Lack of communication between the inspection on the 27th of February and the invitation to interview under caution

Key Concerns in Her Conduct

  1. Unsubstantiated Claims:

    • We repeatedly asked for the specific email where Mark Sherwood allegedly stated “poor management.” This request was reasonable and relevant, yet she never produced it or clarified the source.

    • Continuing to assert a “history of non-compliance” without substantiating that claim when challenged can appear dismissive and unfair, especially when you’re providing counter-evidence.

  2. Lack of Disclosure Transparency:

    • She notes that “not all evidence will be disclosed before the interview,” which is technically compliant with PACE, but practically, it places us at a disadvantage in preparing a defense—especially when serious allegations are made.

    • This comes across as rigid, especially when balanced against your proactive offers to remediate and cooperate.

  3. Dismissal of Context:

    • we made a strong point about how “operation of an unlicensed HMO” can be misleading without context (e.g., whether someone is cooperating or avoiding regulation). That point wasn’t acknowledged or engaged with at all, which gives the impression of an inflexible or one-dimensional enforcement mindset.

  4. . Failure to Disclose Key Evidence

    We repeatedly requested a copy of the alleged “poor management” comment attributed to Mr. Sherwood. Hannah Cann failed to produce this, nor did she clarify whether it even exists. This undermines the credibility of her case and potentially violates our right to understand the substance of the allegations in a timely and fair manner.

    📌 Point: “An allegation cannot be central to an investigation if the primary source is withheld from those being accused.”

    2. Mischaracterisation of Contextual Facts

    The investigation reduces a complex, cooperative licensing process into a misleading and simplistic phrase: “operation of an unlicensed HMO.” We provided a clear timeline and context showing active cooperation, prompt remedial works, and full engagement with council officers. This was ignored, which suggests either a lack of due diligence or deliberate narrative shaping.

    📌 Point: “This selective framing appears misleading and intended to justify disproportionate enforcement, not reflect the actual situation.”

    3. Ignoring Evidence of Compliance

    We highlighted:

    • Prompt resolution of fire safety concerns

    • A consistent record of responding to officer visits and correspondence

    • Witnessed praise from Mr. Sherwood regarding the property

    None of this was reflected in the investigation. Hannah Cann declined our offer to supply written statements or maintenance logs. This points to a one-sided approach and suggests the investigation may be affected by confirmation bias.

    📌 Point: “Disregarding counter-evidence undermines the fairness and neutrality of any enforcement process.”

    4. Vague and Overgeneralised Language

    Language such as:

    • “History of non-compliance”

    • “Poor management”

    • “Deficient fire doors”

    …was used without supporting detail, dates, or documentation. In enforcement settings, such broad terminology must be backed by evidence. Otherwise, it risks misleading outcomes and unfair reputational damage.

    📌 Point: “Using vague, unsupported claims weakens the integrity of the entire investigative process.”

    5. Procedural Pressure & Withholding Evidence Before Interview

    We have not been given access to the full body of evidence prior to the PACE interview. While this may be technically allowed, when paired with unclear allegations and withheld evidence, it creates the impression of a coercive rather than constructive process.

    📌 Point: “Without full disclosure, it is impossible to prepare a meaningful response to the allegations.”

    6. Weaponising Technical Breaches Without Proportionality

    Minor and easily rectifiable issues — such as mould in a bathroom or an uneven surface in a yard — were presented as justification for serious enforcement. We acted quickly to address these and offered full access for follow-up. Escalating to formal action without exploring informal resolution is disproportionate.

    📌 Point: “This approach is inconsistent with the council’s stated commitment to proportionate and staged enforcement.”

    7. Lack of Engagement with Offers of Cooperation

    We have repeatedly offered full access to the property, immediate maintenance intervention, and follow-up visits to demonstrate compliance. These were either ignored or declined. This conflicts with the council’s stated aim of working collaboratively with property owners and managers.

    📌 Point: “Ignoring genuine offers of cooperation undermines the credibility of the enforcement process.”

    8. Allegations Contradicted by Their Own Officer’s Praise

    Council Officer Mr. Sherwood verbally expressed praise for the property during his visit, in front of witnesses. This praise directly contradicts the current framing of “poor management.” Failing to investigate this inconsistency suggests the investigation is not impartial.

    📌 Point: “If the lead officer’s assessment contradicted the narrative being pursued, it must be addressed — not dismissed.”

