The register integrity letter, 25 September 2026

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CLAG: the register integrity letter (25 September 2026) The Council runs the public register of this application on two rules. Christ’s College’s (“the applicant”) papers are displayed at once: its email to every City councillor is dated 11 June 2026, its answers to the Victorian Society were displayed the next day, and its letters of 5 and 27 August 2026 within a day. Its account of CLAG’s judicial review of the Council’s 2025 permission, R (Christ’s Lane Action Group) v Cambridge City Council, Christ’s College Cambridge interested party, AC-2025-LON-004656 (“the judicial review”), has been on the register from the first day. The objector’s papers are kept off the register at the applicant’s request, withheld until CLAG complains, displayed after the consultation has closed, dated as if they had been on time, and now put through a review that applies to CLAG alone. The Council’s own documents rule out each of these steps. Paragraph 4.19 of its Statement of Community Involvement promises that representations will be added to the file and made publicly available online; its stated aim is consultation “consistent to all”; its letter of 19 August 2026 promises that views are “published onto the website promptly”; on 21 July 2026 it wrote that CLAG “will be treated exactly the same as any other objector on any planning application”; on 13 August 2026 it stated that the date shown is the date of upload. CLAG asks the Council to display every paper filed with this letter, and the record of the applicant’s public meeting of 6 July 2026, on Friday 25 September 2026, the day they reach it. It asks for the correction of every date to the day the document appeared, the audit trail and the Council’s written statements by Tuesday 29 September 2026. Submitted for the public register of application 26/02109/FUL, to be recorded under the heading above and displayed on the day it reaches the Council, Friday 25 September 2026: the Council’s notice of 19 August 2026 states that views are “published onto the website promptly” (document 9499001), and the applicant’s letters of 5 and 27 August 2026 were displayed within a day (documents 9486713 and 9506331). Application 26/02109/FUL: Christ’s College Library, St Andrew’s Street, Cambridge. Christ’s Lane Action Group (CLAG). Quotations are verbatim from the document cited, and documents are cited by their numbers on the register of this application. It states every point it relies on, so that it stands on its own. Three exhibits are filed with it: Exhibit R1, CLAG’s copies of the Council’s correspondence to it (the responses of 21 July 2026, the emails of 16 July and 13 August 2026, the notice of 20 August 2026 and the response of 28 August 2026); Exhibit R2, CLAG’s timed copies of the register; and Exhibit R3, CLAG’s record of the applicant’s public meeting of 6 July 2026 as sent to the Council on 9 July 2026. To: planning@greatercambridgeplanning.org and PlanningComments@greatercambridgeplanning.org, for the attention of Dominic Bush (case officer); copy Vanessa Blane (Senior Planning Lawyer, 3C Shared Services); copy Stephen Kelly (Joint Director of Planning and Economic Development, Greater Cambridge Shared Planning); copy legal@3csharedservices.org (the 3C Shared Legal Practice, the address the Council has stated as its accepted point of service). From: Christ’s Lane Action Group (residents@christs-lane.com). Filed Friday 25 September 2026.

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Contents 1.

The Council kept CLAG’s record of the applicant’s public meeting off the register because the applicant asked it to, adopted the applicant’s solicitors’ reason as its own and has stated no legal basis, in breach of its SCI

2.

The Council displayed the applicant’s account of the judicial review throughout the consultation, and the court documents only after CLAG complained and the consultation had closed, in breach of its SCI

3.

The Council fixed the register’s dates by the case officer’s instructions, so the register shows CLAG’s case and the applicant’s email to every councillor as public on days they were not, against its own rule of 13 August 2026

4.

The Council displayed the applicant’s answers to the Victorian Society within a day and the Society’s rejection of them fourteen days later, after the consultation closed, so the public saw one side only, in breach of its SCI

5.

The Council has put CLAG’s papers, and no one else’s, through a review before they reach the register, a step not in its protocol, against its SCI and its own standard that CLAG is treated “exactly the same as any other objector”

6.

