⟡ Chromatic v RBKC & Westminster: A PLO in Retaliation’s Clothing ⟡

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⟡ “A Year of No Risk — Followed by a PLO. That’s Not Safeguarding. That’s Strategy.” ⟡
Judicial Review pre-action outline challenging retaliatory PLO issued by Westminster and RBKC following police complaint and failure to disclose outcome

Filed: 23 April 2025
Reference: SWANK/RBKC-WESTMINSTER/JR-PLO-RETALIATION
📎 Download PDF – 2025-04-23_SWANK_PreAction_JR_PLORetaliation_KirstyHornal.pdf
Outline of legal challenge against RBKC and Westminster for unlawful safeguarding escalation, disability discrimination, and data protection breach

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I. What Happened

On 23 April 2025, Polly Chromatic prepared a formal Judicial Review Pre-Action Letter Outline, instructing her solicitor to initiate proceedings against the Director of Children’s Services for RBKC and Westminster. The proposed claim challenges a PLO letter dated 14 April 2025, issued by Kirsty Hornal and approved by Sam Brown, despite:

• No safeguarding concerns after a full year of investigation

• No final report or explanation of any findings

• A police report filed by the claimant weeks earlier regarding misconduct

• Repeated disregard for disability accommodations

The escalation to PLO was framed as retaliatory, procedurally flawed, and incompatible with domestic and human rights law.

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II. What the Complaint Establishes

• Procedural breaches: PLO invoked without final assessment; data withheld; retaliatory timing

• Human impact: Physical illness, psychiatric distress, deterioration in trust and stability

• Power dynamics: Misuse of statutory authority to punish protected acts — especially police complaints

• Institutional failure: Breakdown of communication, documentation, and proportionality

• Unacceptable conduct: Conflation of compliance with submission; medical silence repackaged as risk

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III. Why SWANK Logged It

Because a PLO without an outcome report is not legal process — it’s institutional gaslighting.
Because when you file a police report and receive a PLO letter weeks later, that’s not coincidence. It’s code red.
Because safeguarding is not supposed to function as reprisal.
And because this filing makes it clear: disability isn’t risk. It’s a right — and rights don’t expire when the council feels threatened.

This isn’t a PLO challenge. It’s a declaration of war on retaliatory bureaucracy.

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IV. Violations

• Children Act 1989, Section 47 – escalation without lawful evidence or procedural integrity

• Equality Act 2010, Sections 20, 21, 27, 149 – discrimination, failure to adjust, and retaliation for protected activity

• Human Rights Act 1998, Article 8 – interference with private and family life via unjustified statutory action

• Data Protection Act 2018, Sections 45–54 – unlawful withholding of outcome documents

• Common Law Public Law Principles – breach of legitimate expectation and proportionality

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V. SWANK’s Position

We do not accept that filing a police report is grounds for safeguarding escalation.
We do not accept that silence is neglect when the silence is medical.
We do not accept that the absence of findings can be used as justification for further scrutiny.

This was not lawful child protection.
It was revenge policy in a PLO envelope.
And SWANK will litigate it line by line, citation by citation, archive by archive.

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