⟡ “You Called It Escalation, We Call It Retaliation” ⟡
A pre-action protocol letter becomes a landmark record of public law abuse, disability breach, and safeguarding misuse dressed up as care.
Filed: 25 April 2025
Reference: SWANK/WCC/PLO-01
📎 Download PDF – 2025-04-25_SWANK_Legal_Westminster_PLOEqualityBreachPreAction.pdf
Formal pre-action notice challenging the unlawful escalation of PLO proceedings despite known disability status and lack of safeguarding threshold.
I. What Happened
On 25 April 2025, the claimant (Polly Chromatic) issued formal notice of intent to seek Judicial Review after Westminster Children’s Services escalated her family into Public Law Outline (PLO) proceedings without any lawful basis. Despite extensive written medical evidence — including a psychiatric report dated 26 November 2024 — confirming her need for written-only communication due to severe respiratory and psychiatric disabilities, the local authority categorised this clinical adjustment as “non-compliance.”
The letter outlines breaches of the Equality Act 2010, Human Rights Act 1998, and public law principles of fairness, and formally demands withdrawal from the PLO process.
II. What the Complaint Establishes
Unlawful escalation to PLO despite absence of safeguarding threshold
Mischaracterisation of written engagement as defiance
Breach of medically prescribed communication adjustments
Discriminatory treatment of a disabled parent in legal proceedings
Institutional use of child protection frameworks to retaliate against rights-based advocacy
III. Why SWANK Filed It
This letter captures the moment when procedural misuse crosses into deliberate reprisal. Westminster not only ignored a decade of medical evidence — it actively escalated proceedings to punish a disabled mother for invoking her legal rights.
SWANK London Ltd. archived this document to:
Expose systemic abuse of the PLO process against whistleblowers
Document a textbook breach of Sections 20 and 149 of the Equality Act
Establish a public record of legal intimidation masquerading as child protection
IV. Violations
Equality Act 2010 – Section 20 (reasonable adjustments), Section 149 (public sector equality duty)
Human Rights Act 1998 – Article 6 (fair trial), Article 8 (private and family life)
Children Act 1989 – Misuse of safeguarding framework
Common Law – Breach of legitimate expectation, procedural fairness, and proportionality
UN Convention on the Rights of Persons with Disabilities – Article 21 (access to communication)
V. SWANK’s Position
This case reflects the growing pattern of weaponising safeguarding against disabled and vocal parents. When Westminster social workers dismiss lawful communication boundaries as obstruction, and then escalate under PLO frameworks without lawful foundation, the result is not protection — it’s persecution.
SWANK London Ltd. calls for immediate regulatory scrutiny, including:
Audit of all PLO decisions involving known disabled parents
Disciplinary review of staff who labelled medical adjustments as “non-engagement”
Compensation and public acknowledgement of wrongdoing
⟡ This Dispatch Has Been Formally Archived by SWANK London Ltd. ⟡ Every entry is timestamped. Every sentence is jurisdictional. Every structure is protected. To mimic this format without licence is not homage. It is breach. We do not permit imitation. We preserve it as evidence. This is not a blog. This is a legal-aesthetic instrument. Filed with velvet contempt, preserved for future litigation. Because evidence deserves elegance. And retaliation deserves an archive. © 2025 SWANK London Ltd. All formatting and structural rights reserved. Use requires express permission or formal licence. Unlicensed mimicry will be cited — as panic, not authorship.
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