The Council has to display every paper of this filing on the day it reaches it, Friday 25 September 2026, publish the record and correct the dates, or write its report on a register that treats the applicant and the objector differently

1. The Council kept CLAG’s record of the applicant’s public meeting off the register because the applicant asked it to, adopted the applicant’s solicitors’ reason as its own and has stated no legal basis, in breach of its SCI On 16 July 2026 the Council’s Senior Planning Lawyer at 3C Shared Services (“the Senior Planning Lawyer”) told CLAG that the record, CLAG’s record of the applicant’s public meeting of 6 July 2026 sent to the Council on 9 July 2026 (“the record”, Exhibit R3), would not be uploaded because “the college objects to its inclusion”, refused it at 16:59 in the words of the solicitors who wrote for the applicant that day (“the applicant’s solicitors”), and has stated no legal basis since. Paragraph 4.19 of the Council’s Statement of Community Involvement adopted in March 2024 (“the SCI”) promises that representations “will be added to the application file and made publicly available online”; its one qualification is the Council’s Privacy Notice, and it gives the applicant no say. If the Council publishes the record and states that an applicant’s objection is no ground for keeping a representation off the register, the documents tab of the Council’s public access website for this application (“the register”), the objector’s representation is on the register before the case officer’s report to committee on this application (“the report”) is written. If the record stays off, the Council has let the applicant decide what an objector may place on the public file. 1.

The Council’s reason was the applicant’s objection. The Senior Planning Lawyer’s email of 16 July 2026: “… with the exception of the transcript of the meeting held at Christ College on the 6 July. You will note from the email below that the college objects to its inclusion for the reasons detailed in the email.” The email below, the applicant’s solicitors’ of 09:11 that morning, ends: “The College respectfully requests that the Council does not place the transcript on the public register.” (Document 9476426, which carries the

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applicant’s solicitors’ email of 16 July 2026 at 09:11, the Senior Planning Lawyer’s email to CLAG of that day and CLAG’s reply at 14:51, “the 16 July exchange”, pages 3 and 4.) 2.

The refusal repeats the solicitors’ reason and states no legal basis. CLAG asked at 14:51 for “the legal basis on which an objector’s representation is being excluded from the register at the applicant’s request”; the answer at 16:59, copied to the solicitors, is their sentence of that morning repeated: (a)

the applicant’s solicitors, 09:11: “As such, the resulting transcript has not been agreed, verified or approved by the participants and cannot properly be characterised as an official record or minutes of the meeting.”;

(b)

the Senior Planning Lawyer, 16:59: “Your comments are noted. However, the Council is not prepared to upload onto the planning portal, the unauthorised copy of the transcript which the Council has been advised, has not been agreed, verified, or approved by the participants of the meeting.” (The 16 July exchange, pages 1 to 4; Exhibit R1, item R1.3.)

3.

CLAG asked twice how the applicant came to decide, and has had no answer: on 15 July 2026, whether any item was unpublished because it was “with the applicant for comment or by agreement with the applicant”, and on 16 July for the legal basis (item 2). The applicant’s solicitors objected at 09:11 on 16 July, before the Council had displayed anything; how the applicant came to know, and who decided the exclusion and under what power, is in the Council’s records. (Document 9464495, point 6.)

4.

The register carries the applicant’s side of the meeting and not the objector’s, and the stated ground did not operate. The applicant’s email of 11 June 2026 inviting every City councillor to the meeting is displayed under 11 June 2026; CLAG’s emails of 9 and 10 July 2026 asking for the record to be placed on the file are displayed under 10 July 2026 without it. The record says on its first page that it “is not a verbatim transcript, but a faithful minute of the exchanges” and that “Private attendees are identified by role or capacity only”; CLAG’s own account of the meeting, filed on 17 July 2026 and also not a transcript, was uploaded. (Documents 9465769, 9464505 and 9476871; Exhibit R3, page 1.)

5.

The Council had done the same a week earlier, and reversed it on challenge. On 8 July 2026 it refused the residents’ petition for a Development Control Forum: “The applicant, Christ’s College, has declined to participate. … Accordingly, your request for the Council to hold a DCF is declined.” CLAG wrote on 9 July 2026 that applicant consent is not among the published conditions for a petition; the Director of Planning reversed the refusal the same day, and the Development Control Forum of 29 July 2026 (the DCF) was held. (Documents 9456113, 9475180 and 9475984.)

