[2024] UKUT 126 (AAC)

[L] had returned from a cinema trip with staff at 20.05. [L] sat in the office with staff chatting about the film he had been to see. [L] was then offered his medication which was administered by AD and PR. DJ went into the kitchen to microwave her dinner and went into the dining room. At 20.24 staff received a call to pick up another young person so PR left in the pool car. [L] was now sitting in the reception area with staff [the appellant] (Agency staff) watching videos on his phone.

BEHAVIOUR:

AD was in the office stock checking the medication and heard shouting from the reception area from [L] and [the appellant] (Agency staff). AD went immediately out into the reception area. [L] was standing near the front window of the reception area near the radiator and [the appellant] was standing in front of [L]. AD saw [the appellant] swinging her arms in an over arm motion in the direction of [L] connecting with his body (chest and shoulders)

DJ hearing the shouting immediately came out of the dining room and straight into the reception asking what was going on, unaware that PR had left the building to pick up young person SG.

[L] was shouting at the top of his voice and was standing in front of the chair near the radiator by the snug window, his t shirt soaking wet. [L] was raging, puffing up his chest and clenching his fists calling [the appellant] a fucking cunt and black bitch. [The appellant] was standing not too far away from [L]. [L]’s drinks bottle was lying empty on the carpet by [L]’s feet.

AD was trying to calm [L] down. DJ stood between [L] and [the appellant] asking [L] to calm down and tell her what was wrong. [L] said “that fat bitch has thrown water all over me and I’m going to punch her right in her fucking face the bastard” [L] was trying to get to [the appellant] by trying to barge past DJ, his fists were clenched and face was red with rage. AD and DJ asked [L] several times to calm down but he continued to try and get to [the appellant].

[The appellant] stood behind DJ, she said something that DJ couldn’t quite make out but AD heard [the appellant] say “if he hits me I’ll hit him back I’m not scared of him” AD guided [L] away with a half shield to his room. DJ followed and asked [L] again to calm down. He immediately went back into reception, calling [the appellant] a Black Cunt and that he was going to punch her.

[L] opened the front door and started to walk up the drive. AD offered to go for a walk with [L] to help him calm down which he refused and also refused the offer of a dry t shirt instead taking off his soaking wet one throwing it on the floor.

[L] started pacing around the drive. [L] picked something up, like a small stone, off the drive and threw it through the open door where [the appellant] was standing. [The appellant] then closed the front door and sat on the sofa in the reception area.

[L] then started to kick the front door continuing to threaten and swear at [the appellant] calling her a fucking fat black bitch and black cunt who he was going to “get” He asked if the car in the drive was [the appellant’s] as he was going to destroy it. DJ told [L] no it was hers.

[L] went to the side window and was punching it with some force. He then made a racial slur towards [the appellant] calling her a Fucking Nigger. DJ told [L] to stop it as he could be arrested by saying the N word. [L] said he didn’t care. DJ asked AD to ask [the appellant] to leave as it wasn’t helping that [the appellant] was sitting by the window in reception just staring out at us whilst we were trying to deal with [L].

AD went into the house and asked [the appellant] to go into the sleeping in room with a pad and pen and write down what had happened. DJ stayed outside with [L] who then facetimed his mum on his mobile. [L] told his mum that a member of staff had hit him and that he could call the police and get her sacked.

[L] then pointed to the upper left side of his chest area. He ended the call and was starting to calm down. DJ asked [L] what happened, he said that he had some water in his mouth and laughed so it came spurting out in the direction of [the appellant]. [L] also stated that [the appellant] had pushed him into the radiator.

Approx. 20.40 Staff PR arrived back in the pool car with young person SG and AD came back out to the front of the drive. [L] asked if he could go into the back garden to kick a ball about. AD went through the house and opened the back gate. [L], SG and PR went into the back garden.

DJ then rang BD (the on call manager) at 20.43 to inform him of the situation. BD said he would come straight in. After several minutes [L] came back in the house, he was offered medical attention for his hand in case he had injured it by punching the windows. He declined and turned to go to his room DJ noticed a mark on his back.

