When Retaliation Becomes the Policy Itself

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⟡ SWANK Regulatory Complaint ⟡

“When the Safeguarding Process Requires Its Own Complaint Procedure”
Filed: 2 June 2025
Reference: SWANK/LGO/WCC/2025-06-02
📎 Download PDF – 2025-06-02_SWANK_OmbudsmanComplaint_KirstyHornal_SafeguardingThreat_DisabilityBreach.pdf

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I. The Escalation Westminster Engineered

On 2 June 2025, SWANK London Ltd. formally referred Westminster City Council — and specifically Ms Kirsty Hornal — to the Local Government and Social Care Ombudsman. The cause?

An email.
A threat.
A choreography of coercion dressed up as child protection.

Ms Hornal, having already ignored a documented disability adjustment requiring written-only contact, elected to inform the claimant (a disabled mother in active litigation) that Westminster was “applying to court for a supervision order.”

There was:

• No risk

• No assessment

• No meeting

• No procedural basis

There was only a safeguarding pretext, delivered as an act of bureaucratic retaliation.

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II. The Offences Committed

This complaint identifies four core domains of institutional failure:

1. Disability Discrimination
   Breach of Equality Act 2010, Sections 20, 26, and 27 — failure to uphold adjustments, repeated knowingly.

2. Human Rights Violation
   Article 8 of the Human Rights Act 1998 — family life interfered with via administrative threat.

3. Retaliatory Conduct During Litigation
   Issued while a live civil claim (N1) was underway — a textbook misuse of institutional power.

4. Collapse of Complaint Pathways
   Westminster’s internal handling was either performative or prejudiced — necessitating third-party regulatory involvement.

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III. The Evidence (And Its Tone)

• Exhibit A – The offending email

• Exhibit B – The documented disability communication directive

• Exhibit C – The police report acknowledging coercion

• Exhibit D – Evidence of the ongoing civil proceedings against Westminster

This wasn’t a safeguarding plan.
It was an administrative flex — designed to intimidate a disabled parent mid-litigation.

And now it’s documented in triplicate, distributed to Parliament, the police, regulators, and the public archive.

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IV. SWANK’s Position

Let us be clear:
We are not appealing to conscience. We are activating governance.

When the safeguarding process is used to frighten, not protect, it becomes necessary to file complaints about safeguarding itself.

And when that happens —
You are no longer safeguarding children. You are safeguarding power.

This Ombudsman complaint now joins the growing dossier of recorded abuses by Westminster staff and officials. It is no longer a local matter. It is a matter of public service accountability.

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⟡ 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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