CLAG files the record as Exhibit R3 and asks the Council: 1.

to place the record on the register on Friday 25 September 2026, the day it reaches the Council, dated the day it appears, with the Senior Planning Lawyer’s email of 16 July 2026 at 16:59 beside the 16 July exchange;

2.

to state in writing by Tuesday 29 September 2026 that an applicant’s objection is no ground under paragraph 4.19 of the SCI for keeping a representation off the register;

3.

to state by the same date whether, when and under what power the record or notice of it went to the applicant before 09:11 on 16 July 2026, and who decided the exclusion.

CLAG asked the first two on 15 and 16 July 2026 and asks again; if no answer comes, the record stands as it is: the applicant’s objection was the Council’s reason, and the applicant’s part in it is unexplained.

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If the Council publishes the record and gives those statements by those dates, the objector’s representation is on the register where paragraph 4.19 of the SCI puts it, and the report states the representation and the exclusion of 16 July 2026. If the record stays off the register: 1.

the Council has broken the promise in paragraph 4.19 of its SCI for the principal objector, at the applicant’s request and after notice; a breach of that kind quashed the permission in R (Kelly) v London Borough of Hounslow [2010] EWHC 1256 (Admin) (at [25] to [27] and [37]);

2.

the decision was made because the applicant objected, and a decision made because another party objects is not the authority’s own: in H Lavender & Son Ltd v Minister of Housing and Local Government [1970] 1 WLR 1231 the court quashed a refusal where “It was the decision of the Minister of Agriculture not to waive his objection which was decisive in this case” (at 1240 to 1241); consulting the applicant about placing a document on the file was held against the council in R (Joicey) v Northumberland County Council [2014] EWHC 3657 (Admin) (at [44]);

3.

a report that sends members to the register for the full representations sends them to one that carries the applicant’s invitation to the meeting and omits the objector’s record of it because the applicant asked. Such a report misleads members (R (Mansell) v Tonbridge and Malling BC [2017] EWCA Civ 1314, [2019] PTSR 1452 at [42]; the report to the Planning Committee of 29 October 2025 on 25/02161/FUL, “the 2025 report”, paragraph 7.5, section 6).

2. The Council displayed the applicant’s account of the judicial review throughout the consultation, and the court documents only after CLAG complained and the consultation had closed, in breach of its SCI From the first day of the consultation, the period for comments on the application that closed on Wednesday 22 July 2026 (“the consultation”), the register carried the applicant’s account of the judicial review of the 2025 permission (item 2). The court documents that test that account were CLAG’s papers, and they were on the register at none of CLAG’s copies taken during the consultation, nor at its copy of 26 July 2026, four days after the close. They appeared by 2 August, dated 15 June and 10 July. Paragraph 4.19 of the SCI promises that representations will be added to the file and made publicly available online, and that promise is kept only by publishing in time for the public to use what is published. If the Council dates the entries the day each appeared and the report states the record, members are told what the public could and could not read. If it does not, the consultation stands as one run on the applicant’s account alone. 1.

The applicant’s Covering Statement, shown as published on 5 June 2026 and on the register at every copy CLAG took, is the register’s account of the judicial review during the consultation: “On 6 March 2026, a Judge agreed that the Judicial Review could proceed.” (Document 9423967, paragraph 1.2.)

2.

The judicial review is R (Christ’s Lane Action Group) v Cambridge City Council, Christ’s College Cambridge interested party, AC-2025-LON-004656: permission on all four grounds by the order of Kimblin J signed 6 March and served 9 March 2026; the draft consent order signed by the Council and the applicant on 28 April 2026, agreeing that the permission of 2025 be quashed on all four grounds, which CLAG did not sign, so that the grounds receive a reasoned judgment, and which the Court did not make on the papers;

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the one day hearing listed for Tuesday 20 October 2026 (documents 9462822, page 18, and 9475597, pages 1 and 55). The order of Kimblin J granting permission on all four grounds is shown 15 June 2026 (document 9462886). CLAG’s objection of 10 July 2026, which carries the order, the Statement of Facts and Grounds and the signed consent order, is shown 10 July 2026 (document 9475597). 3.