    Lack of Transparency in Decision-Making Process

    Despite several direct queries, Hannah Cann has failed to clarify:

    • What specific evidence the allegations are based on

    • Whether any complaints were made and by whom

    • Why escalation was chosen over informal resolution

    This lack of transparency obstructs our ability to engage fairly with the process and raises concerns about whether decisions are being made on proper grounds.

    📌 Point: “Opaque decision-making undermines trust in the legitimacy of enforcement actions.”

    10. Lack of Neutrality in Language and Tone

    Throughout her correspondence, Hannah Cann consistently uses accusatory, adversarial language. Phrases like “we do not agree”, “failures in management”, and “the council intends to prosecute” are used prematurely — before any formal interview or full evidence disclosure.

    📌 Point: “The tone adopted prejudges the outcome and compromises the objectivity expected of an investigator.”

    11. Ignoring the Council’s Own Enforcement Policy

    Most local authorities (including North East Lincolnshire) have clear enforcement protocols:

    1. Informal resolution

    2. Advisory visits

    3. Written warnings

    4. Final notices

    5. Prosecution

    In our case, the council — led by Hannah Cann — appears to have skipped steps in this graduated approach, despite our full cooperation and willingness to resolve issues. This is procedurally unfair and potentially outside policy.

    📌 Point: “Disregarding internal protocols is not only unfair — it may also invalidate the outcome of the process.”

    12. Unreasonable Delays in Responding to Communication

    Despite the seriousness of the matter, there were delays of over X days in responding to key emails (insert specifics if you have them). Timely communication is essential to allow for fair preparation ahead of interviews or enforcement steps.

    📌 Point: “Procedural fairness includes timely, responsive communication — especially when legal rights may be affected.”

    13. Failure to Document or Record Key Meetings

    Verbal comments made by officers (e.g., Mr. Sherwood’s praise) were never recorded in written summaries or follow-up reports. These would normally be included if the council were acting in a balanced, transparent manner.

    📌 Point: “The omission of favorable findings indicates selective recording and a potential intent to bias the outcome.”

    14. Refusal to Acknowledge Witness Statements or Third-Party Testimony

    We offered to provide witness accounts, maintenance logs, and statements from contractors or residents supporting our position. These offers were dismissed or not followed up. Ignoring exculpatory evidence directly contravenes investigative fairness standards.

    📌 Point: “A refusal to consider third-party evidence reflects an intent to maintain a predetermined narrative.”

    Misleading Questioning Techniques Suggest Intent to Incriminate

    According to a tenant’s statement and our records, the officer asked:

    “How many months has this bathroom been out of order?”

    This leading question presumes guilt and ignores the actual context — the bathroom had only been under repair for 2–3 days, not months. This style of questioning shows a bias toward finding fault rather than establishing facts.

    📌 Point: “Framing questions to elicit incriminating answers is not only unprofessional — it undermines the objectivity of the entire investigation.”

    18. Disregarding Firsthand Testimony From Tenants

    We submitted a signed declaration from tenant Rashpinder Kaur, confirming that the downstairs room was used as a communal space and that the bathroom issue was only temporary. There is no indication this was acknowledged or considered.

    📌 Point: “Ignoring credible tenant testimony, especially when signed and dated, reflects a one-sided and possibly prejudiced approach.”

    19. Disproportionate Use of a Warrant at 7:00 AM

    Executing a warrant at 7:00 AM in a licensed HMO with a well-documented history of cooperation is grossly disproportionate. Tenants were distressed, and no urgent risk was present to justify such timing.

    📌 Point: “This kind of action is more appropriate for criminal investigations, not collaborative housing enforcement.”

    20. Concealment Tactics Following the Inspection

    Following the 27 February 2025 inspection, we received no communication regarding findings. There was no opportunity to rectify issues. This silence violates principles of transparency and the council’s duty of care.

    📌 Point: “Concealing findings after a warrant-led visit contradicts both procedural fairness and best practice.”

    21. Disregarding the Fire Brigade’s Clearance

    We documented that Lincolnshire Fire & Rescue found no outstanding safety concerns during their inspection on 7 April 2025. This occurred after the council’s visit, yet no consideration appears to have been given to their findings.

    📌 Point: “Disregarding expert third-party clearance undermines the validity of continued enforcement action.”

    22. Absence of Follow-Up Communication Until Interview Letter

    We heard nothing between 27 February and 11 April — a period of over 6 weeks. This silence led us to believe no further action was needed. Instead, we were abruptly issued an interview under caution.

