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Dr Karin Christine Reenie Elliott

THE ARCHITECTS REGISTRATION BOARD
PROFESSIONAL CONDUCT COMMITTEE

In the matter of:

KARIN CHRISTINE REENIE ELLIOTT (061005D)

———

Held in person on 27-31 October 2025 and 7-9 April 2026 at the:

General Dental Council
37 Wimpole St
London
W1G 8DQ

And also held as a virtual hearing on 12-16 October 2026
———-

Present:

Neil Dalton (Legally Qualified Chair)
Robert Dearman (PCC Architect Member)
Rachel Childs (PCC Lay Member)

———–

In this case, the ARB is represented by Mr James Lloyd (the “Case Presenter”) of
Mountford Chambers, instructed by Kingsley Napley LLP.

Dr Karin Christine Reenie Elliott (the “Registered Person”) attended this hearing and was assisted by McKenzie Friend, Mr Michael Eisenbarth.

The PCC found Dr Elliott guilty of unacceptable professional conduct (“UPC”) in that she:

(1) The Registered Person sent inappropriate communications regarding her neighbours on or around:
a) 23 February 2024; and
b) 1 March 2024

(2) The Registered Person’s actions at particular 1a and 1b were:
a) Misleading; and
b) Lacking Integrity; and
c) Dishonest

and that by doing so, she acted in breach of Standards 1.1, 1.2, 9.2 and 12.1. of the Architects Code: Standards of Conduct and Practice 2010 (“the Code”).

The sanction imposed is Erasure.

 

Determination on Facts

The Registered Person is a registered Architect.

Allegation

1. The Allegation made against the Registered Person is that she is guilty of Unacceptable Professional Conduct (UPC).

2. The ARB relies upon the following particulars in support of the Allegation:
(1) The Registered Person sent inappropriate communications regarding her neighbours on or around:
a) 23 February 2024; and/or
b) 1 March 2024
(2) The Registered Person’s actions at particular 1a and/or 1b were:
a) Misleading; and/or
b) Lacking Integrity; and/or
c) Dishonest

Background
3. The Presenting Officer, in the opening of his case, relied in effect upon the alleged facts as set out in a report prepared by Kingsley Napley (‘the KN report’), which in turn was based on the witness statements of Steven Bloomfield (“Referrer A”), Steven Davis (“Referrer B”), and Alison Gurney (“Referrer C”).
4. At its essence, the circumstances giving rise to the Allegation are these:
5. In documentation dated 15 December 2023, the Registered Person made a planning application for the installation of CCTV cameras on her property. All three Referrers are neighbours of the Registered Person, and each live in homes immediately adjacent to the one she shares with her partner, Mr F Girardin (FG).
6. This CCTV application arose against a background of acrimony between the Registered Person and the Referrers. This centred around the Registered Person’s claim that the Referrers had acted improperly so as to diminish the size, shape and character of her property; as well as, by their behaviour, threatening and harassing her, and diminishing her capacity both to enjoy and preserve that property (her home being a property of historic architectural value).
7. On or around 23 February 2024, she wrote correspondence seeking to generate support for her CCTV application.
8. That correspondence, addressed to ‘Friends, and neighbours on [Street name redacted]’, and headed ‘Request for letters of support on planning application (Listed building consent) to install CCTV’’ (hereafter, ‘the Letter’), was marked ‘highly confidential’.
9. The Letter sought support for three broad reasons, including ‘to help protect us from ongoing harassment’ and ‘to protect our remaining trees, walls, historical garden and house.’
10. Within the letter were a number of serious allegations regarding the Referrers, each of which the Referrers refute. The ARB considers the letter inappropriate, as well as being misleading and/ or lacking integrity and/ or dishonest.
11. Subsequently, on 1 March 2024, the Registered Person posted a Planning Appeal Form (hereafter, ‘the Form’) on the Norwich City Planning Portal, appealing against an earlier grant of planning permission to Referrer A.
12. The use of the Form for this purpose is alleged by ARB to be inappropriate in itself. Additionally, within the Form are a number of serious allegations regarding the Referrers, each of which the Referrers again refute. The ARB likewise considers the content of this Form to be inappropriate, as well as misleading and/ or lacking integrity and/ or dishonest.
13. The Registered Person accepts being the author of the Letter and the Form. She also accepts having sent both communications. Otherwise, though, the Registered Person denies the Allegation’s particulars.

Evidence
14. The Committee was provided with an ARB hearing bundle which included:

i. Report to ARB prepared by Kingsley Napley;
ii. Witness statements of Referrer A (dated 4 February 2025), Referrer B (dated 27 February 2025), and Referrer C (dated 7 February 2025);
iii. Undated letter from Registered Person to ‘Friends and neighbours on Street,’ seeking responses by 28 February 2024;
iv. Planning Appeal form (1 March 2024);
v. Various plans, drawings, and planning application paperwork;
vi. Various emails and other correspondence; and
vii. A number of documents specifically relied upon by the Referrers (as set out in paragraphs 31, 63 and 81 below)

15. The Committee was also supplied with the following evidence from the Registered Person:

i. Witness statements of the Registered Person (5 October 2025) and FG (29 June 2020, 12 October 2025 and 23 November 2025), together with various other notes from the Registered Person including (for example) ‘Response to ARB professional standards investigation’ (16 July 2024)
ii. Witness statements (undated) from other people, including Elspeth Hamilton (EH) and Lesley Graham (LG), together with letters of support.
iii. Various plans, drawings, photographs and planning application paperwork, together with commentary upon planning application paperwork, relating to the Registered Person’s property (as identified more fully in paragraphs 102-103 below)
iv. Emails and other correspondence.
v. A selection of ‘Police reports’
vi. Four video clips

16. Referrers A, B and C gave oral evidence to the Committee, as did the Registered Person, FG, EH and LG.

Outline of evidence

Overall, the salient evidence was as follows.

The Letter
17. In seeking the support of ‘friends and neighbours’ for the installation of CCTV (‘which would not be intruding on anyone else’s privacy’), the Registered Person’s letter provided three broad reasons for requiring that support, the first being ‘to help protect us from ongoing harassment’.
18. In that regard, having first stated that ‘We’ve been the victims of repeated harassment and have regularly made crime reports to the police about the people who have been harassing us’, the Registered Person supports that claim by making the following assertions in relation to the Referrers (identifying them by their postal addresses):

Regarding Referrer A and his family (who lived at [address redacted[):

i. “Our neighbours at [address redacted] have between them chopped down at least 6 trees7in our garden and destroyed much of the planting along a ‘green tunnel’ entrance laneway into our property”.
ii. “Our neighbours at [address redacted] has recently applied for permission to ‘trim’ several more trees, again without our consent. He had already destroyed three of our trees before even making his application”.
iii. “[…] [address redacted] have smashed down several of our historic walls, chopped down many of our historic trees, and built on our property, all without our consent”.

Regarding Referrer B and his family (who lived at [address redacted]):

iv. “She threatened to burn our car if we park on our own property”.
v. “He calls us either a ‘piece of shit’, ‘disgusting’ and/or exclaims ‘the stench’ regularly. It is very upsetting. We are Irish/American and French”.
vi. “He has regularly obstructed us from entering our home and overturned our bins. He threatened to hit one of us over the head with a hammer at one stage, after he was asked to desist. He had been starting to build a wall on our property illegally on a Sunday, following Trump’s declaration that he would ‘build a big wall’ to keep out immigrants”.

Regarding Referrer C and her family (who lived at [address redacted]):

vii. “[They] demolished a historic wall, pier, fencing and trees on our property between 2017 and 2018. It was scary to hear your home being smashed up.”
viii. “They proceeded to build an ugly concrete foundation (partially upon our property) and a carport for their own use (also partially upon our property) all without our consent.
ix. “They have consistently refused to vacate our property, despite a court decision in our favour in 2019, requiring them to stay off our property”.
x. “As former manager of Norwich City Council and a senior employee at Norfolk County Council, our neighbours at [address redacted] appear to have exerted significant influence to escape justice. The council – his employers and former staff – have not required [Referrer C] to rebuild after they illegally demolished walls or to replant after they illegally felled trees or after they built their ugly steel and concrete garage partially upon our property”.

Regarding all three Referrers:

xi. “We hope that the CCTV might deter them all from further trespassing and further destroying our listed garden, and from any further gender violence and racial harassment”.

In relation to Referrer C, the Registered Person also included within the letter, as ‘Additional note’, to the following effect:

xii. “[They] built their garage one foot inside our property, leaving our pathway inaccessible for anyone with a disability. This loss of disabled access to our property [is] more than a mere annoyance. My disabled father slept on the sofa in his office for two years, eating cornflakes and not much else. He eventually had to be taken into safeguarding and is now dead. So the upset caused by the harassment and bullying is significant. When dad died, I was treated to a rendition of Tragedy’ by the Bee Gees, (sung by our neighbours at [address redacted] from the enormous balcony they built overlooking our home, also without our consent)”

The Form

19. In the Form, the Registered Person makes the following assertions in relation to the Referrers (identifying each of them by name):

Regarding Referrer A and his family
i. She describes the planning application by Referrer A as being ‘fraudulent’ and claims he has been ‘assisted’ by Referrer C’s husband ‘former manager of Norwich city Council’.
ii. She adds that the purpose of Referrer A’s application was “to conceal more serious crimes”.

The Registered Person continues:

iii. “[He] has never owned this property (i.e., the one in relation to which he applied for planning permission) and […] he did not consult us about destroying any of our trees”.
iv. “[He] bullied and harassed us, both from his side of the wall and on our own private property, using a chainsaw. He proceeded to chop down our grade 2 listed trees without even asking permission. When I found him wielding his chainsaw in October 2023, he had already destroyed two trees […] I encountered him in the garden of my house wielding a chainsaw in our direction. I begged him to turn off his chainsaw and explained that I considered it to be racial harassment. After he chopped down a third tree, I reported him to the police. I can supply the crime reference number should you require.”
v. “[In] the past [he] has illegally entered our garden, driven wooden stakes into the ground, and destroyed much of our planting […]’
vi. “Two disabled people in my family – and one disabled guest in a wheelchair – have all been obstructed from visiting my home as a result of these repeated violent attacks on my home”.

Regarding Referrer B and his family:

vii. An “equally abusive and violent man” who “threatened to hit my partner over the head with a hammer […]”
viii. “They have been subjecting us to racial harassment since we moved in shortly after the Brexit vote in 2016, calling me a ‘piece of shit’, ‘disgusting’, the stench, etc. We are European citizens.”

Regarding Referrer C and her family:

ix. “[They] instructed men to smash down several heritage protected walls of our garden”.
x. “They then stole 300mm wide x 15 meters length (approx.) of our property and built themselves an ugly concrete foundation and steel framed garage upon it”.
xi. “[Referrer C’s husband] has clearly abused his position of power […] In the past, he has similarly abused his position in the council to given himself permission to destroy walls and requisition part of our home for his own personal – and his wife’s – use (the ugly garage)”.
xii. “They have repeatedly abused their position of power to requisition our property for their own use”.
xiii. “Those in public office should not abuse their position to secure fraudulent permissions”.
xiv. “My disabled father is now dead aged 87, having been unable to ever access my home as a result of the earlier fraudulent planning permission and the ongoing harassment”.

Regarding all three Referrers
xv. Visitors from the Planning Inspectorate should “prepare themselves for the potentially abusive and/ or violent behaviour we know these occupants of no’s [addresses redacted] to be capable of”.