Neither the order nor the objection is on any of CLAG’s five copies of the register of 14 to 16 July 2026, nor on its copy of 26 July at 16:16; both are on its copy of 2 August at 13:59. The copies are the register’s documents tab printed to file on 14 July 2026 at 15:15 and 16:47, on 15 July 2026 at 08:30 and 10:19 and on 16 July 2026 at 16:56, with CLAG’s screenshots of the website of 22 July 2026 at 22:40, 25 July 2026 at 15:49 and 20:01, 26 July 2026 at 02:11 and 16:16, and 2 August 2026 at 13:59 (“CLAG’s copies of the register”, Exhibit R2).

4.

The Council’s own covering emails show its uploads of CLAG’s July papers beginning on 16 July 2026, the day after CLAG’s complaint that they were missing. (Exhibit R2, items 1 to 7; documents 9464495 and 9464692.)

CLAG asks the Council to date documents 9462886 and 9475597 the day each first appeared on the register, by Tuesday 29 September 2026, with the other entries listed in section 6. CLAG asks that the report state that the order of 6 March 2026, the signed consent order and CLAG’s objection of 10 July 2026 were not on the register at any copy CLAG took during the consultation or on 26 July 2026. The report should state from the audit trail the day each first appeared. If the Council dates the entries the day each appeared and the report states the record, members are told that the public read the applicant’s account of the judicial review during the consultation without the court documents that test it. If the Council leaves the dates and the report sends members to the register as it stands: 1.

the consultation was run with the applicant’s account of the judicial review on the register and the objector’s case off it, in breach of paragraph 4.19 of the SCI, which requires publication “in good time for members of the public to be able to digest it and make intelligent representations” (Joicey at [47]);

2.

the dates shown are the Council’s statement of what the public could see, and its own covering emails and CLAG’s copies contradict them; a report that rests on them rests on a mistake of established fact (E v Secretary of State for the Home Department [2004] EWCA Civ 49 at [66]);

3.

a report that sends members to the website for the full representations sends them to a register that says the objector’s case was public from 15 June 2026; such a report misleads members (Mansell at [42]; the 2025 report, paragraph 7.5, section 6).

3. The Council fixed the register’s dates by the case officer’s instructions, so the register shows CLAG’s case and the applicant’s email to every councillor as public on days they were not, against its own rule of 13 August 2026 The register’s column headed “Date Published” (“the date shown”) is the Council’s statement of the day each document became public, and the Council’s own rule, stated on 13 August 2026, is that the date shown is the date of upload. For CLAG’s papers of July the case officer’s covering emails instruct that the documents be dated the day CLAG sent them, and the documents were sent to the document system days later. For the applicant’s email to every City councillor the register shows 11 June 2026, five weeks before the Council sent it to its document system.

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If the Council corrects every date to the day of first display, the register tells members and the public what could be seen and when. If it leaves them, the register says the objector’s case was public inside the consultation and the applicant’s approach to the committee was public from the first day, and the Council’s own documents show neither. 1.

The Council’s rule is the date of upload. The Senior Planning Lawyer wrote to CLAG on 13 August 2026 of one entry: “The display date of this representation has been changed to the 16th July to reflect the date it was uploaded.” The Council applied the rule to that entry, after CLAG’s letter of 7 August 2026 (document 9490029), and to no other. (Exhibit R1, item R1.2.)

2.

Three covering emails on the register carry the case officer’s instructions of 16 July 2026 to date CLAG’s documents to another day: “Could the documents please be dated the 14th July.”; “If uploaded tomorrow can they please be dated the 16th July.”; “If uploaded tomorrow please can it be dated the 16th July.” The documents were sent to the document system on 17 and 20 July 2026 and are shown 14 and 16 July. (Documents 9475984, 9476638, 9476426 and 9476525.)

3.

The applicant’s email to every City councillor is shown 11 June 2026. Its first page is the case officer’s email of 16 July 2026 sending it to the Council’s document system, and it is on none of CLAG’s copies of the register of 14 and 15 July. (Document 9465769; Exhibit R2, items 1 to 5.)