    📌 Point: “Strategic silence followed by legal escalation is incompatible with constructive enforcement.”

    23. Inconsistent Documentation Dates

    We identified that Hannah Cann referenced a letter dated 26 March, but the attached document is dated 27 March. This discrepancy raises doubt about the reliability of the recordkeeping and communication process.

    📌 Point: “Administrative inconsistencies like this cast doubt on the procedural integrity of the case.”

    24. Ignoring Government Policy on Proportional Enforcement

    Government guidance clearly states that licensed HMOs should be dealt with through engagement first. Hannah Cann’s heavy-handed approach contradicts this principle, despite our continued cooperation.

    📌 Point: “The council’s actions appear misaligned with national enforcement policy, which prioritizes dialogue and rectification over prosecution.”

    26. Shifting Tone from Cooperative to Punitive Without Cause

    We have a consistent history of working with the council, especially under Officer Mark Sherwood. The sudden shift in tone and treatment under Hannah Cann is not reflective of any change in our conduct.

    📌 Point: “The escalation of enforcement without any material change in our compliance record is unjustified and alarming.”

Contraddiction in the conduct after the inspection under warrant.

The fact that Hannah Cann and the Council conducted a warrant-led inspection on 27 February 2025, allegedly found serious issues, and chose to withhold all findings until issuing a formal interview under caution letter in mid-April is not only counterproductive, but potentially in contravention of multiple policy principles, common law standards, and basic logic.

Below is a detailed breakdown of all the contradictions this strategy creates — legally, procedurally, and in terms of common sense.

🔥 Contradictions in the Council’s Concealment Tactic (Post-Warrant Inspection)

⚖️ 1. Contradiction with the Purpose of Housing Enforcement

Council Enforcement Policies (e.g. City of Lincoln Council’s 2019–2024 Policy) state:

“The primary objective of enforcement is to secure compliance and protect public health and safety.”

📌 Contradiction:
If the goal is truly to protect tenants, then withholding findings that supposedly impact safety directly delays action that could protect them. It’s illogical to say something is “serious” but then keep it hidden for 6+ weeks.

⏱️ 2. Contradiction with the Principle of Urgency

If the council truly believed the findings were severe enough to justify a dawn warrant and potential prosecution, then common sense and professional duty would require them to:

  • Notify the license holder immediately

  • Give a short deadline for remediation

  • Monitor compliance proactively

📌 Contradiction:
Delaying notification implies the problems were not urgent at all, contradicting the original justification for a warrant (which is normally used for time-sensitive issues).

📜 3. Contradiction with Procedural Fairness and Natural Justice

Natural justice (a foundational legal principle in the UK) requires:

  • The right to know the case against you

  • The right to respond in a timely manner

  • The opportunity to rectify before penalties are applied

📌 Contradiction:
By keeping the findings secret until issuing a formal interview under caution, the council denied you the opportunity to address the issues proactively, violating these fundamental legal standards.

🔍 4. Contradiction with the Council’s “Staged” Enforcement Policy

The council’s own policy outlines a graduated approach:

  1. Advice

  2. Warnings

  3. Notices

  4. Prosecution only after non-compliance

📌 Contradiction:
we received no advice, warning or notice after the warrant visit — just a sudden formal letter weeks later. This skips the entire early intervention process and contradicts their stated framework.

📞 5. Contradiction with Communication Expectations in Enforcement

Best practice in enforcement expects:

  • Follow-up contact within days of inspection

  • Clear written summaries of findings

  • An open invitation to discuss or dispute claims

📌 Contradiction:
we received no contact at all until 11 April, despite being highly accessible and historically cooperative. This total silence is abnormal and suggests concealment, not collaboration.

🛠️ 6. Contradiction with the Principle of Rectification Before Prosecution

Government guidance, including from DLUHC (Department for Levelling Up, Housing and Communities), emphasizes that landlords should be given a reasonable opportunity to rectify breaches before formal enforcement is triggered — especially if they are licensed and cooperative.

📌 Contradiction:
The council withheld all findings, so you were not given any chance to rectify anything, violating both the spirit and intent of the regulatory framework.

