100% refusal. No PD 1A reference anywhere. Objectively provable.
12 formal RA requests across all courts. Not a single one granted. Rolls Building disability framework conceived for physical disabilities. Neurodivergent conditions do not exist in their documentation. No PD 1A reference anywhere.
What the opponent will argue, and why they are wrong.
Rolls Building disability framework addresses reasonable adjustments.
The Rolls Building disability framework is conceived for PHYSICAL access only. No reference to PD 1A, EA 2010 s.6 mental impairment definition, or ETBB anywhere in court-facing documentation. Neurodivergent conditions do not exist in their framework. 0/12 grant rate across ALL courts proves systemic failure, not individual oversight. American Cyanamid: serious question to be tried.
The applicant did not specify what adjustments were needed.
12 requests across all courts specified adjustments including: extended time limits, written rather than oral communications, structured hearing agendas, breaks during hearings, written summaries of oral directions. Dr Woolley's psychiatric report was provided. The ETBB (May 2025) provides a checklist at pp.258-264. The court's duty under PD 1A is PROACTIVE, not dependent on the disabled person knowing the 'right' words.
Logged and scheduled. 12 requests across 6 courts, 7 judges. 0 granted.
Formal admission binding under CPR 14: 'It is admitted that adjustments were not made for him.'
Fallback: Appeal EA 2010 grounds (G-A11, G-A12) achieve same result via different legal route.
Independence: Partially dependent on other grounds succeeding.