 

Referrer A’s account

20. Like Referrers B and C, Referrer A entirely refutes the Registered Person’s assertions in both the Letter and the Form.
21. By way of background, he explains in his written evidence that he has lived at that address since 1977 and that the Registered Person moved into her address in or around August 2016. Initially, their relationship had been ‘very neutral’.
22. However, during the period 2017-2019 a dispute arose between the Registered Person and one of their joint neighbours (Referrer C’s family) in relation to which the Registered Person had sought Referrer A’s support. The dispute related, first, to the Registered Person’s suggestion that Referrer C’s family had deliberately knocked down a wall and, second, to her suggestion that Referrer C’s family had illegally entered her property and cut her trees in her absence.
23. Referrer A had been unable to assist the Registered Person in either respect.
24. Regarding the wall:

‘[my wife] was not prepared to do this’, […] we were in the house when this occurred and we believe it was a complete accident caused by builders doing works behind the wall’,

25. Regarding the tree cutting:

‘We knew this was just not the case, as we could see the work that was being done from within their property. The Registered Person then produced some photographs and asked us to confirm that [Referrer C] had cut down the trees shown in the images, which included trees on our boundary. […] This was a bizarre request as the pictures showed trees which had been trimmed and cut dozens of years beforehand; they were trees which had been in that state for many years.’

26. After these points of contact, and having declined the Registered Person’s request for assistance, Referrer A had little contact with her until September 2023. Two events then occurred.
27. First, ‘a branch of a tree on the Registered Person’s property was leaning into our garden and had started to split near the trunk. I was in my garden and saw the Registered Person’s partner […] and approached him over the fence to discuss the branch as it had now dropped to head height on our side of the fence. FG readily agreed that the branch was a hazard and that it should be cut off. […] Therefore, the branch was cut with specific verbal permission from the Registered Person’s partner. The Registered Person was in Ireland at this time, so was not present for the discussion.’
28. Second, on around 24 September 2023, Referrer A was in his garden, sanding some shelves with an electric sander, when ‘the Registered Person proceeded to scream at me over the fence, making the accusation that we were trying to cut down her trees and were threatening her with a chainsaw and trespassing on her land.’
29. He continues:
‘The boundary between our Property and the Registered Person’s is delineated by a Victorian wall, and there is a 1.5 metre height difference at the back of our garden to the boundary of her property. This significant height difference runs around the whole property, reducing to around a quarter of a metre at the front. Due to this height difference, there is no possibility of encroachment onto her land occurring. Additionally, we have a 1.2 metre-high wooden fence on top of the wall which means it would have been impossible for the Registered Person to see what we were doing in our garden’.

‘The Registered Person continued to scream at me over the fence that I should stop damaging her trees, stop whatever I was doing, and she threatened to call the police. I waved the electric sander over the top of the fence, so that she could see what I was doing. She continued to scream at me about the trees being protected, that no one was allowed to touch them, and that I should stop. I finished sanding the shelves within the next three to four minutes and then went back inside. I was shaken up following this incident. She was screaming and angry, and I just didn’t know how to respond to her.’

30. Following this, he says that the ‘September 2023 incident made me think about the trees within the Registered Person’s garden, which had been overhanging our garden for a very long time. It had been over thirty years since the trees were last trimmed. At this point, I felt that I had nothing to lose and that I needed to protect myself and my family against future accusations of tree damage. On 5 October 2023, I made an application for planning permission to have the trees trimmed. While the trees were not protected by English Heritage, they were in a conservation area so there is a general Tree Preservation Order in place. The Authority’s Tree Officer came to the Property to conduct an inspection on Weds 15th November 2023 at 10:30h. During this visit, I was told in person by the Tree Officer that […] they would do a thorough investigation before granting permission. The planning permission was granted […] We then contacted a number of arborists to obtain quotes. […] The arborist we chose, Wild Tree Care Limited, agreed to trim the trees entirely from our property. I wrote to FG on 4 December 2023, advising him that we had obtained planning permission for the work, that we would arrange for it to be undertaken from our garden, and that we would keep them updated with regards to the process. On 7 December 2023, I received an email from the Registered Person saying “Please leave us alone. The police have been informed.”. The work on the trees was then completed on 6 March 2024.’

31. In support of his overall account, Referrer A produced:
i. An image of his electric sander;
ii. His planning application regarding the proposed tree trimming (5 October 2023);
iii. Referrer A’s correspondence to Norwich City Council (10 October 2023) in support of his planning application, attaching photographs together with a site plan marked ‘Not to scale’;
iv. A letter from Norwich City Council (20 November 2023) granting planning permission;
v. His exchange of correspondence with the Registered Person and her partner (4 and 7 December 2023); and
vi. Images of the works themselves being completed by Wild Tree Care Limited.

32. Subsequent to these matters, Referrer A became aware the Registered Person had submitted a planning application for CCTV cameras on her property. Upon reviewing it, Referrer A formally objected to the application on 19 February 2024 on the basis that the position of the cameras was inappropriate. He explained that (among other things) the cameras were ‘looking directly into our garden and into a spare bedroom of our house, in which we regularly have guests to stay.’
33. It was shortly after this that, on 22 February 2024, Referrer A became aware of the Letter.
34. It had been brought to his attention, he said, by other neighbours (‘One of these neighbours was a resident right at the end of the street, some ten houses away. Therefore, I was immediately concerned about the spread of the letter.’)
35. Having regard to the letter, Referrer A responds:
‘I can, with absolute certainty, say that there is no item of truth in the letter about me or my family. Every single word that mentions me by name or address is a lie.’
36. Within 48 hours, Referrer A submitted a complaint to ARB, which he has exhibited to the Committee.
37. Thereafter, on 1 May 2024, a further development occurred. He received an automated notification that there was a document on the Norwich City Planning Portal in relation to his aforesaid planning application.
38. The document in question was the Form referred in paragraph 1b of the Allegation. Having read its contents, he contacted the Government Planning Inspectorate via their portal ‘message’ service, and sent an email to Norwich City Council:
Within my email, I requested that they “remove at once a libellous document that contains personal and totally untrue information about me and other local residents from the planning portal”. The following day, 2 May 2024, I received confirmation that the document had been removed from Norwich City Council’s website. I also had an apologetic telephone call from the Government Planning Inspectorate, who explained that it normally took some time before issues submitted to the Government portal were read by a real person, but on receiving my complaint they had immediately reviewed the objection application and had decided to remove it from the portal as inappropriate.’
39. Referrer A exhibits both his email and the council’s apology in response.
40. Reflecting upon the Form, Referrer A says that it was ‘knowingly submitted by the Registered Person after planning permission was granted. It seems to me that this was maliciously used as an opportunity to present in the public forum, lies and misinformation.
41. Of its contents, he insists that:
i. He had never destroyed any trees and had only ever applied to trim them from his ‘side’.
ii. He had never owned, hired or used a chainsaw in his life. In oral evidence, he explained that this was because a close family member had once received a serious chainsaw injury. Regarding how the Registered Person had characterised their exchange (in paragraph 19 [iv], above), he added it was ‘‘bizarre and utterly ridiculous. How do you refute something so utterly imaginary? I’ve never threatened her or her partner ever. A fatuous lie.’
iii. He never illegally entered her garden, nor had he been responsible for driving wooden stakes into the ground. Rather, the wooden stakes were placed there by the previous owners of his property.
iv. Regarding the Registered Person’s claim that his planning application had been ‘fraudulent’ on the basis that he was claiming to own her property, and / or that he was seeking to seize some of her land (by, as she put it, his ‘totally fraudulent site plan, diminishing the size of my property […] by about 50%’); Referrer A refuted both suggestions. He said the planning application manifestly does not make the claim that he owns her property. Meanwhile, the ‘site plan’ served the sole purpose of identifying the position of particular trees, and it was clearly marked ‘not to scale’.

42. Likewise, he refutes the entire contents of the Letter as it pertained to him and his family.
43. Of particular offence to Referrer A was the Registered Person’s accusation of racial harassment. In his statement, he explained:
‘[This]was incredibly upsetting for me to read. Within my family, I have Polish, Singaporean, Spanish, Chinese, and Australian relatives. I have worked with the NHS and with a polyglot community from all over the world, my entire life. I have a clear understanding of the impact of this type of harassment, having counselled adults and young people who have suffered from this and its consequences. This accusation of being racist was particularly offensive.’

44. He returned to this theme in oral evidence to the Committee, saying the slur had engendered within him a feeling of real anger. He added that he had worked in mental health most of his life: ’I’ve been a champion of peoples equality all my life… this personal slur hurt me and my wife a lot.’ (His wife is a counsellor in local school.) ‘it’s the worst insult of all within this horrible process’.

Referrer B’s account

45. For his part, Referrer B indicates that his family have lived at his address for more than sixty years and that they had enjoyed a good relationship with the previous occupants at the Registered Person’s address.
46. The Registered Person moved into her home in 2016. At that time, he says:
‘[We]were beginning extensive building work at our Property. Therefore, I, and my builder separately, visited the Registered Person and explained the situation in that there would be vehicles, equipment, and material passing across the forecourt as this was the only way on to my premises. No vehicles, equipment, or material were stored on her property. Due to the building work, we moved out for October and November returning the week before Christmas 2016. There was very little interaction with the Registered Person or her partner at this time, although there were a series of letters between us at the beginning of the year relating to the forecourt.

On the 4th March 2017, my wife received an email from the Registered Person falsely accusing me of bullying and racial harassment. This was reported to the Police on the same date. On receipt of this email, it became clear that we would not have a good relationship with the Registered Person and her partner. Between the Property and the Registered Person’s property, there is a gate. There is no right of way, and the fence and gate are ours. We decided to remove the gate, as we knew there would be no good interaction with the Registered Person.

The ‘hammer’ incident

47. Having given the Registered Person and her partner written notice of his intention to remove the gate, on 12 March 2017 Referrer B began to replace it with a fence. He says:

‘Whilst I was doing this work, I could hear the Registered Person screaming at her partner from within her property. After a short conversation with the Registered Person’s partner […] I was then assaulted by him. He kicked through the shuttering I had put up, he picked up the shuttering (which was roughly a metre by half a metre) and threw it at me.
I was crouching down at the time and fended it off with my forearm, I then stood up, and told him he had just assaulted me. FG then ran away, crying “bullied, I am being bullied.” I immediately reported this incident to the Police who did not attend, as I advised I no longer felt at risk. I gave a statement at Bethel Street Police Station, and FG was interviewed under caution. […] The Registered Person later tried to claim that I had threatened FG with a hammer, which is not true, and I believe the above is the incident which the Registered Person describes as follows in her letter: “he threatened to hit one of us over the head with a hammer at one stage, after he was asked to desist”.
48. In oral evidence, Referrer B said that this was the occasion when he was using a hammer in connection with his work on the fence, but he was adamant that at no stage did he threaten the Registered Person’s partner with that hammer ‘or anything else’, adding: “Since this incident, my interaction with the Registered Person and her partner have been strictly limited to those regarding the shared garage forecourt.’