👷‍♂️ 7. Contradiction with our Demonstrated Pattern of Compliance

You have:

  • Maintained the property regularly

  • Provided rapid repairs

  • Invited inspections

  • Submitted evidence

  • Cooperated fully for years

📌 Contradiction:
Withholding findings from someone who has always responded constructively makes no practical sense. If anything, it punishes the very behaviour the system is meant to reward.

📅 8. Contradiction with Timelines of Serious Risk

If issues  were truly serious enough to justify legal action, then they were too serious to delay acting on for over a month.

📌 Contradiction:
By not acting urgently or demanding fixes, the council implicitly admitted the issues weren’t serious, undermining the credibility of later enforcement claims.

🤐 9. Contradiction with Ethical Public Service Standards

Public officials are expected to:

  • Act transparently

  • Use enforcement powers responsibly

  • Avoid unnecessary stress to compliant citizens

📌 Contradiction:
Strategic silence followed by a formal legal threat undermines public confidence, appears manipulative, and violates the ethical standards of public administration.

👨‍👩‍👧 10. Contradiction with Tenant Wellbeing

Concealing findings rather than allowing quick rectification prolongs exposure to risk (if any existed). Tenants are not helped by this approach — they are left in the same condition for weeks.

📌 Contradiction:
If tenant welfare was the priority, issues would have been flagged immediately. Concealment puts political or prosecutorial strategy above tenant safety.

🧾 11. Contradiction with Proportional Use of Legal Tools

Using a PACE interview under caution is a legal escalation tool. It is not meant to replace ordinary communication, and certainly not to be the first point of contact after an inspection.

📌 Contradiction:
The council jumped from inspection → silence → interview under caution. This bypasses proportionality, procedural dialogue, and shows signs of bad faith enforcement.

In particular there are several contraddictions with the policy that the council is supposed to follow.

 contradictions between the Council’s concealment of inspection findings (from the 27 February 2025 warrant entry) and their own stated principles in the City of Lincoln Council’s Directorate for Communities & Environment — Health & Environment Enforcement Policy 2019–2024.

These points highlight how Hannah Cann’s approach sharply deviates from the Council’s own enforcement standards — and why her conduct may be grounds for formal complaint, and legal challenge.

🔍 Contradictions with Enforcement Policy 2019–2024

1. Violation of Principle: “Early Engagement and Advice”

Policy Statement:

“The council will seek to resolve cases at the earliest opportunity and give businesses and individuals the chance to rectify breaches voluntarily before resorting to formal enforcement.”

📌 Contradiction:
Despite allegedly identifying serious issues on 27 February, no communication was made for over six weeks. No advice, no guidance, no chance to rectify — just silence until a formal interview under caution letter was issued on 11 April. This is the opposite of early engagement.

2. Violation of the “Proportionality Principle”

Policy Statement:

“Enforcement action will be proportionate to the risks and the seriousness of the breach.”

📌 Contradiction:
If the breaches were serious, proportionate action would be to notify the license holder immediately so issues could be rectified. If they were not serious, then the warrant and formal caution were excessive. Either way, the action taken does not align with proportionate enforcement.

3. Breach of “Transparency”

Policy Statement:

“We will ensure that those we regulate are kept informed and understand what is expected of them and what they can expect from the regulator.”

📌 Contradiction:
The council withheld all inspection results for six weeks — giving no indication of expectations or requirements. This makes the enforcement process intentionally opaque and violates the duty of transparency.

4. Disregard for the “Staged Enforcement Model”

Policy Statement:

“The council uses a stepped approach, starting with informal action (advice/warning) before escalation to legal enforcement where appropriate.”

📌 Contradiction:
There was no informal step taken after the 27 February visit. Instead, the council moved straight to legal escalation via an interview under caution — with zero communication in between. This skips an entire phase of the enforcement pathway.

5. Breach of “Targeted Action Based on Risk and History”

Policy Statement:

“Officers will consider the history of compliance and willingness to cooperate before taking action.”

📌 Contradiction:
Our record shows years of cooperation, rapid maintenance responses, and even Fire Brigade clearance after the inspection. These facts were ignored. Taking enforcement action without weighing history contradicts the Council’s own stated standard of risk-based, targeted enforcement.

6. Undermining of “Consistency”

Policy Statement:

“Our enforcement decisions will be consistent with our policy and with how we deal with similar situations.”

📌 Contradiction:
Other landlords with far worse, unlicensed properties have not been subjected to early morning warrants or interviews under caution. Our treatment appears inconsistent and discriminatory — especially as a license holder operating transparently and legally.