CLAG asks the Council to correct the date shown for every entry on the register to the day the document first appeared on it, by Tuesday 29 September 2026, beginning with the entries listed in section 6. CLAG asks for the audit trail of each entry set out there, including the instruction under which each date was set. CLAG asks that the report state which of CLAG’s papers were on the register during the consultation and from what day. If the Council corrects the dates and the report states the record, the register carries the dates the Council’s own rule requires and members read the consultation as it was. If the Council leaves the dates: 1.

the register states, for the objector’s case and for the applicant’s email, dates on which the Council’s own covering emails and CLAG’s copies show the documents were not there; a report that relies on those dates rests on a mistake of established fact (E v Secretary of State for the Home Department at [66]);

2.

the practice is the one the Local Government and Social Care Ombudsman found to be fault in its decision on Bristol City Council, reference 20 007 596, of 21 August 2022 (“the Ombudsman’s decision”): on a complaint about “an incorrect backdated date on its planning portal for publishing documents”, the Ombudsman recorded that the correct process is “to always show the ‘publication date’ for documents as the date it uploaded these documents on the planning portal” (the Ombudsman’s decision, paragraphs 1, 12, 21 and 28); of a website date that preceded the upload the court said “I take a dim view of any public authority backdating a document in a manner which could give a false impression to the public” (Joicey at [45]);

3.

a report that sends members to the register for the full representations sends them to dates the Council’s own documents contradict, and misleads them (Mansell at [42]).

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4. The Council displayed the applicant’s answers to the Victorian Society within a day and the Society’s rejection of them fourteen days later, after the consultation closed, so the public saw one side only, in breach of its SCI On the evening of 9 July 2026 the applicant’s agent and the Victorian Society wrote to each other within the hour, both copied to the case officer. The Council displayed the applicant’s answers to the Society on 10 July, and the Society’s rejection of those answers on 23 July, fourteen days later and the day after the consultation closed. It then dated its copy of the exchange 10 July, the applicant’s day, and, when CLAG challenged that date, 16 July, a day on which CLAG’s copy of the register shows the exchange was not there. If the Council dates the exchange the day it appeared and the report records that the Society rejected the applicant’s answers and that the public did not see it do so, the record is true. If it leaves the entry as it is, the register and the report present the applicant’s answer as the last word the public saw, which the Council’s own file contradicts. 1.

The agent wrote at 18:55 on 9 July 2026, attaching the applicant’s and its architects’ responses to the Society’s objection and asking that they “be uploaded to the application website please”. The Society replied at 19:32: “Our principal point still stands. Harm is attributed to this scheme, and this has not been mitigated in the resubmitted design. It is important that alternatives be considered in line with the harm identified.” (Document 9464487.)

2.

The applicant’s responses are shown 10 July 2026 and were on the register at CLAG’s first copy of 14 July (documents 9458387 and 9458386). The Society’s reply is on none of CLAG’s copies of 14 to 16 July; it appeared on 23 July 2026 as its own entry (document 9473149), the day after the consultation closed, and the Council’s own account gives the day: “the latest document was uploaded to the public portal on the 23rd July”. (Documents 9464487 and 9473149; Exhibit R2.)

3.

The Council’s copy of the whole exchange, which the case officer sent for upload on 16 July, was not on the register at 16:56 that day or at 16:16 on 26 July; on 2 August it was on the register dated 10 July. On CLAG’s challenge of 7 August the Council changed the date on 13 August to 16 July “to reflect the date it was uploaded” and refused a further consultation: “The Council considers that there has been sufficient time to comment given that the latest document was uploaded to the public portal on the 23rd July.” (Documents 9464487 and 9490029; Exhibit R1, item R1.2; Exhibit R2.)