The Shared Garage Forecourt
49. He says:
At the front of our property, there is a shared garage forecourt area. […] The deeds do not dictate which area of the garage forecourt can be used by which neighbour, they just make it explicitly clear that the owners and occupiers of both properties have the right to pass and repass over the entire area at any time. Subsequently, I pay fifty percent of the maintenance for the forecourt.
Both I and my father before me had parked on the shared garage forecourt in front of our gates since 1971, with no issues. When the Registered Person and partner moved into [address redacted], they allowed vehicles to be parked on the forecourt, and I therefore assumed I could also park my vehicle there. However, the Registered Person has objected to my use of the shared forecourt. I therefore made it clear to them that if they respect the deeds, I will respect the deeds. While I accept that I cannot park there (as this obstructs the right to pass and repass), the same applies to the Registered Person and they cannot park or allow obstruction there either. […]
We have used the shared forecourt to put our bins out on bin day, ever since the introduction of wheelie bins. The Registered Person has now taken to moving our bins halfway down the car park, which is unnecessary and unpleasant. There is no reason for her to touch or move our bins, as their presence does not affect the shared right to pass and repass. Their bins are left permanently on the forecourt, in breach of our rights within the deeds […]’

50. It was against the background of these matters that, in February 2024, he became aware of the Registered Person’s application to install CCTV on her property. Having reviewed it, he objected as it would result in cameras pointing directly into his property. After this, a neighbour alerted Referrer B to the existence of the Registered Person’s Letter. He is aware, from undertaking his own enquiries, that it was widely distributed.
51. He says he found the Letter ‘incredibly distressing’, and insists its contents, as they pertained to him and his family, are untrue.
52. Regarding the allegation that ‘she threatened to burn [the Registered Person’s] car’, Referrer B assumes ‘she’ to be a reference to his wife. He says: ‘My wife is a Consultant Clinical Psychologist; she has never said this and never would say this.’
53. In relation to the suggestion that he had referred to the Registered Person as a ‘piece of shit’, Referrer B says he used to have a dog called Summer, and the only circumstances in which he might have used such language would have been when addressing his dog about using the garden as a toilet. He has never said it of, or to, the Registered Person:
‘I would always end with “Summer”, as in “that’s a bit of a stench Summer”. Occasionally, we get smells from the sewage treatment works. Presumably, the Registered Person has listened to me talking to my dog. I have only ever said this to the dog.’
54. He denied obstructing the Registered Person’s entry to her property.
55. He likewise denied threatening anyone with a hammer. Referrer B believes the Registered Person is referring to the incident where he was putting up a fence (i.e., paragraphs 47-48 above). This was an incident where Referrer B had been the victim of an assault. He reported this and, resultantly, it was FG who was then the subject of a formal police interview.
56. As to the allegation that he “had been starting to build a wall on our property illegally on a Sunday, following Trump’s declaration that he would ‘build a big wall’ to keep out immigrants”, Referrer B responded that none of this was true, adding:

‘I took great care to ensure that I did all of the work from my side of the fence, without stepping a single foot on their premises. The reference to Donald Trump is unnecessary and untrue.

57. More generally, he states:
‘[We] have never trespassed on to their property, we have never destroyed any part of their garden or property, and we have never been involved in any gender violence or racial harassment. This is completely untrue.’

58. He referred the Registered Person’s letter to the police, and he also made a formal complaint to ARB on 26 February 2024.
59. Referrer B was, thereafter, alerted by a neighbour to the Registered Person’s planning appeal form:
‘The contents of [the Form] were very concerning and were completely untrue. I have never threatened to hit the Registered Person or her partner with a hammer, and I have never racially harassed them or made a racial comment whatsoever. The Registered Person refers to me as “equally abusive and violent man”. I do not abuse people, and I have never been violent or threatened violence to anyone in my life. This is simply not true. Nor have my wife or I ever subjected anyone to racial harassment. The Registered Person goes on to claim that I have “diminish[ed] the size of [her] property […] as an attempt to requisition [her] property for [my] own use”. Again, this is simply not true.
60. In oral evidence, Referrer B’s position remained unchanged. Of the accusations, he repeated that any comments about ‘shit’ and ‘stench’ were not addressed to the Registered Person or her partner, but were made in private, from the confines of his own garden, in relation to his dog’s toileting conduct. He agreed he played music from his garden ‘mancave’, but it was not directed at neighbours, nor was it to annoy them. He accepted that he had no right to park in the shared forecourt, just as others (including the Registered Person) had no such right, but that – like them – he had done so intermittently though custom and practice. The video evidence relied upon by the Registered Person does not show any harassment, he suggests.
61. As to the accusation that he or his family had racially harassed anyone or conducted gendered violence, he said he had never done this to ‘anybody in my life’; while, to the general accusation of being ‘an […] abusive and violent man’, he stressed that he had never even received a parking ticket. He had never had a conversation with the Registered Person or her partner that could explain a link between him and Donald Trump’s comments regarding building walls to keep out immigrants.
62. Overall, he said the Registered Person’s behaviour in creating the Letter and the Form was a shock to him and his family:
‘‘People think, no smoke without fire, but this is. I find it offensive.’

63. In support of his overall account, Referrer B produced:

• An image of the shuttering he claims was thrown at him in the ‘hammer’ incident;
• A copy of the deeds relating to the forecourt establishing the joint right of way. The deeds state “[…] Together with the right for the Purchasers and their successors in title owners and occupiers for the time being of [address redacted] aforesaid to pass and repass with or without vehicles at all times over and along the garage forecourt”;
• An image of the Registered Person’s bins situated on the shared forecourt; and
• His initial complaint correspondence to ARB.

Referrer C’s account

64. Referrer C indicates that her family have lived at that address since 2010. When the Registered Person moved next door in 2016, their relationship had initially been good:
‘This included us having keys to her property to feed her cat whilst she was on holiday. Our first impressions of the Registered Person were therefore positive, reasonable, and trusting of her.’

65. Soon after she moved in, Referrer C alerted the Registered Person that her husband and her wished to undertake some works on their own property. Having obtained planning permission for those works, a seven-month build period (‘during which no objections or concerns were raised’) resulted in the works being finished in September 2017. She says:
‘Around this time, the Registered Person alerted my husband and I to a query regarding replacing a small wall we had taken down as part of the works. Replacing the small wall with a fence was part of the approved planning permission, and we had intended to instruct a smaller contractor to install the fence and wanted to discuss with them the type of fence they preferred. It was at this point that the Registered Person first alerted us to not being happy about knocking down the wall, which was wholly on our Property, and the first time we had become aware of any disputed boundary on the Property. We initially sought to resolve the issue amicably, however, this quickly became impossible. From this point onwards, our relationship with the Registered Person deteriorated significantly.’

66. Referrer C says they made attempts to resolve the dispute:
‘We responded twice to a letter we received from the Registered Person’s solicitor in February 2018, including offering to try to resolve the disputed boundary and fence installation, but we have never received a reply’.
67. However, such was the relationship’s deterioration that Referrer C’s family had to go to court to obtain a restraining order against the Registered Person. This order was made by Norfolk Magistrates’ Court on 19 July 2019 and remained in place until 18 July 2021.
68. It was against this background that Referrer C and her husband reviewed a planning application by the Registered Person to instal CCTV. Like Referrers A and B, she objected to the application. She explains:

“Although I had no objection to the Registered Person installing CCTV to protect her property, and respected her right to this, I objected to the positioning of the CCTV Cameras. It was clear that the position of some of the cameras directly overlooked our property boundaries, and looked into our back and side gardens. I did not want the Registered Person monitoring our movements or capturing images of us.’

69. However, before submitting her objection, Referrer C became aware of the Registered Person’s Letter seeking support from her neighbours.
70. Like Referrers A and B, she refutes its entire content, insofar as it refers to her and her husband:
‘[It] contained lies and untruths. It is full of accusations which are factually incorrect. I was upset and devastated at the thought of this being what our neighbours, workplace peers and senior local government officials would think we have done.’

71. To the specific allegation that Referrer C had improperly ‘demolished a historic wall, pier, fencing and trees’ etc, she denies this. In support, she relies upon the fact that – following a dispute with the Registered Person regarding this matter – Norwich City Council had, in January 2018, specifically undertaken a formal investigation. That investigation resulted in the council confirming in writing that there had been no breach of planning permission by Referrer C’s family:

‘this demonstrates that we conducted the process correctly, and that the Registered Person is lying.’

72. She further notes that the pathway was not altered.
73. Regarding the Registered Person’s allegation that Referrer C and her husband ‘have consistently refused to vacate our property, despite a court decision in our favour in 2019, requiring them to stay off our property’, she notes that this is untruthful, too:
‘The letter is factually inaccurate in that it implies that the restraining order was issued to my husband and I. It was not; it was issued to the Registered Person to protect us by preventing her from speaking to us or entering our Property. The insinuation that either my husband or I have broken a restraining order is completely factually inaccurate, as the restraining order was imposed by the Crown Prosecution Service (“CPS”) in the Magistrates Court on to the Registered Person.’

74. Referrer C says that she and her husband were ‘significantly distressed’ by the Registered Person’s false assertion that, because professional links exist between them and local government, Referrer C’s family thereby ‘appear to have exerted significant influence to escape justice’’. She says:
“I am currently employed as an Assistant Director within the Adult Social Services of Norfolk County Council, and this insinuation triggered a very emotional response from me. Furthermore, my husband has not worked for Norwich City Council since 2012, where he was in a significantly more junior position than he is now.’

75. More generally, Referrer C comments,
“The false accusations of gender and racial violence have been particularly damaging and distressing. Such serious allegations, made without any evidence, not only tarnish my reputation but also carry severe social and professional implications. The mere suggestion of such behaviour can lead to mistrust, isolation, and significant harm to our personal and professional relationships. These baseless accusations have caused immense emotional pain and anxiety, as they attack the very core of my character and integrity.
76. Finally, she says that the implication that they contributed in any way to the death of the Registered Person’s father is distressing and hurtful and that this is a serious and unfounded claim. Referrer C describes this claim leaving her feeling ‘devastated.’
77. In response to all these accusations by the Registered Person in her Letter, Referrer C submitted a complaint to ARB on 26 February 2024.
78. On 10 April 2024, Referrer C’s family also issued the Registered Person (though their solicitor) with a ‘cease and desist’ letter.
79. On 1 May 2024, Referrer C then became aware of the Form the Registered Person had posted in relation to Referrer A’s aforesaid planning application. She asserts that this, too, is wholly untrue. Moreover:
‘[…] the language used throughout is incredibly unprofessional. The tone and wording were not only inappropriate but also highly emotive and emotionally charged, which is not what I would expect from a Registered Architect.’

80. To the accusation in the form that Referrer C’s family “stole 300mm wide x 15 meters length (approx.) of our property and built themselves an ugly concrete foundation and steel framed garage upon it”, she explains:

‘We did build a new car port on an existing concrete foundation (slightly increasing the base) replacing an old 1950’s asbestos garage, however we did so with full planning permission, and the structures were built in line with the plans and within our properties’ boundaries.’

81. In support of her account, Referrer C produced:

• Correspondence from Norwich City Council (9 January 2018) with its investigative findings following alleged breaches of planning permission;
• A ‘Notice of restraining order’, dated 19 July 2019;
• Letter of complaint to ARB, dated 26 February 2024; and
• ‘Cease and desist’ letter to Registered Person dated 10 April 2024.