DJ along with AD went to [L]’s] room and asked they [sic] could check him over. There was a strange semi-circular mark just below his left shoulder blade area and a red scratch mark on his left upper arm area. [L] said that there was a mark on the front upper left chest area but staff couldn’t see it. DJ asked [L] if he would give permission to take photos of the marks and he agreed.

CONSEQUENCES:

[L] then got his drinks bottle, sat in reception with DJ. [L] asked where [the appellant] was. DJ told [L] that she had gone home and that the on call BD was on his way in and [L] could explain to BD what had happened and if he wanted make [sic] a complaint.

[L] said that he hadn’t seen [the appellant] leave, DJ replied it was when [L] was in the garden. [L] was calm at this point took his refilled drinks bottle and went to his room. BD arrived at approx. 21.20 He checked on [L] and was given a full account of what happened by AD and DJ.

BD then went into the sleeping in room where [the appellant] was and asked her for her account of what had happened. AD rang [L]’s mum to inform her of what had occurred and injuries noted.

At approx. 21.50 [the appellant] walked up to the top of the drive waiting for a lift home DJ stood at the top of the drive with her until her lift arrived.

Highlight any significant comments made during the Incident:

[The appellant] was heard saying “if he hits me I’ll hit him back I’m not scared of him”

[L] told DJ [the appellant] had pushed him into the radiator.

[L] told AD that [the appellant] had thrown his water bottle at him.”.

“Designated Officer (formerly LADO) referral form for Professionals”

ASSAULT

[…]

Pre interview risk assessment 26 August 2020

1/D [redacted]

on that day, on shift with 3 x staff.

Shift end 3pm. Asked to work later agreed.

Child taken to McDonalds.

Splashing water from mouth water bottle on my body.

Told him to move away from me.

He went outside. I let him back in.

Seeking attention.

Spraying me from water bottle. I took bottle of him.

He punched me in chest, kicking. Staff restrained.

‘called black goat / bitch’

He went to his room. Manager asked me what happened.

I stayed in office until end of shift.

He assaulted me. Never touched him. Know his behaviour. Wouldn’t want to hurt him – repercussions, wouldn’t ruin my career. Just wanted to support him.

Q Holding bottle?

With two hands. So I took it, one hand. He punched me in the chest.

I screamed. Staff came to me.

Q Swinging your arms?

cant remember. Deny.

He was trying to fight me – kicked + punched. Staff inbetween us.

Q Assault child?

No he assaulted me.

Q Manager report – hit him?

Deny. Didnt say that.

Q Write statement?

Yes before I left that day sent to agency also.

Q copy?

No.

Child injury marks.

Deny causing injury. Dont know how caused. Never touched child.

Q Want to pursue complaint?

No, he’s vulnerable lad, special as in care.

Worked 5 – 7 shifts with child. Worked there before he arrived. I helped arrange his toys

He doesn’t have a relationship with anyone. We take him out to make him happy. Engage in activities.

2:1 care.

At time just me + him in living area.

Q Why child make allegation?

Only black girl – ‘fuck off black bitch.’

He’s a special kid, he vulnerable.

Colleagues make me feel very welcome. Don’t take personally.

Post interview assessment

Feel very sad. Child just a vulnerable child. Never done anything wrong. Why like that towards me.

Worried – Police come to office – he assaulted me.

Wanted to be social worker.”.

Record of LADO JEM meeting which took place 3 March 2021

A member of staff at [the home] [AD] has reported that, whilst in the office stock checking, she heard shouting in the reception area from (young person) and [the appellant] (Agency Support Worker). [AD] immediately went to the reception area and found [the appellant] swinging her arms in the direction of CHILD and connecting with his upper body, chest and shoulders. This lasted a few seconds. [AD] stood in-between [the appellant] and CHILD

[The appellant] appeared angry by her facial expression and said: “If he hits me, I’ll hit him back. I’m not scared of him”. CHILD was backing away and shouting: “You fucking bitch. You hit me”. When asked what was going on, CHILD said that [the appellant] had soaked him and [the appellant] shouted that CHILD had wet her clothes.