CLAG asks the Council to date document 9464487 the day it first appeared on the register, which its audit trail will show and which was not 10 or 16 July 2026, by Tuesday 29 September 2026. CLAG asks that the report record the Society’s reply of 9 July 2026 in its own words as the Society’s position, and that it was not on the register until after the consultation closed. If the Council dates the entry the day it appeared and the report records the Society’s reply and its publication after the close, the register and the report tell members and the public when the Society’s answer could be read and what it said. If the Council leaves the entry dated 16 July 2026: 1.

the register states a date on which the Council’s own file and CLAG’s copy show the entry was not there, against the Council’s own rule and the Ombudsman’s finding (section 3);

2.

the public was consulted on the applicant’s side of the exchange alone, in breach of the SCI’s promise, which requires publication in good time for the public to use it (Joicey at

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[47]); the SCI’s promise is “a paradigm example” of the promise that binds a council (R (Majed) v London Borough of Camden [2009] EWCA Civ 1029 at [14]); 3.

a report that presents the exchange as public in the consultation misleads members on the Council’s own file (Mansell at [42]).

5. The Council has put CLAG’s papers, and no one else’s, through a review before they reach the register, a step not in its protocol, against its SCI and its own standard that CLAG is treated “exactly the same as any other objector” On 16 July 2026 the Council kept an objector’s paper off the register at the applicant’s request (section 1). On 20 August 2026 the Director of Planning notified CLAG of a “Single Point of Contact (SPOC) arrangement” for CLAG alone, under which material for the application file is uploaded “promptly where required following review”. On 28 August the Council defined the review as its screening of all incoming mail for inappropriate language and personal data. The applicant’s letters of 5 and 27 August 2026 were displayed within a day. If the review is that screening and nothing more, it holds no paper back and CLAG’s papers appear on the same day as the applicant’s. If it is more than that, no protocol or rule describes it, and the Council’s own standard that CLAG “will be treated exactly the same as any other objector on any planning application” is broken. 1.

The Council’s standard, in its response of 21 July 2026 to CLAG’s letter of 7 July: “CLAG as an objector will be treated exactly the same as any other objector on any planning application.” and “All relevant material in respect of the planning application will be placed on the planning portal.” (Exhibit R1, item R1.1.)

2.

The notice of 20 August 2026: “In the case of material to be uploaded onto the application file, this will be undertaken promptly where required following review.” Asked on 21 August for the criteria of the review, the Council answered on 28 August that it is “to screen, as per all incoming mail displayed by the Council online, for any inappropriate language or term or personal data (which are then redacted)”. The published protocol the notice relies on contains no step of reviewing material before it goes on a planning file. (Exhibit R1, items R1.5, R1.6 and R1.7.)

3.

The applicant’s letter of 5 August 2026 is shown 6 August (document 9486713), and its letter of 27 August 2026 was on the register at CLAG’s download of 28 August (document 9506331). The ground on which the Council held the record off the register on 16 July 2026, that it “has not been agreed, verified, or approved by the participants of the meeting”, is neither inappropriate language nor personal data: the Council has already held one CLAG paper back on a ground its own definition of the review does not contain (section 1).

CLAG asks the Council: 1.

to display every paper listed in CLAG’s index of the papers filed with this letter (“the filing index”) on the register, under the heading at its head and dated the day it appears, on Friday 25 September 2026, the day this filing reaches the Council; the Council’s consultation letter of 19 August 2026 states that views are “published onto the website promptly” (document 9499001);

2.

to state in writing by Tuesday 29 September 2026 that the review applies that screening and no other test to CLAG’s papers, on the same day as to the applicant’s, and holds no paper back on any other ground;

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3.

for any paper not displayed by that day, to give the reason and the rule applied, in writing by Tuesday 29 September 2026.

If every paper is displayed on Friday 25 September 2026 and the Council gives that statement, the objector’s papers reach the register on the same rule as the applicant’s, and the report is written on a register that carries both sides. If any paper of this filing is not displayed on Friday 25 September 2026: 1.

the review has kept an objector’s representation off the register, after CLAG had asked in writing for its display, in breach of paragraph 4.19 of the SCI; a breach of an SCI promise that deprived an objector of what the promise was for quashed the permission in Kelly (at [25] to [27] and [37]);

2.

the Council treats the two sides of the application differently and has itself written that no such difference exists; a difference the authority cannot justify is irrational (R (Gallaher Group Ltd) v Competition and Markets Authority [2018] UKSC 25 at [26] and [50]);

3.

a review that stands between one group of residents’ representations and the public file during a consultation engages article 10 of the European Convention on Human Rights. Members cut off from objectors’ material “would be reliant only on material from the applicant placed on the public record as part of the application or the information and opinions summarised and edited in the committee report” (R (Holborn Studios Ltd) v London Borough of Hackney [2020] EWHC 1509 (Admin) at [78] and [79]);

4.

the report is written on a register from which the objector’s papers have been filtered and the applicant’s have not, and misleads members (Mansell at [42]).