The Registered Person’s account
82. The Registered Person confirmed that when she and her partner first moved to that address, they ‘made great efforts to fit in’.
83. She had fallen in love with the house, and the vendor had chosen to sell it to her (rather than other potential purchasers) precisely because, as an architect, she could be entrusted to preserve its value and beauty.
84. Upon moving in, the Referrers initially sent her ‘welcome’ cards. She described Referrer A as having been ‘friendly’ and said Referrer C had invited her to tea. She was also involved in ‘cat-sitting’.
85. However, her relationship with the Referrers deteriorated. Matters became ‘very stressful’’ and indeed she was so ‘badly affected by it’ that she stayed away from her home for 4½ years.
86. Against that background of deterioration, the Registered Person accepts that she had indeed written and published both the Letter and the Form.
87. She confirmed in cross examination that, by the time she wrote the Letter, she knew (1) there had been no findings of impropriety or fraud against the Referrers, and (2) her allegations in these regards had already been rejected by the police and/or local government. She added,
‘I think I’d give this letter a serious editing if I did it again’.

88. Of the Form, the Registered Person claimed she had not realised it had been lodged ‘out-of-time’, attributing the oversight to other pressures in her life at that point (she had just started a new job, and her mum had health issues). She added, “I shouldn’t have named [the Referrers] in it – I apologise for that”.
89. More generally, she apologised if the tone of her correspondence was unprofessional (‘I didn’t intend it to be’). She accepted that she should have toned down the wording, that she should have spent more time writing the Letter, and that she should not have supplied the Referrers’ addresses.
90. The Registered Person accepted, though, that she wanted the reader of the Letter to understand that she was being harassed, and she also wanted the reader to believe a crime had been committed. In cross examination, she confirmed the Letter was intended to convey that Referrer B was racist (‘he is a racist’). She also agreed she wanted her neighbours to be perceived as misogynistic and sexist.
91. She explained that she was very upset and in mourning at the time of this correspondence and this might have affected her judgement. However, regarding the particular allegations she makes in the Letter and the Form, she maintained these were fundamentally accurate.
92. By contrast, she suggested the Referrers had conspired in their accounts to the ARB. In doing so, they were driven (she suggested) possibly by their desire to secure extended rights of land over her properly and/ or because they were racially motivated.
93. Thus, she insisted that the threat by Referrer B to hit her partner over the head with a hammer had occurred as described, albeit she was not present.
94. Likewise, she and her partner had received a threat to burn their car. She said she had evidence of this ‘somewhere’, adding ‘I have shown it to the police’.
95. In oral evidence she confirmed the chainsaw incident also occurred as described. In her written evidence, she put it thus:
‘The complainant’s actions were not only illegal but also posed a threat to the integrity of our Grade II listed private historic landscape. The use of a chainsaw on our property without provocation was also a threat to our health and safety and that of our family. Despite my clearly explained request that he put down his chainsaw, vacate my property, and leave us alone, and that I considered his actions to be harassment, he persisted.’

96. She insisted that Referrer B was calling her a ‘piece of shit’ when in the garden, and that this was the key aspect of the harassment, together with singing ‘Sledgehammer’. She confirmed she had never actually seen him saying the words ‘piece of shit’, as he would be on the other side of the fence and she was putting washing on the line. Her partner would not always necessarily hear it being said, as he would have on his headphones.
97. To the larger accusation of ‘racism’ against the three Referrers, she thought it was an inference that could properly be drawn to explain their conduct towards her (as an Irish/ American woman) and towards FG (a French man). It was also the likely motivation behind Referrer A ‘wielding’ his chainsaw. Additionally, she suggested Referrer C’s surname was one known to be linked to the Troubles in Northern Ireland. Consequently, Referrer C’s behaviour may have been because she ‘thought I was Irish’. The Registered Person confirmed in cross-examination that none of the neighbours had ever actually said anything about her Irish heritage.
98. As regards her allegation of ‘gender violence’ against all three Referrers, she said that, as a woman living on her own for a part of each week, encountering a 6-foot man in her garden with a chainsaw (i.e., Referrer A), she viewed necessarily as ‘gender violence’. She also suggested that, since the Referrers had targeted her, and not her male partner, this suggested the violence was gendered. (It was put to her in cross-examination that she had said, though, that her partner had been threatened with a hammer, and that he was the person alleged to have been referred to in the context of a ‘stench’. Her response to this was unclear.) As regards Referrer B, she posited that how he used his car (which she described as a ‘phallic symbol’) to drive repeatedly across her driveway was, from ‘a psychoanalytic perspective’, a manifestation of gender violence.
99. Regarding her use of the word ‘crime’ in relation to different aspects of the Referrers’ conduct, she accepted in cross-examination that (1) it was outside her expertise to identify other people’s conduct as a ‘crime’ and (2) the police had specifically written to her explaining that ‘theft of land’ was technically incapable of amounting to a crime. She responded, ‘I should probably not have used the term’. The Registered Person went on though, in re-examination, to say she had used the word ‘crime’ in the sense of a ‘heritage crime’ and not in the more everyday sense.
100. In relation to the restraining order, she maintained that the claim in her letter was true regarding Referrer C’s family ‘consistently refusing to vacate… despite a court decision’. She insisted a restraining order was indeed made against Referrer C and her husband, having been requested by her lawyer. She could not produce this restraining order.
101. In support of her account in all these regards, the Registered Person produced (among other things):
i. A court extract in relation to a Restraining Order;
ii. Video evidence of Referrer B on the forecourt. (One of the videos shows Referrer B asking FG to move his vehicle; another shows him moving a bin in front of the Registered Person’s gate);
iii. Video evidence which shows the frailty of the Registered Person’s father; and
iv. A collection of ‘Police Reports’ (mid 2021 to December 2024) These comprise approximately one hundred pages and establish a long period of contact by the Registered Person towards the police, making a range of allegations in relation to the Referrers.
102. However, the larger focus of the Registered Person’s attentions, in both her oral and written evidence, was around the Referrers’ conduct in relation to her property – a property said to be of historical significance – and the damage caused by them (and by others on their behalf) to her property. Approximately 1000 pages of supporting material was relied upon by the Registered Person in this regard. Some of this material was duplicated, but all of it has been considered by the Committee.
103. It includes, for example (and the following descriptors are the Registered Person’s):
‘Before and After’ Photographs of Grade II listed Garden and House, ‘Historical Map of the Garden’, ‘Conservation Area Guidelines, Thorpe Hamlet (1990s)’, ‘Historic England Listings (House and Garden)’, ‘Heritage Crimes Map’, ‘Refuting the referrers Misleading claim to title’, ‘Misleading / misleading planning applications (excerpts)’, ‘Survey of Green Tunnel’, ‘Commentary on the invisibility of referrers architect’, ‘Site Plan Drawing by Michael Everitt Architect, 1970s’, ‘Party Wall Act’, ‘Further fraudulent aspects of Referrer A’s planning application.’, ‘Sycamore Gap Tree Felling / National Trust estimate’, ‘Solicitors Letter to Referrer C (23 Feb 2018), including photos and 1966 letter sent with solicitor’s letter’., ‘Wheelchair users – understanding space requirements’, ‘Excerpts from Referrer C’s Planning application completed by Tyrell Lewis’, ‘Architects / Evidence of theft of my land needed for disabled access.’, ‘Conservation Officers Objections to Referrer C’s demolition of our Historic Walls’, ‘Photograph of Damage to one of our many trees by Referrer C’s Sept 2024’, ‘Email received from neighbour at 109 St. Leonards Road about Referrer C’s tree rampage September 2024’, ‘Pre-sale Particulars (Law Society Property Information Form) by previous owner of our house (excerpts)’., ‘Response by the previous owners solicitor to Pre-Contract Enquiries (Excerpt)’, ‘Letter from Previous Owner (downloaded 27 November 2024) confirming our ownership of our Green Tunnel and our garage forecourt’, ‘Witness Statement from Previous Owner (2020)’, ‘Referrer A’s Planning Application, where he claims to be the owner of our property.’, ‘Historic England Criminal Offences.’, ‘Tyrell Lewis Architects Refusal to Communicate (2018)’, ‘Suzy Lamplugh Trust Advice / National Stalking Helpline Advice’, ‘Ordnance Survey Historical Map’, ‘Gardener witness statement and photographs’

Together with,

• The Registered Person’s ‘Title Deeds’ (i.e., the Land Registry’s entry)
• Her ‘commentary’ on those ‘Title Deeds’

104. In essence, the Registered Person sought to establish by reference to these documents the truthfulness of her assertions (or, at least, the sincerity of her belief, based on documentary evidence) regarding the Referrers having damaged her home and garden, and having also unlawfully trespassed upon and/or built upon her land.
105. In addition, she appeared to place reliance upon these documents – together with her own oral and written evidence and that of Mr FG – concomitantly to demonstrate (in terms) that:
i. Referrer A’s planning permission was fraudulent; and,
ii. Insofar as planning permission had been granted at different times to Referrer A and Referrer C, it should not have been. The fact that it should not have been, and the fact that other conduct by the Referrers had not been the subject of redress, meant it had been reasonable for her to infer an abuse of power had arisen out of the links between Referrer C’s family and local government. (In oral evidence, both she and FG also suggested a ‘relationship’ existed between Referrer C and the local police.)
106. Under cross-examination, however, she confirmed she could not produce any evidence of impropriety or fraud (‘I’ll have to think about that’).
107. The Committee returns to these themes in its analysis below.

Mr F Girardin’s account
108. FG maintained that the Registered Person’s communications were substantially true and accurate. He confirmed that although he read both the Letter and the Form, he had no input into writing them.
109. He said the Letter was written because that was all ‘they’ could do – as the Referrers bullied everyone else, including the police and other institutions (‘it was difficult not to be angry, but we had to be safe from those people’).
110. Under cross-examination, he appeared to accept that the Registered Person’s planning appeal was submitted after:
• Norwich City Council had adjudicated upon the alleged planning breach by Referrer C (correspondence, 9 January 2018);
• The police had told them they were not taking criminal action; and
• The Restraining Order against the Registered Person had expired.

111. He agreed that, by 2024, the Registered Person was frustrated (‘anyone would be’) but said there was no anger on her part.
112. In relation to the allegations in Registered Person’s correspondence, he made the following comments:

i. Threat to burn car:
He insisted they had received a note from Referrer B’s family which said, in effect, ‘we need use the forecourt, otherwise someone from a neighbouring estate will burn the car’. Their lawyer had told them the note amounted to a threat and suggested they send it to the police. He agreed he could not produce a copy of the note.

ii. Referrer B threatening to hit him with a hammer:
He explained he had approached Referrer B and put his hand on the surface where Referrer B was about to apply his hammer. Referrer B’s hand, containing the hammer, remained aloft, and Referrer B had looked at him – his wife had then said ‘stop’. There was no physical violence, but he considered Referrer B’s actions aggressive. The Registered Person was in her home at the time.
He confirmed in cross examination that he was the person formally interviewed by the police in connection with this incident; confirming, too, that those details were not mentioned in the Form or the Letter.

iii. The ‘piece of shit’/ racism allegations
Although he would tend to wear headphones in the garden, FG said he had heard Referrer B use the expression ‘piece of shit’ towards the Registered Person more than once. Although it was said from behind a fence, he was sure it was directed to the Registered Person as it would only be said when she was in the garden. The words ‘disgusting’ and ‘stench’ – also said from behind the fence – were directed by Referrer B towards him, he believed.
In cross-examination, it was put to FG that the comments might (per Referrer B’s account) have instead been directed towards his dog. He did not accept this. When asked why, he relied upon a conversation he claimed to have overheard wherein Referrer B had said to Referrer A, “I’m going to call my dog ‘Piece of shit’ “. The exchange is said to have occurred sometime between October 2025 and April 2026 (i.e. post-dating Registered Person’s correspondence, and after this hearing had commenced).
He confirmed that none of the Referrers had said anything directly racist. However, it was his inference in the absence of any other explanation. That inference was fortified, in his view, by the fact that (i) sometimes a ‘Union Jack would ‘appear’; (ii) a wall had been constructed after the US President had talked about building a big wall to keep out immigrants; and (iii) whenever the England team played sport, Referrer C’s family would leave their doors open, and – especially when England played France – Referrer C’s family would cheer for England.