7. Failure to Fulfill Duty of Care Toward Tenants

Policy Implication (from Health & Safety focus):

Councils must act to improve housing conditions for the safety and well-being of tenants.

📌 Contradiction:
If the council had genuinely found safety issues, it had a duty to inform the landlord immediately to ensure tenant safety. By waiting over 40 days, they effectively put tenants at risk — or exposed the lie that those issues were ever serious to begin with.

8. Use of Legal Tools as Punitive Measures

Policy Statement:

“Legal action is a last resort when informal advice and guidance fail.”

📌 Contradiction:
We received no feedback, warnings, or request for follow-up after the inspection. Therefore, legal action wasn’t used as a last resort — it was the first step after silence. This weaponizes enforcement powers in a way that violates the stated policy aim.

9. Misuse of Council Resources

Policy Value:

Enforcement should make “best use of available resources to protect the public.”

📌 Contradiction:
Issuing warrants and formal interviews against a cooperative, licensed HMO operator is a misallocation of resources — especially when unlicensed HMOs with poor conditions exist elsewhere and go unchecked.

10. Damage to Regulator Credibility

Policy Principle:

“We will aim to maintain public trust in our regulatory role by being open and fair.”

📌 Contradiction:
By concealing findings, surprising a landlord with an interview under caution, and failing to engage in fair communication, the council undermines its credibility as a fair and trustworthy authority. This weakens its standing not only with you, but with the broader landlord community.

Serious Implications of a Biased and Unfair Enforcement Approach

 

The severity of the biased approach taken by Hannah Cann and the Council becomes even more apparent when viewed through both regulatory expectations and broader legal and ethical principles.

1. Presumption of Guilt Undermines Legal Integrity

From the outset — such as the question “how many months has the bathroom been out of order?” — there is a clear bias in assuming wrongdoing rather than neutrally investigating facts.

📌 Severity:
Presuming guilt before evidence is tested contradicts Article 6 of the Human Rights Act (right to a fair trial) and undermines the fairness of any subsequent enforcement.

2. Selective Use of Information as Evidence of Malice

The council failed to disclose  historical cooperation — while highlighting vague or minor findings out of context.

📌 Severity:
This suggests intentional narrative shaping, potentially to manipulate enforcement outcomes, which borders on malfeasance in public office if it leads to disproportionate or fabricated charges.

3. Use of Surprise Legal Tactics Despite History of Cooperation

We were not evasive at any point. We responded, submitted evidence, maintained the property, and welcomed inspections. Yet the council used a punitive approach and then remained silent until issuing a formal interview under caution.

📌 Severity:
Using aggressive tactics against a cooperative license holder is not just biased — it is abusive and intimidatory, and could be construed as harassment by a public authority.

4. Omission of Evidence Supporting Innocence

The failure to acknowledge:

  • Hystorical cooperation

  • Tenant testimony,

  • Ongoing maintenance and transparency,

…suggests a deliberate attempt to build a one-sided case, in contradiction with the duty of a regulator to act in the public interest, not for institutional gain or political expedience.

📌 Severity:
This constitutes very valid grounds to invalidate any legal proceedings on the grounds of unfair investigation or abuse of process.

5. Disproportionate Focus on a Cooperative Landlord

There are other unlicensed HMOs. Yet the council appears to have targeted a known, registered, and transparent license holder — potentially because it is easier to obtain a  financial penalty.

📌 Severity:
This reflects institutional bias and resource misallocation, which has both financial and reputational implications and may even qualify as maladministration under the Local Government Ombudsman’s standards.

6. Withholding Findings Weakens Safety Protections for Tenants

If the alleged risks were genuine (e.g. bathroom disrepair, fire safety), the decision to withhold findings from the landlord for weeks directly endangered tenants by delaying repairs.

📌 Severity:
This conduct is irresponsible and unethical, and contradicts the council’s duty under the Housing Health and Safety Rating System (HHSRS) to act swiftly to prevent harm to tenants.

7. Contradiction Between Inspection Findings and Interview Timing

Council officials claimed issues were so serious they required a warrant, yet:

  • No emergency notices were issued,

  • No repair orders were made,

  • No emails were sent for over 6 weeks.

📌 Severity:
This destroys the credibility of the council’s claim that these were urgent risks. Instead, it points to an attempt to delay disclosure until it was too late to respond before formal action.