6. The Council has to display every paper of this filing on the day it reaches it, Friday 25 September 2026, publish the record and correct the dates, or write its report on a register that treats the applicant and the objector differently CLAG asks the Council to answer this letter by Tuesday 29 September 2026 and before the report is written. The Council answered CLAG’s letter of 7 August 2026 (document 9490029) on 13 August 2026, six days later, changing a register date in the same answer (section 4, item 3), and CLAG asks for these answers and corrections within four days. The Council’s reports send members to the register: the 2025 report closed its account of the representations with “The above representations are a summary of the comments that have been received. Full details of the representations are available on the Council’s website.” (the 2025 report, paragraph 7.5, reports pack printed page 136). The step that resolves the matter is the display of every paper filed with this letter and of the record on Friday 25 September 2026, the day they reach the Council, and the corrected dates, the audit trail and the Council’s written statements by Tuesday 29 September 2026. CLAG asks for: 1.

the display of every paper listed in the filing index on the register, under the heading at its head and dated the day it appears, on Friday 25 September 2026, the day this filing reaches the Council (section 5);

2.

the publication of the record, Exhibit R3, on Friday 25 September 2026, dated the day it appears, with the Senior Planning Lawyer’s email of 16 July 2026 at 16:59 beside the 16 July exchange (section 1);

3.

the correction of the date shown for every entry on the register to the day the document first appeared on it, by Tuesday 29 September 2026, beginning with documents

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9465769, 9464487, 9462886, 9462890, 9475180, 9464505, 9464692, 9475597, 9475984, 9476638, 9476426 and 9476525 (sections 2 to 4); 4.

the audit trail for every entry on the register, by Tuesday 29 September 2026: the date received, the date sent to the Council’s document system, the day it first appeared on the register, the date shown as first set and each change to it, the instruction under which each date was set and the officer who gave it; and, for the record, the decision of 16 July 2026 to exclude it, its maker and the power relied on;

5.

the Council’s written statements, by Tuesday 29 September 2026: that an applicant’s objection is no ground under paragraph 4.19 of the SCI for keeping a representation off the register; whether, when and under what power the record or notice of it went to the applicant before 09:11 on 16 July 2026; and that the review applies to CLAG’s papers the screening for inappropriate language and personal data and no other test, on the same day as to the applicant’s papers (sections 1 and 5).

If the Council displays the filing and the record on Friday 25 September 2026, and gives the corrected dates, the audit trail and the statements by Tuesday 29 September 2026, the report is written on a register that carries both sides on one rule. That register tells members and the public when each document became public. If the Council does not display the filing or the record, correct the dates or give the audit trail and the statements by those dates: 1.

the report sends members, for the full representations, to a register that keeps the objector’s record off at the applicant’s request, displayed the objector’s case after the consultation closed and dates it as if it had been on time; such a report misleads members (Mansell at [42]);

2.

the Council has broken the promise in paragraph 4.19 of its SCI, and its own standard of 21 July 2026 that CLAG is treated “exactly the same as any other objector”, for the principal objector on the application, after CLAG had asked in writing and before the report is written; that is the breach on which the Court quashed in Kelly (at [25] to [27] and [37]);

3.

the duty to publish does not wait for a request (R (Chidswell Action Group) v Kirklees Council [2025] EWHC 2256 (Admin) at [172]); CLAG’s requests of 15 and 16 July, 7 August and 21 August 2026 and this letter are on the record, and CLAG’s copies of the register stand as the record of what the public could see and when.

CLAG corresponds through the case officer and the published addresses. Christ’s Lane Action Group residents@christs-lane.com

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