iv. Referrer A and the chainsaw
He was not present when this occurred, but the Registered Person phoned him afterwards and sounded scared.

v. Restraining Order
In cross-examination, he accepted that there was a Restraining Order against the Registered Person but insisted there was also one against Referrer C. In re-examination, FG then appeared to suggest the Restraining Order exhibited by Referrer C was against Referrer C.

vi. Referrer B obstructing the forecourt
FG confirmed the Registered Person’s account that Referrer B would park on the forecourt (where he only had a right of way), thereby obstructing his and his partner’s access. He also confirmed that Referrer B would park skips and sand on his property.

vii. Building works, and damage etc
More generally, FG addressed at length, as the Registered Person had done, the issues surrounding the Referrers having allegedly damaged their home and garden, and having also allegedly unlawfully trespassed upon and/or built upon their land.
He asserted that alterations to their ‘Green Tunnel’ had limited the access available to wheelchair-bound users; and, indeed, the Registered Person’s mother had been unable to visit their home once the Green Tunnel had been reconfigured. Under cross examination, he then appeared to accept wheelchair access through the tunnel remained possible; but, nevertheless, the alterations amounted to a technical breach.
FG accepted that planning permission had been sought and granted, and that this fact could have been mentioned in the Registered Person’s correspondence. However, he maintained that the planning permission had been improperly obtained, and that the council had not investigated such applications with the required degree of thoroughness.

viii. Regarding Referrer C’s family appearing “[…] to have exerted significant influence to escape justice”
FG confirmed in cross-examination that he had no evidence of this; it was purely an inference. He also agreed this theory had been reported to the police, and that the police – having investigated – reported back in 2021 that there was no criminality, thereby ending their investigation.
At the same time, though, FG recounted an incident where he and the Registered Person had been in the company of a police officer when that officer had taken a call from the husband of Referrer C. Upon ending the call, the officer’s manner then changed towards them. This led FG to conclude that Referrer C’s family had direct access to the police, noting the police station was directly adjacent to where Referrer C’s husband works. (Nothing of this alleged incident was put to Referrer C by the Registered Person’s representative when she gave evidence.).
In addition, he claims he was told that local government had initially intended to refuse Referrer C’s application for planning permission, but that the proposed decision was ‘overturned’ by someone more senior at the council. (The person, or people, who were alleged to have told him this were not witnesses at the hearing, and no written evidence from them was available to the Committee.)

Other witnesses’ accounts
113. The Registered Person also called oral character evidence from EH and LG. Each has known her for many years: EH as a friend, and LG in her professional capacity as a district councillor. Both witnesses attested to the Registered Person’s honesty, professionalism and integrity. They also referred to the Registered Person’s strong concern for her home’s historic value, and her concern about the safety of visitors to her home.
114. In addition, LG observed that the Registered Person had felt unsafe in her home and that Brexit had played a part in that. She said the Registered Person would ‘freeze’ when she saw the Referrers and would avoid contact with them.

Decision on Facts

The Committee’s Approach
115. In reaching its decision on facts, the Committee has borne in mind the burden of proof rests solely on the ARB. The Registered Person does not need to prove anything. The standard of proof is that applicable to civil proceedings, namely the balance of probabilities.
116. In reaching its determination, the Committee took into account all the written and oral submissions from the parties.
117. The Committee also took into account the advice provided by the Legally Qualified Chair – which was provided in public session and upon which the parties were invited to comment. The Committee accepted fully that advice.

The Committee’s Analysis of the Evidence and Findings
118. The Committee has considered each outstanding paragraph and subparagraph of the Allegation separately and has evaluated the evidence in order to make its findings on each of the particulars within the Allegation.
119. In order to do this, the Committee first reached the following primary findings of fact on the basis of the above evidence.

 

Primary findings of fact

Regarding Referrer A and his family
120. The Committee finds as a fact each of the following.
121. There were two occasions on which Referrer A trimmed the branches of trees belonging to the Registered Person, being those referred to in paragraphs 27 and 30. On each occasion, he undertook the trimming from his own side of the boundary (i.e., he did not enter the Registered Person’s property) and, on both occasions, the trimming was only in respect of tree branches that were overhanging his property.
122. On the first occasion, he obtained permission from FG before doing so. (Referrer A’s evidence in this regard was clear and precise, and it was not challenged in cross examination.)
123. On the second occasion, Referrer A obtained planning permission. The Committee finds that his account in this regard is corroborated by the documentary proof he exhibits: namely, the planning application itself, together with the correspondence from Norwich City Council dated 20 November 2023 granting planning permission. (The council’s correspondence, reference [REDACTED], says that ‘following an inspection by the Authority’s Tree Officer, your proposals are considered to be reasonable’, and Referrer A is granted planning permission to trim six trees ‘back to boundary’.)
124. Having considered the planning application form, the Committee finds nothing fraudulent in its contents. On a careful reading by any reasonably intelligent person acting in good faith, it plainly identifies that Referrer A is the applicant but that the trees themselves are on the Registered Person’s property (i.e., he does not claim her property to be his).
125. The Committee notes that, in support of his planning application, Referrer A submitted further information to the council, including a map. The stated purpose of that map is to identify the six overhanging trees he wished to trim. It is specifically marked ‘not to scale’. The Committee does not find the map is part of an attempt by Referrer A to steal the Registered Person’s land.
126. The documentary evidence adduced by Referrer A then goes on to establish that, once planning permission had been granted, (1) Referrer A wrote to FG (4 December 2023) explaining the trimming process due to commence and attempting to consult with him regarding arrangements; (2) the Registered Person replied (7 December 2023) with the words ‘Please leave us alone. The police have been informed’; and (3) the work was then undertaken (per the photographs) by Wild Tree Care Limited via an ‘access platform’ which was clearly being used from within Referrer A’s own property.
127. Overall, the Committee considered Referrer A’s evidence here had been clear, cogent and compelling. It was measured in tone and scope. It was supported by irrefutable documentary evidence. By contrast, the Registered Person’s assertion in evidence that that Referrer A had ‘submitted two almost identical planning applications’, as ‘an act of deliberate trickery’ to confuse the council is not borne out by the paperwork she herself exhibits. That paperwork makes plan from the council’s case number [REDACTED] that it is the same application to which Referrer A refers, and also makes plain the council were not confused regarding the application: viz. Referrer A was the applicant, but the overhanging branches were from trees located on the Registered Person’s address (hence the reference to both addresses).
128. Beyond those matters, the Committee went on to find as a fact that – notwithstanding oral and written claims of the Registered Person and her partner, and the documentation she relied upon (including photographs and plans etc. referred to in paragraph 103) – there was nothing to substantiate the accusation that Referrer A had done any of the following on, or to, the Registered Person’s property:
• ‘Destroyed’ or ‘chopped down’ trees, historic or otherwise,
• ‘Destroyed’ planting along the ‘green tunnel’
• Illegally entered her garden, driven wooden stakes into the ground, and/or
• Built upon the Registered Person’s property.
While the Registered Person produces photographs of trees etc having been cut, none of these demonstrate when the cutting etc occurred (on its face, it does not look recent), nor by whom.
129. The Committee likewise found that Referrer A never entered the garden of the Registered Person’s home ‘using’ or ‘wielding’ a chainsaw in her ‘direction’. Neither did he then proceed to chop down her ‘grade 2 listed trees’; nor did she have to ‘beg’ him to turn off his chainsaw. Rather, having considered written and oral evidence from Referrer A and the Registered Person, the Committee found Referrer A’s account much more measured, realistic and plausible. It could think of no reason why Referrer A would do as she suggested. It concluded the events had not occurred in the manner the Registered Person described in the Form; rather, hers was an invented account, confected out of the aforesaid ‘sander’ incident (paragraphs 28-29).
130. Furthermore, the Committee found as a fact that there was no racial harassment or gender violence by Referrer A towards the Registered Person or her partner. There was no ‘abusive and/ or violent behaviour’ by him, nor was any ‘repeated violent attacks’ by him, ‘upon [her] home’. Save for the inference she claims to have drawn from the chainsaw incident (her account of which the Committee rejects), the Registered Person was not able to point to anything in relation to Referrer A capable of supporting such accusations.
131. Finally, and more generally, there is no evidence of any concealment by Referrer A of ‘more serious crimes’. Indeed, there is no evidence of crimes at all, by Referrer A (or Referrers B and C). The Registered Person relies, in part, upon those documents exhibited by her as ‘police reports’. Taken at their highest, though, those ‘reports’ only establish that at some point in the past she might have been sincere in her belief that crimes had been committed (albeit not necessarily by Referrer A).
132. However, the ‘police reports’ make plain this is not the case. They make plain, too, that she had been told this repeatedly by the police (being told it, notably, before writing the Letter and completing the Form).
133. Among the entries in the ‘police reports’ are the following:
• A file note from the police (24 September 2021) which records having received, ‘[…] a collation of the incidents reported between these two neighbours over a number of years, most of which were reported to and closed by the police.’ It continues, ‘I visited the [Registered Person] in January […] but could find no new allegations in her reporting. A decision was made by local commanders that any allegation of wrongdoing against the local council had been investigated and dealt with by the city council. There was nothing further for us to investigate [the Registered Person] has been fully updated accordingly.
• Police email correspondence to the Registered Person (14 December 2021), wherein the police explain to her that ‘there is no provision in English Law for the ‘theft of land’ – it is not something that can be stolen. By the same token ‘trespass’ is not a crime in English law […].’
• A police file note (13 October 2021) where she is recorded alleging a fraudulent planning application, together with further police note of even date saying ‘I note [the Registered Person] has alleged (without providing any supporting evidence at this stage) corruption involving [the Referrers], NCC and Norfolk Constabulary’
• A police file note (8 April 2022) which asserts that ‘[the Registered Person] has not provided any evidence of a fraud and has stated she will not have an independent survey undertaken, which would at least assist in settling the dispute as to ownership [of] the disputed wall,’ [and] She appears fixated and obsessed with the boundary dispute and the majority of what she claimed was not rational or evidenced’
• A police file note (14 April 2022) regarding allegations of assault and criminal damage. Herein, the police note that ‘a wall has been apparently lawfully demolished by some builders. Furthermore, the criminal damage’ to some trees has already been looked into by MD, arboricultural officer with NCC with A/PS Burton of Norfolk Police and all works have been found to be in compliance with the planning application, as per his email to [the Registered Person] dated 21/3/19’. (The 2019 correspondence to the Registered Person is then quoted and makes plain she has been informed there was no evidence of criminal damage to trees, nor any evidence that Referrer C had acted other than ‘in accordance with regulations’.
• A police file note (2 May 2023) identifying topics for discussion with the Registered Person, including harassment, boundary dispute, parking, bins; and a subsequent file note (20 May 2023) which states ‘The investigation is now closed. There is no evidence to support the allegation […]’
• A police file note (9 January 2024) to the following effect: ‘The trees … have clearly been pruned in line with council guidance that has been sought appropriately under planning legislation. They have only been pruned to the property line and there is therefore no offence’
• A police file note (21 January 2024): ‘Trees assessed by OIC and found to have not been excessively trimmed and planning permission sought. The victim perceives it is hate-related as she is Irish but there has been no hate-related exchanges between suspect and victim within this investigation. Cancel crime question set completed. Victim made aware by post’

(The emphases are the CCommittee’s.)