8. Failure to Distinguish Between Enforcement and Prosecution Mindsets

The Council’s role is not to seek convictions but to ensure compliance and protect public health. The shift in tone from cooperative to adversarial without cause signals a move from enforcement to persecution.

📌 Severity:
This blurring of roles is inappropriate, and if repeated, could open the council to judicial review or even misconduct proceedings in regulatory oversight.

9. Impact on Reputational and Emotional Wellbeing

Targeting a responsible landlord with years of clean record, and treating them as a criminal suspect, causes:

  • Stress,

  • Damage to professional reputation,

  • Financial harm due to legal costs and tenant concerns.

📌 Severity:
This is not just procedural — it is personal harm caused by abuse of process, potentially subject to a complaint under Article 8 of the Human Rights Act (right to private and family life).

10. Risk of Setting Precedent for Future Abuses

If this behaviour is not challenged, it risks becoming a new enforcement norm — where:

  • Evidence is hidden,

  • Cooperative landlords are punished,

  • And legal tools are used for intimidation rather than resolution.

📌 Severity:
This would create institutionalised bias and erode landlord trust in the regulatory system — something that policy and central government specifically warn against.

Most of the issues raised on the second inspection carried out on the 27th of February 2025 not only were not notified to the landlord immediately as expected, but they were completely new issues never reported during the first inspection in October 2024.

 

the procedure was disproportionate, rushed, or motivated by enforcement rather than improvement.

Enforcement Policy Contradictions

Most councils have a published Enforcement Policy (e.g., Lincoln City’s “Directorate for Communities & Environment Enforcement Policy 2019–2024”) which states they will:

Work cooperatively before escalating,

Give landlords a chance to remedy non-compliance voluntarily, and

Apply graduated enforcement.

The council  skipped those steps; Therefore, their actions contradict their own policy, making the action potentially procedurally unfair or abusive.

No opportunity to correct issues before penalty (breach of proportionality).

No proper communication or follow-up after first visit.

Failure to Notify — Procedural Unfairness

  • The council did not inform us of these alleged breaches at the earliest opportunity .

  • we were therefore denied a reasonable chance to remedy or respond to the issues.

  • This is contrary to:

    • “Right to be heard” (audi alteram partem)

    • Council’s own Enforcement Policy

    • Regulators’ Code (BEIS, 2014) – which requires fair and transparent enforcement

“Ambush Enforcement”

  • Allegations raised only after obtaining a warrant, and not raised in October, suggest a shift in focus or an attempt to escalate the situation without reasonable prior engagement.

Lack of Continuity or Credibility

    • The delay in raising these issues undermines their seriousness — if they were truly critical, they should’ve been pointed out earlier.

  • The timing of the new allegations suggests retaliatory or fishing tactics, especially if they emerged only after  earlier action failed.

Contradictions with Lincoln City Council’s Enforcement Policy (2019–2024)

Lincoln’s own policy commits to proportionality, fairness, early engagement, and voluntary compliance.

🔹 Section: General Principles of Enforcement

“The Council is committed to dealing with enforcement matters in a fair, transparent, and consistent manner. We aim to provide opportunities to voluntarily comply before formal action is taken.”

Contradiction:

  • No opportunity was given to voluntarily comply or respond after the first inspection.

  • No warning letter, informal email, or engagement occurred between the visit in October 2024 and the ambush visit under warrant on the 27th of February 2025

  • No warning letter, informal email, or engagement occurred regarding the February issues.

🔹 Section: Enforcement Approach

“We will seek to resolve cases informally wherever possible and reserve formal action where there is clear evidence of non-compliance despite the opportunity to comply.”

Contradiction:

  • The February 2025 breaches were never raised informally before formal action (interview under caution).

  • This skips the council’s own escalation hierarchy: engagement → informal notice → enforcement.

🔹 Section: Proactive Inspections

“Where inspections identify breaches, we will notify the responsible person promptly and offer guidance on how to comply.”

Contradiction:

  • The alleged breaches from February were not notified to us promptly.

  • Instead, they were stored and brought forward during a formal interview, bypassing the guidance phase entirely.

🔹 Regulators’ Code (BEIS 2014) — which Lincoln Council claims to follow

“Regulators should provide advice and guidance to help those they regulate meet their responsibilities.”

Contradiction:

    • No advice or warning was given following the first inspection.

    • Instead, the council pursued a punitive approach first, which is inconsistent with the Regulators’ Code.