6 Notice and caution. Raised before: my email of 27 September (the family's case) and ICR/090/26. NEW: stage two says my family could have applied for a caution. That requires knowing of the application. Please produce every notice and service record for WA240304, as sent, showing the title it concerned, the addressee's name, the address, the date and any proof of delivery. A notice addressed to Mary Williams and issued or received after 26 March 1983 went to a person who had died. If it went to "Mrs Williams" at the property, I ask whether that was the right name and the right household. I am not asserting that this happened. I am asking for the record.

3.7 The 1987 judgment and the amalgamation. Raised before: 16 September (point 14) and ICR/090/26. Stage one said it is not for the Registrar to look behind decisions of the Court. The Court of Appeal considered adverse possession, the 1962 order and the 1974 letters. As I read it, it did not review the Registry's examination of title, the documents supplied or the notices. Please say precisely what HMLR says that judgment established and which parts of its 1983 process it says the judgment answers. NEW: please provide the application, decision and completion dates of the amalgamation, the instrument and plans relied on, the power used, and whether the registered extent changed or only the structure of the register. HMLR has also given the closure of WA240304 as 1987 (the amalgamation) and as 2005 (your email of 21 September 2026, enquiry 260919-6726246). Please state the actual date and the entry that records it.

3.8 What the complaint decisions examined. Raised before: ICR/090/26. The itemised schedule reached me on 30 July 2026, after both decisions. NEW: stage two says the reviewer examined "the evidence lodged in support of the application". Please confirm which original first-registration documents each decision-maker examined, whether the absence of the 1969 conveyance was identified, and provide the recorded basis for the conclusions reached.

3.9 The 1994 corrections. NEW to the Registry (raised only with the ICR). WA231076 items 12 and 22 are applications "to correct the title", dated 20 January 1994 and 13 October 1994. Stage one and stage two found no evidence of a mistake. Please say what was corrected, on whose application, under what authority, on what evidence, and whether the registered extent changed, including land derived from WA240304.

4. Schedule 4 (mistake and rectification) and Schedule 8 (indemnity). NEW

A. Mistake. I understand Schedule 4 now governs alteration of the register as it stands, including entries made in 1983 under the 1925 Act. The Registrar may alter the register to correct a mistake (paragraph 5(a)). Practice Guide 39 gives "including too much land in a registered title" as an example. I say there is a possible mistake in the 1983 entry in two respects: absolute title entered on a root that is not on the file (3.1 and 3.2), and an extent fixed by plans that do not reconcile (3.3). Please state whether HMLR accepts either as a mistake.

B. Possession and proper care. Practice Guide 39 (sections 1.3 and 1.4) says a registered proprietor in possession is protected unless it caused or contributed to the mistake by fraud or lack of proper care, or unless it would be unjust not to correct. Possession means physical possession. Please say who is in physical possession of the land affected. Practice Guide 39 (appendix 12.3.1) gives as an example a solicitor on a first registration who fails to lodge all the documents in their possession. Please say whether the applicant's solicitors lodged every document in their possession in 1983, including the 1969 conveyance and the abstract, and whether HMLR considers that bears on this protection. I do not assert that anything was withheld.

C. Class of title and overriding interests. Practice Guide 39 (section 1.1) says an alteration can give effect to an estate, right or interest not affected by registration where land is registered with good leasehold, possessory or qualified title. If the root evidence supported no more than that, the class entered may itself be the mistake. Section 1.2 says an alteration reflecting an overriding interest is not rectification. Please say whether HMLR accepts that an occupier's rights in 1983 could be recorded without that being rectification, and how it would deal with them.

D. Indemnity and process. Please confirm Z084NQV is being treated as a formal application for alteration, or tell me what form and fee are required (Practice Guide 39 section 2.1; rule 13 of the Land Registration Rules 2003). Practice Guide 39 says anyone may apply, and the fee may be refunded where the Registry caused the error. Indemnity time runs for six years from when the claimant knew or should have known of the claim (Schedule 8 paragraph 8). The family first saw the file schedule on 30 July 2026. Please confirm HMLR will treat any claim as in time. Please also give your consent under Schedule 8 paragraph 3 to reasonable costs, including copy fees at £11 per document. Where indemnity is not available, please consider whether a payment for maladministration is appropriate (Practice Guide 39 section 11).

5. Anticipated responses

- "The amalgamation was administrative tidying." Points 3.3 and 3.7 ask whether it altered the registered extent. Points 3.1 and 3.2 go to the examination of title, not to the structure of the register.
- "The missing documents' contents are unknown, so absence of evidence is not evidence of absence." That is why I ask for the files to be read and the examination record produced.
- "The Registry may rely on the solicitors' certificate." Please produce the certificate actually given on form 1C (3.5).
- "The registrar may approve a title open to objection where the holding is unlikely to be disturbed (section 13 of the 1925 Act, and section 9(3) of the 2002 Act)." If HMLR relied on that discretion, please identify the defect considered, the contemporaneous evidence supporting the opinion that the holding would not be disturbed, and the recorded reasons for approving the title. Please also explain how the occupier's rights under section 70(1)(g) were examined before they were treated as undisclosed.

6. Requests

(a) Confirm these points are added to Z084NQV, and confirm receipt of this email.
(b) Answer each numbered point and A to D, or say the record is not held.
(c) Provide copies of the WA240304 register as first registered, form 1C as lodged, form D23, the letters of 8 and 12 April 1983 and 12 May 1983, the A3 application of 13 January 1984 and the register edition, the 1971 abstract, both plans, the original title plan, every notice and service record, the amalgamation application with its decision and completion dates, and the two 1994 correction applications. If copies cannot be emailed, please give the OC2 / HC1 wording and the address for each.
(d) Reply within 20 working days.

Please also keep every document on both first-registration files and every related internal record, in line with my preservation notices of 3 June and 28 September 2026.

To the Independent Complaints Reviewer: please confirm whether you will consider this additional material in ICR/090/26, or whether I should raise it separately.

Yours faithfully,

Sion Buckler (Ret'd Sergeant)
Royal Signals Cyber/Electronic Warfare Professional and Life Member