Regarding Referrer B and his family
134. The Committee finds as a fact each of the following.
135. Referrer B was clear and adamant that there had been no threat made by his wife to ‘burn’ the Registered Person’s car. The Committee finds that no such threat was made. In coming to that view, it noted an absence of clarity regarding when the ‘threat’ was said to have been made, as well as regarding the terms in which it was said to have been framed. (In other words, was it the case that Referrer B’s wife had ‘threatened to burn [their] car’, per the Letter; or had Referrer B’s wife suggested that some third party from a neighbouring estate might do so, as FG indicated in oral evidence?) When such detail was explored with FG in cross examination, he responded with laughter.
136. Moreover, although the threat was said to have been made in writing (and the case materials exhibited by the Registered Person indicated the document would be ‘available on request’), the document itself could not be produced. Although the Registered Person and FG each said that the document’s contents had been shared with others – first with their lawyers and then (at their lawyers’ suggestion) with the police – there was no written or oral evidence from these sources to confirm having seen the document.
137. On balance, therefore, the Committee found as a fact that Referrer B’s wife had not threatened to burn the Registered Person’s car.
138. The Committee also found that Referrer B had never referred to the Registered Person and her partner in the terms set out in paragraphs 18 [v] and 19 [viii].
139. Referrer B was very clear that he might indeed have used the words, but specifically in the context of his dog. The Registered Person, like FG, fairly conceded she had actually never seen the words uttered; having drawn an inference from the other side of a fence, and having assumed it on the basis of her and her partner’s ethnicity. The Committee finds that she drew a false and unreasonable inference in this regard.
140. From her oral evidence, and from that of FG, it was clear neither of them could identify anything racist that Referrer B had ever said to them or said to anyone else in their presence. Neither could they identify any reference made by him to the general issue of ‘race’ – at any time or in any context. The Committee found in this regard that there was no link between Referrer B choosing to erect a fence on his property, and any comments about immigrants by the American President. Moreover, it could identify no basis upon which any reasonably intelligent person acting in good faith could infer such a link.
141. The Committee found as a fact that there was indeed an ongoing dispute regarding the shared forecourt, and the extent to which – by custom and practice – a deviation to the deed arrangements might have occurred by one or both parties. However, it did not consider this theme formed part of the mischief at the centre of the Allegation.
142. More significant was how the Registered Person had put matters:
“[Referrer B] has regularly obstructed us from entering our home and overturned our bins. He threatened to hit one of us over the head with a hammer at one stage, after he was asked to desist.
(The Committee’s emphasis)

143. The Committee finds as a fact that the hammer incident did not occur as described above. It prefers the account of Referrer B (paragraphs 47, 48, 55) as the accurate and more measured portrayal of events, being an account consistent with the surrounding events (i.e. that it had been Referrer B who reported the incident to the police, and FG who – as he himself accepted – had been formally interviewed in its regard (paragraph 112[ii])). Put shortly, the Committee finds Referrer B did not ‘threaten’ FG with a hammer.
144. In the absence of racist comments or hammer threats, per above, the Committee found as a fact that there was no ‘gender violence and racial harassment” by Referrer B towards the Registered Person and her partner.
145. The Registered Person’s video evidence did not depict any harassment by Referrer B towards the Registered Person or her partner.
146. Meanwhile, her reliance during cross-examination upon a psychoanalytic ‘reading’ of how Referrer B drove his car across their shared forecourt (paragraph 98) – an interpretive account she appeared to construct for the first time during oral evidence in order to justify her accusation of gender violence against Referrer B – underscored how tenuously she constructed serious accusations against other people, and how casually she dispensed them.
147. In summary, the Committee found as a fact there was no basis to justify the Registered Person’s public characterisation of Referrer B as an ‘abusive and violent man.’

Regarding Referrer C and her family
148. The Committee finds as a fact that that the work undertaken by Referrer C and her husband as a result of planning permission (granted on 7 February 2017) was undertaken in accordance with that permission.
149. Referrer C asserted this clearly and persuasively in oral and written evidence, and her account was supported by documentary evidence. In correspondence from Norwich City Council (9 January 2018), the council formally confirmed that, following its investigation, there had been no breaches of planning permission. Among the issues considered by the council, and addressed in the correspondence, were:
• ‘Lack of opportunity to object to the proposed works’
• ‘Removal of boundary beyond what has been approved, party wall agreement issues’
• ‘Loss of privacy’
• ‘Car port construction. Impacts of steel and glass terrace and associated works, steel staircase, gabion wall. Changes to fenestration’
• ‘Brick pier to front/street elevation – bricks don’t match existing, courses do not line through, mortar colour wrong’
150. Beyond those matters, the Committee went on to find as a fact that – notwithstanding oral and written claims of the Registered Person and her partner, and the documentation she relied upon (including photographs and plans etc. referred to in paragraph 103) – there was nothing to substantiate the accusation that Referrer C or her family had done any of the following on, or to, the Registered Person’s property:
• ‘Demolished a historic wall, pier, fencing and trees’;
• ‘Instructed men to smash down several heritage protected walls of [the Registered Person’s] garden”;
• ‘Stole 300mm wide x 15 meters length (approx.) of [their] property and built themselves an ugly concrete foundation and steel framed garage upon it”;
• “Built [a] garage one foot inside [the Registered Person’s] property’; and/ or
• [Along with Referrers A and B] ‘trespassed and further destroyed her listed garden.
151. It noted, too, the corroboration provided to Referrer C and her family by Referrer A regarding some of these matters (i.e., paragraphs 22-26, above)
152. The Committee likewise found as a fact that the Registered Person’s statement was inaccurate when she had said in the Letter that Referrer C’s family had ‘consistently refused to vacate our property, despite a court decision in our favour in 2019, requiring them to stay off our property”.
153. Referrer C refuted this, relying again upon documentary evidence to support her position. The Committee noted the documentation in question was a court order addressed to Referrer C and her husband and headed, ‘Notice of Restraining Order’. It formally identifies the Registered Person as the ‘defendant’ and indicates that an order is made against her in order to ‘protect (Referrer C and her husband) from further conduct which amounts to harassment’.
154. The two-year Restraining Order, dated 19 July 2019, is made in the following terms:
i. Not to contact directly or indirectly [Referrer C or her husband] save through solicitors regarding civil proceeding only
ii. Not to enter the curtilage of [Referrer C’’s property] as defined by the current Land Registry records.’
155. The order continues that ‘if the defendant [i.e., the Registered Person] does not obey any part of this order she will commit an offence and may be sent to prison for up to five years’
156. The Committee found that the Order was unambiguous and any reasonably intelligent person acting in good faith would understand its meaning. No such person could plausibly claim it intends the opposite meaning to the one it articulates. (The court extract, relied upon by the Registered Person, is likewise clear and substantially identical.)
157. As for the suggestion (paragraphs 100 and 112 [v]) that ‘another’ court order was made on the same occasion, but against Referrer C, two points arise. First, no such other court order has been produced for the Committee to view. Second, as a matter of legal reality, a court would not issue a Restraining Order against a complainant or a witness who is not formally before that court. It was the Registered Person who had been charged with criminal offences and was ‘before’ the court, not Referrer C or her husband.
158. Moving on, the Committee found no evidence, nor even a plausible constructive hypothesis, that might underpin the Registered Person’s claims about Referrer C’s family having ‘exerted significant influence to escape justice’. Speculation to this effect has been given no evidential underpinning.
159. Likewise, no evidence was produced to the Committee to support accusations of ‘gender violence and racial harassment against Referrer C’s family. The Committee found that the inferences the Registered Person and her partner claim to have reached in these regards were false, unjustified and wholly unreasonable.
160. Neither does the evidence permit a link to be established between any act or omission by that family and the death of the Registered Person’s father.
161. Set against those primary findings of fact, the Committee considered the particulars of the Allegation.

Particular 1(a) – The Committee finds this fact proved.
162. It is not in dispute the letter was written and distributed by the Registered Person.
163. While it was proper for her to seek support for the application to install CCTV, the Committee has determined that the particular terms in which she chose to do so, as set out on paragraph 18 above, were inappropriate both in tone and content.
164. That is, having identified the Referrers by reference to their postal addresses (something she confirmed, in cross examination, she should not have done), she then accuses them of a range of serious matters, including damage to her property, threats of assault, gender violence and racial harassment; doing so in language that was highly emotive and personal (e.g., ‘it is scary to hear your home being smashed up’).
165. The Registered Person herself conceded in oral evidence, ‘I’d give this letter a serious editing if I did it again’. However, in the Committee’s judgment, she knew the communication was inappropriately worded at the time she created it, and this is why – in hand-delivering it to her neighbours – she did not include the Referrers among the recipients.

Particular 1(b) – The Committee finds this fact proved
166. Again, it is not in dispute that the Form was written by the Registered Person.
167. The Committee has determined that the particular terms in which she chose to complete the Form, as set out on paragraph 19 above, were inappropriate both in tone and content.
168. That is, having identified the Referrers by name (something she confirmed, in cross examination, she should not have done – “I apologise for that”), she then accuses them of a range of serious matters, including fraud, theft, damage to her property, threats of assault, gender violence and racial harassment; doing so, again, in language that was highly emotive and personal (e.g., ‘I found him wielding his chainsaw [and ] I begged him to [stop]’.
169. The use of the form was inappropriate, too, for other reasons.
170. First, the form was plainly intended for the use of the person who had originally sought planning permission (in other words, Referrer A). As the form states, ‘the name of the person making the appeal must appear as the applicant on the planning application form to appeal a planning decision’. The Registered Person was, therefore, not the proper person to complete this form.
171. Second, the form was submitted out-of-time. The Registered Person claimed she did not realise this, but the Committee found this claim implausible. She is an experienced architect, and she personally inputted onto the form both the date of the planning application (10 October 2023) and the date of the ‘LPA’ decision to grant that application (20 November 2023). Moreover, by the date she submitted the Form (1 March 2024), she clearly knew the planning application had already been granted – as is evident from the exchange between her and Referrer A, captured in paragraph 126.
172. For the Registered Person to have completed the Form in such circumstances – knowing it could have no impact on the original application (which had already been granted and acted upon) – appears to have been motivated by nothing more than malice and the desire publicly to traduce the three Referrers named therein – two of whom, furthermore (Referrers B and C), had nothing to do with the planning application itself.

Particular 2(a) – The Committee finds this fact proved

173. Both the Letter and the Form contain numerous instances where, by her words, the Registered Person has misled the reader.
174. Having regard to the Committee’s findings of primary facts above, these instances include (but are not restricted to) the Registered Person having claimed, or plainly inferred, that:
i. Neighbours had destroyed trees and planting on her land – in circumstances where the only provable trimming was either undertaken by consent or by planning permission;
ii. Building works affecting her property had been undertaken without her consent – without mentioning that no breach of planning permission had been found following a council investigation;
iii. ‘Theft’ of her land had occurred – where she had specifically been told by the police it had not;
iv. Crimes generally had been committed – where the police had told her (and more than once) that this was not the case;
v. A chainsaw incident had resulted in a report to the police – without adding that the police had taken no action in its regard;
vi. One of the Referrers had ‘threatened to hit one of us over the head with a hammer’ – without mentioning that she had not witnessed this, and that indeed it was her partner who had been interviewed in connection with it, not Referrer B;
vii. A court order had been made in her favour – when the exact opposite was the case;
viii. A nexus existed between Referrer B building a wall and Donald Trump’s comments about walls to keep out immigrants – by directly eliding the two events without basis; and
ix. Acts of racial harassment and gender violence had been performed by the Referrers – when, as a highly intelligent woman, she knew her grounds for asserting this were completely spurious.

Particular 2(b) – The Committee finds this fact proved
175. The Registered Person is a professional. She is registered with a regulatory body and is subject to standards of conduct and practice. The obligation to act with integrity is, in the Committee’s view, a key part of the ARB’s Code. In particular, Standard 1.1 which expects an architect to act with honesty and integrity at all times.
176. The word ‘integrity’ is used to express the higher standards which society expects from professional persons and which professionals expect from their own members. In broad terms, ‘integrity’ denotes adherence to the ethical standards of one’s own profession, and professional integrity is linked to the manner in which that particular profession professes to serve the public (Wingate and Evans v SRA and SRA v Malins [2018] EWCA Civ 366).
177. In respect of the particulars, the Registered Person should have been aware of the proper ways in which to gather support for her CCTV application and in which to object to a planning application.
178. Instead, the Registered Person – having exhausted other formal channels (e.g., complaints to the police and to the council’s planning department) – took the opportunity to use both the Letter and the Form in order to pursue a vendetta against the Referrers. She framed both documents in inflammatory language, making a series of misleading and potentially damaging accusations against the Referrers with scant regard to their accuracy (and, in some instances, actually knowing they were untrue). Additionally, a number of the accusations were incapable of being relevant to the stated purpose of the Letter or the Form.
179. In sending inappropriate communications, she failed to act with moral soundness and rectitude, and she failed to adhere to the standards of ethics expected by the ARB. By her actions, the Registered Person demonstrated a lack of integrity and a departure from the higher standards that society expects from architects and the standards that the profession expects from its members.

Particular 2(c) – The Committee finds this fact proved.
180. In determining whether the Registered Person has been dishonest in relation to her actions at particular 1a and/ or 1b, the Committee applied the test established in the case Ivey v Genting Casinos [2017] UKSC 67.
181. This requires that the Committee must first ascertain (subjectively) the state of the Registered Person’s knowledge or belief as to the facts. The reasonableness of the belief is a matter of evidence going to whether she genuinely held the belief, but it is not a requirement that the belief must be reasonable.
182. Second, it must consider whether that conduct was dishonest by the (objective) standards of ordinary decent people. There is no requirement that the Registered Person must appreciate that what they have done was, by those standards, dishonest.
183. Set against this, the Committee found the Registered Person knew that:
• Per paragraph 129, Referrer A had not ‘wielded’ a chainsaw in her direction
• Per paragraph 131-133, no crimes had been committed; and
• Per paragraphs 156-157, there was no court order requiring Referrer C’s family to stay off her property.

184. By stating these things to be true when the Committee finds she knew them to be untrue, the Registered Person’s conduct was dishonest by the standards of ordinary decent people.

Annexes/ Other issues before and during the Facts stage

The outcome of Applications made prior to the hearing’s commencement.
185. The Chair of the Committee refused an application (6 October 2025) made by the Registered Person for the hearing to be heard in private. The Chair’s full determination is included at Annex A. To be handed down in private.
186. The Chair of the Committee granted an application (22 October 2025), unopposed by the ARB, made by the Registered Person for a third party (a lay representative) to have full rights of representation at the hearing. The Chair’s full determination is included at Annex B. To be handed down in private.

The outcome of Applications made during the facts stage.
187. The Committee refused a further application (28 October 2025) made on behalf of the Registered Person, and opposed by the Case Presenter for the hearing to be heard in private. The Committee’s full determination is included at Annex C. To be handed down in private.
188. The Committee heard an application made in private (Case Management Meeting, 26 March 2026) for the Registered Person to adduce further evidence. The application was granted in part. The Committee’s full determination is included at Annex D. To be handed down in private.
189. The Committee granted an unopposed adjournment application made by the Registered Person on 14 May 2026. The Committee’s full determination is included at Annex E. To be handed down in private.
190. The Committee refused an application (13 August 2026) by the Registered Person to shorten the length of the hearing. The Committee’s full determination is included at Annex F.
191. The Committee refused an application (12 October 2026) made by the Registered Person in private for named people in attendance to be excluded from observing the hearing. The Committee’s full determination is included at Annex G. To be handed down in private.

Decision on Unacceptable Professional Conduct (‘UPC’)
The Committee’s Approach
192. The Chair advised that whether the facts found proved amount to UPC is a matter for the Committee’s independent judgment and there is no burden or standard of proof.
193. UPC is defined as conduct which falls short of the standard required of a Registered Person in the circumstances.
194. In reaching its findings on UPC, the Committee recognised that not every shortcoming on the part of an architect, nor failure by him or her to comply with the provisions of the Code (‘The Architects Code Standards of Professional Conduct and Practice’, 2017) will necessarily give rise to disciplinary proceedings or a finding of UPC. Architects are expected to be guided by the spirit of the Code as well as its express terms. The Committee reminded itself of the Code’s introductory comments to the effect that ’The Code also covers your private life where your conduct may affect your fitness to practise as an architect, or public confidence in the profession.
195. In deciding whether the proven facts amounted to UPC, the Committee had regard to Spencer v General Osteopathic Council [2012] EWHC 3147 (Admin). It bore in mind that for a finding of UPC to be made, it required “a degree of moral blameworthiness on the part of the registrant likely to convey a degree of opprobrium to the ordinary intelligent citizen”.
196. The Committee also took into account the observation made by Mr Justice Kerr in Shaw v The General Osteopathic Council [2015] EWHC 2721 (Admin); namely, that although the conduct in question must be sufficiently serious, it does not need to be of such gravity that imposing an admonishment would be too lenient.

Findings of UPC
197. The Committee determined at the fact-finding stage that the Registered Person had sent inappropriate communications regarding her neighbours on or around 23 February 2024 and 1 March 2024, and that her actions in those regards had been misleading in the various respects set out in the facts determination at §173-174; that her conduct had lacked integrity for the reasons set out in that determination at §175-179; and that she had been dishonest in the ways particularised, and for the reasons stated, in that determination at §180-184.
198. The Committee relies upon those paragraphs of its facts determination. It does not rehearse the same points here, save to note that this conduct involved the Registered Person publicly naming her neighbours (the Referrers), and then accusing them of – among other things – theft, racism and gender violence.
199. In her accusations, she deployed carefully crafted emotional language, seemingly calculated to elicit from the reader a particular response.
200. Moreover, it is noteworthy that these inappropriate communications only occurred after the Registered Person had been repeatedly unsuccessful in pursuing her grievances through ‘official’ channels (e.g., complaints to the police and the local council).
201. Reflecting upon the Registered Person’s conduct, and considering the wider context in which it took place (as set out throughout the generality of the facts determination), the Committee considers this to be a very serious matter.
202. This was deliberate behaviour by the Registered Person, and its impact was profoundly felt by the Referrers, not least because it emanated from someone who, as an architect, had a particular social standing in the community.
203. In the Referrers’ own words:

Referrer A
‘The contents of [the Registered Person’s letter] had a huge impact upon us, in a number of ways. We have lived in friendly relations with practically everyone on our street since we moved here in 1977, and are personal friends with most of the residents in our immediate vicinity. But since the Registered Person sent the letter, it has created a number of problems. A few people showed us the letter, knowing that it was untrue, but with others it has created a distance and mistrust between us. The contents of the letter [have] also had a significant impact on my wife. Helen is a counsellor at a local school, and has been responsible for counselling parents and children in the immediate area for 29 years. The letter has led to a situation whereby people have chosen not to talk to her, which has been very distressing.
The accusations have been distressing to both me and my wife, painting ordinary actions (and worse, imaginary actions) as almost or actually criminal to our neighbours. […] For my part as a past trustee of the local Mind mental health charity and a mental health activist as well as having been the business manager of the city NHS Walk-in Health Centre, [the Registered Person’s] bizarre accusations of threatening behaviour and the racist accusations have been a source of acute embarrassment and personal discomfort to me. Luckily my (and my wife’s) professional colleagues have been very supportive and understanding since they are aware of our past reputations and the reality of our situation. Her bizarre actions and accusations towards us and our immediate neighbours have had a significant impact on us all, and this has also affected our relations with our neighbours as well”.

Referrer B
‘These events have been very depressing and upsetting for us, and there has been a significant impact among our neighbours caused by the letter the Registered Person sent. For example, one of the neighbours is quite old and has the beginnings of Dementia. He was furious about the “six 150-year-old trees being cut down”, until I explained to him that these trees had never existed. I have heard of other neighbours making comments such as “there is no smoke without fire”.

‘Some people have been influenced not only by the contents of the letter, but by the fact that the Registered Person hand-delivered them personally and spent time with people telling them lies. I went to see one of them, who told me he had made a comment of support on the Planning Application due to her influence and the fact that she was a fellow Registered Architect, so he had believed what she had said.
‘The personal impact has been huge. We don’t spend much time in our garden anymore, because the Registered Person and her partner are always looking at us. Our daughter used to use a running machine in the car port, but she doesn’t anymore as she was aware of being watched by FG from an upstairs window. We rarely have guests come to visit us, because we don’t want to risk having them park outside the gates and receive abuse from the Registered Person. This was never a problem with the previous owners, as we would just have a courteous conversation with [the previous owners] to let them know that we were having people to stay, and vice versa.
‘We have sat here and wondered what have we done to deserve this. Everything the Registered Person has said is a lie. She is an absolute disgrace to her profession.’

Referrer C
‘The impact of the letter was substantial. I was incredibly upset that my colleagues and neighbours would think that way about myself or my husband. I fear for the safety of my children, and as a result of the Registered Person’s behaviour we have had to change how we behave in the local community. We have had to change how the children get to school, and discuss with them what to do if they see the Registered Person, or if a Police Officer knocks on the door.
‘Whilst the letter triggered a very emotive response from us in terms of what our local community would think about us, the planning appeal submitted by the Registered Person caused us considerable concern around our professional positions and the potential consequences if these untrue rumours were to be continuously circulated in a public forum.
‘The impact of the Registered Person’s behaviour has reached my workplace. In the past, I have been approached by colleagues who were unaware of where I lived, making comments about my neighbour. This made it clear that they had either been directly contacted by the Registered Person or had heard about her accusations from others who received her communications. After discussing this with colleagues and reviewing the evidence bundles, it has become evident that the Registered Person has been contacting people I work with for years about our alleged behaviour, unbeknownst to me. I constantly worry about the spread of these false allegations and their potential impact on my professional relationships and reputation.
‘We talk about this almost daily, and constantly think about the fact that our neighbours may believe the contents of the Registered Person’s letter. It is clear that some neighbours do because, in her evidence bundle, there are emails from neighbours who responded to receiving her letter, supporting her planning application for the CCTV cameras. These responses from our neighbours show that the Registered Person’s false accusations have influenced their perceptions of us, further isolating us within our community.
‘My biggest concern is over the safety of my family. There is a constant feeling of being watched by the Registered Person, and we no longer enjoy our garden like we used to, the Property, or the local community. We will walk down the street and people will cross the road as they do not want to become involved in any dispute with the Registered Person.
‘Another significant concern is the risk that either my husband or I may lose our jobs or have our future career opportunities affected because of the Registered Person’s actions. The false allegations she has made against us have forced us to take measures to protect our professional reputations. When some of the incidents have occurred, we have felt compelled to inform our employers, communications teams, and board members about the allegations. This constant need to defend ourselves and provide explanations has created an environment of stress and apprehension at work.’
204. In oral evidence to the Committee, Referrer C amplified her position still further. She said that, as a director of health and social care at the local council, she was particularly ‘devastated’ by the Registered Person’s reference to racism and harassment. The Letter to neighbours had caused her ‘complete fear’ precisely because it had emanated from an architect and, as such, would carry weight and respect in the community.
205. The Committee determined that the Registered Person had, by her conduct, wholly failed to comply with the Architects Code Standards of Professional Conduct and Practice (2017) (the Code) in each of the following respects:

Standard 1 – Honesty and Integrity
Standard 1.1: You are expected at all times to act with honesty and integrity and to avoid any actions or situations which are inconsistent with your professional obligations. This standard underpins the Code and will be taken to be required in any consideration of your conduct under any of the other standards.
Standard 1.2: You should not make any statement which is contrary to your professional opinion or which you know to be misleading, unfair to others or discreditable to the profession.

Standard 9 – Maintaining the reputation of architects
Standard 9.2: You are expected to conduct yourself in a way which does not bring either yourself or the profession into disrepute.

Standard 12 – Respect for others
Standard 12.1: You should treat everyone fairly […].’
206. Accordingly, for the reasons set out above, the Committee has concluded that the particular findings of fact (taken both singularly and cumulatively), together with the corresponding breaches of the Code, were sufficiently serious to impact adversely both on the reputation of the Registered Person and upon the profession generally.
207. The Committee therefore finds that the Registered Person’s conduct amounts to Unacceptable Professional Conduct.

The outcome of Applications made during the UPC stage

208. The Committee partly agreed an application (13 October 2026) made on behalf of the Registered Person, and opposed in part by the Case Presenter for additional materials to be adduced. The Committee’s full determination is included at Annex H. To be handed down in private.
209. The Committee refused an application (13 October 2026) made on behalf of the Registered Person, and opposed by the Case Presenter, for the hearing to be adjourned. The Committee’s full determination is included at Annex I. To be handed down in private.
210. The Committee refused an application (13 October 2026) made on behalf of the ARB, and opposed by the Registered Person, to adduce at this stage in the proceedings (i.e., when considering UPC) the determination of the PCC dated 4 March 2021. The Committee’s full determination is included at Annex J.

Decision on Sanction
The Committee’s Approach
211. In considering the issue of sanction, the Committee accepted the advice given by the Legally Qualified Chair. This was provided in public session and the parties were given the opportunity to comment upon it.
212. The Committee took into account its previous findings, together with all the submissions made by the Case Presenter and by the Registered Person.
213. The Committee also took into account the Sanctions Guidance. The Committee was mindful that the purpose of any sanction is not to punish the Registered Person but to protect the public and the wider public interest. The public interest includes upholding public confidence in the profession and declaring and upholding proper standards of conduct and competence.
214. Throughout its deliberations, the Committee applied the principle of proportionality by taking into account the aggravating and mitigating factors, and weighing the Registered Person’s interests with the public interest. It considered the available sanctions in ascending order of severity.

Sanction decision
215. In determining what sanction (if any) to impose, the Committee identified the following aggravating factors:
i. The present conduct occurred against the background of a previous disciplinary finding in 2021 which – significantly – involved two of the three Referrers at the centre of this case. On that occasion, the Registered Person had been found guilty of unacceptable professional conduct on two bases:
• Firstly, that she had sent ‘a number of abusive and/or offensive communications to Neighbour A between 9 – 13 January 2018’. This involved sending texts containing a number of expletives, wherein the Registered Person repeatedly called Neighbour A and her husband racists and Nazis, as well as making offensive references to their physical characteristics.
• Secondly, that she had sent ‘a number of abusive and/or offensive communications to Neighbour B between 10 – 11 January 2018’. This involved repeatedly used offensive swear words, calling Neighbour B and her husband racists and Nazis, and making offensive references to their physical characteristics and mental health.

The Registered Person was found to have acted in breach of Standards 9.2 and 12.1 of the Architects Code: Standards of Conduct and Practice 2017 (‘the Code’) and the sanction imposed was a £2,000 Penalty Order. In imposing that sanction, the previous PCC had heard submissions on the Registered Person’s behalf to the effect that:
(a) She was otherwise of good character and that those matters had occurred ‘[…] at a time of serious and significant distress and upset to [the Registered Person] due to the personal welfare of herself and others and the need to protect her property’;
(b) She recognised her actions had been ‘ill advised’, ‘she had made a serious error of judgment’, and ‘it has taken [her] some time to learn the lessons [she] needed to learn […]’; and
(c) She would not act ‘in a similar way again.’

In deciding to impose a financial penalty, that PCC identified a number of mitigating factors. These included (a) the fact that the abusive and/ or offensive communications had not been placed in the public domain; (b) the Registered Person had begun a process of remediation; (c) her conduct had been out of character; and (d) she had no adverse regulatory history. At the time, the PCC determined ‘the risk of recurrence […] to be low but not insignificant given her ongoing strong views about [her home]’
ii. It was against precisely this background that the present set of events occurred. These present events establish yet a further pattern of poor conduct; a pattern which suggests her behaviour from the 2021 determination was not ‘out of character’, and that any earlier process of remediation had been ineffective.
Notably, the pattern of poor conduct in the present instance is multivarious in its presentation (as set out earlier in the Committee’s determination), repeated across two documents (the Form and the Letter), and this time involves no fewer than three complainants (Referrers A, B and C).
iii. More generally, the present conduct includes several instances of dishonesty.
iv. On this occasion (unlike the 2021 disciplinary matter), the Registered Person has specifically placed the inappropriate communications in the public domain – falsely making very serious allegations which impugn the character of each of the three Referrers. The Committee considered this to have been an escalation in her unacceptable conduct.
v. By her behaviour, the Registered Person thereby caused significant and wholly understandable distress to all three Referrers and their families.
vi. Moreover, her own insight into these matters was negligible.
(For the avoidance of doubt, although the Committee recognised these were denied particulars, this did not preclude the Registered Person making evident that she understood in principle why the conduct alleged was inappropriate; and how, if true, it might have the impact the three Referrers suggested – as well as how it might impact upon public confidence in the profession.)

216. Turning to mitigating factors, the Committee could only identify the following:
i. The conduct occurred at a time when the Registered Person appeared to have other stressors in her life, including family health concerns; and it occurred in circumstances where she considered she was protecting her property and her loved ones.
ii. Character evidence attests that the Registered Person is otherwise known as a person of honesty and integrity; someone held by them in the highest regard. Apart from her unacceptable professional conduct in relation to the three Referrers, the Committee noted that Registered Person otherwise had no adverse matters recorded against her, and there had never been any findings in relation to her professional work as an architect.
217. Set against these aggravating and mitigating factors, and bearing in mind the purpose of sanctions, the Committee then went on to consider which sanction, if any, it should impose.

No Sanction
218. The Committee first considered whether to conclude the case by taking no action on the Registered Person’s registration. In doing so, the Committee considered paragraph 6.1.2 of the Sanctions Guidance which states:
“In rare cases the PCC may conclude, having had regard to all the circumstances, that the level of seriousness of the architect’s conduct or incompetence is so low that it would be unfair or disproportionate to impose a sanction. Where the PCC has determined a sanction is not required, it is particularly important that it is clear in its written reasons as to the exceptional circumstances that justified imposing no sanction.”
219. Exceptional circumstances are unusual, special, or uncommon. The Committee determined that neither the background to this case nor the specific circumstances that arose could be properly characterised as exceptional. Furthermore, the Committee concluded that the finding of UPC alone would not be sufficient, proportionate, or in the public interest. In reaching this conclusion the Committee was mindful that the Registered Person’s failings diminished both her reputation and that of the profession generally. The Committee therefore concluded that the Registered Person’s conduct was sufficiently serious for it to require the imposition of a sanction.

Reprimand
220. The Committee considered whether to impose a reprimand. The Committee took into account the non-exhaustive factors as set out in paragraph 6.2.2 which indicate when a reprimand may be the appropriate and proportionate sanction.
221. The Committee considered, however, that the facts here were too serious to be met by the imposition of a reprimand.
222. Furthermore, given the absence of insight, remorse, or remediation, coupled with the Registered Person’s disciplinary history, the Committee was unable to exclude the significant possibility of further such unacceptable professional behaviour – and, thereby, further adverse impact upon the Referrers as members of the wider public.
223. Neither, withal, could it be said that the conduct represented an isolated incident.
224. In those circumstances, the Committee concluded that rather than uphold the Committee’s regulatory duty to protect the public, maintain public confidence in the profession, and uphold proper professional standards and conduct for members of the profession, a reprimand would undermine these objectives.
225. Therefore, the Committee concluded that a reprimand would be neither appropriate nor proportionate.

Penalty Order
226. The Committee considered whether the imposition of a penalty order would be sufficient and effective in reinforcing the importance of complying with the Code and acting with honesty and integrity at all times. The Committee concluded it would not.
227. Given the particular circumstances of the case, it concluded a financial penalty would add nothing of materiality to the significance of public censure in the form of a reprimand. Moreover, a penalty order would be insufficient to protect the public and meet the wider public interest, given the nature and gravity of the Registered Person’s conduct and behaviour.

Suspension Order
228. The Committee next considered a suspension order. A suspension order would re-affirm to the Registered Person, the profession, and the public, the standards expected of a registered architect. The Committee noted that a suspension order would prevent the Registered Person from using the title of ‘Architect’ during its period of operation, which would therefore provide a degree of protection to the public.
229. However, the Committee determined that – taking together the nature and seriousness of the Registered Person’s conduct, the integrity issues, the dishonesty, the previous disciplinary history, and the absence of insight or remorse – a suspension order would not be sufficient to maintain public confidence in the profession and the regulatory process. It would also not have a deterrent effect upon other Registered Persons.
230. Furthermore, the persistent and wide-ranging nature of the Registered Person’s behaviour indicates an attitudinal problem that may be entrenched. While her conduct is of a kind capable of being rectified, there was no evidence before the Committee to facilitate the belief that, were the Registered Person to be suspended, the conduct would be so rectified such that, upon her return from a suspension, it would not re-occur.
231. Having determined that a suspension order does not meet the objectives of public protection and upholding the wider public interest, the Committee determined that the Registered Person’s name should be removed from the Register.

Erasure
232. The Committee acknowledged that erasure is a sanction of last resort and should be reserved for those cases where there is no other means of protecting the public or the wider public interest. The Committee decided that this was such a case, due to its nature coupled with the high risk of repetition. The Committee concluded that any lesser sanction would undermine public trust and confidence. At present, the Registered Person’s behaviour is fundamentally incompatible with continued registration as an architect.
233. The Committee had regard to the impact erasure may have on the Registered Person but concluded that her interests were significantly outweighed by the Committee’s duty to give priority to the significant public interest concerns raised by this case.
234. In these circumstances, the Committee decided that the only appropriate and proportionate order is erasure.
235. The Committee recommends that the Registered Person is not permitted to apply to re-join the Register for the minimum statutory period of two years. It has determined this period to reflect the seriousness with which it views her behaviour and her seeming attitude towards it. The Committee considers the period will give her time to reflect upon how to conduct herself in accordance with the Code, and thereby to be able to demonstrate that understanding in any application for re-instatement she might subsequently choose to make.