CHILD was raging with clenched fists and was red in the face. He made verbal and physical threats to [the appellant] saying: “I’m going to punch you in the face. I’m going to hit you like you hit me. Look what you have done to me you fucking bitch”. CHILD asked [AD] to let him past so he could punch [the appellant], then said: “If you don’t let me past, I will punch you in the face as well”. CHILD was removed from the area by [AD] to his bedroom and she asked him to calm down. CHILD then immediately went back into the reception area issuing threats again towards [the appellant]. He then opened the front door, followed by [AD] and another staff member, and started to walk up the drive. [AD] offered to go for a walk with CHILD to help him calm down, but CHILD refused, pacing around the drive. CHILD picked something up off the drive and threw it through the open door where [the appellant] was standing. [AD] then closed the door. CHILD started to kick the front door issuing threats to [the appellant] then went to the side window punching it several times and calling her a “fat black bitch” and “black cunt”.

CHILD then started using a racial slur towards [the appellant] (Nigger). Staff told CHILD he could be arrested for using the N word.

CHILD then took off his t-shirt which was soaking and threw it on the ground. He asked if the car in the drive was [the appellant’s] as he was going to destroy it. He was told that it wasn’t. Both [AD] and the other staff member were trying to diffuse [sic] the situation and [the appellant] was asked to go into the sleeping in room with a pad and pen and write down what had happened.

CHILD then face timed his mum saying a staff member had hit him and he could call the police and get her sacked. CHILD then showed his mum his left upper chest area. CHILD then calmed down and asked to go into the back garden to kick a football about.

Meeting Discussion:

Background Information:

[The appellant] is an agency worker for [the employment agency]. Whilst working at [redacted] she got into a fracas with young person, which led to shoving and physical handling. It is alleged that during this, [the appellant] forcibly struck CHILD in the chest and some injuries to prove this were noticed afterwards.

[The appellant] is no longer working for NCC and has been suspended from [the employment agency] whilst investigations take place. A representative from [the employment agency] was unable to attend today’s meeting and they will be fed back to following today’s meeting.

Information from [the home]:

[TM] (Team Manager) relayed that [the appellant] has passed all NCC recruitment criteria and has a clear DBS. With regards to her employment history, she was an office worker between 2015 and 2019, before becoming a support worker in March 2020. She joined [the employment agency] in July 2020 and approached the agency for help due to having shortages in the team. The incident in question took place on 26th August 2020 and there have been no other concerns with [the appellant’s] practice aside from this.

The report from the member of staff who witnessed the incident is that they saw [the appellant] swing her arms and connect with CHILD chest area so they intervened. When questioned, [the appellant] admitted to hitting him and said she did this as he spat water at her. With regards to injuries, [L] had red marks on his upper body and chest. [TM] confirmed that it was not done as part of a restraint.

CHILD is a difficult young person with lots of behavioural concerns. He was originally placed at [redacted] for five days as a stepping stone placement, but remained there for thirty-nine days as his new placement fell through. He left on 18th September 2020. CHILD presents lots of verbal and physical aggression and causes damage to property. He has been diagnosed with ADHD, ASD and Oppositional Defiance [sic] Disorder. With regards to managing behaviour, staff would usually look to verbally deescalate [sic] if possible. [TM] stated that, from looking at the report of the incident, if CHILD was spitting water, there would’ve been plenty of opportunities for [the appellant] to remove herself from the situation and seek additional support from staff, which would’ve been the expectation. If staff are concerned about safety, they can use physical intervention, but [the appellant] did not attempt to do this in this situation, nor was it deemed necessary. As such, even if [the appellant] has not committed a criminal offence, it is poor practice. It is also concerning that, when questioned, [the appellant] said: “I hit him because he spat water at me”.

[The appellant] has not received Team Teach training, but all agency staff are requested to have undertaken some form of restraint training.

Information from Police:

DC Annmarie Brown confirmed that CHILD had red marks on his chest area and his back which were indicative of a struggle. It is difficult to say if they were caused by him being struck, but it is clear that some sort of struggle / fight had taken place. A member of staff had said that they intervened when they heard the struggle taking place and stood between [the appellant] and CHILD, although Police have not been able to get a statement.

[…]

Outcome Discussion:

The DO outlined that the Police investigation and [the appellant]’s statement is clear that there has been an incident during which [the appellant] struck out at [L] causing injuries.”.

Referral form by TW of the appellant’s employment agency

RE: [appellant’s name, date of birth and address]

Specific Offences:

I write to you in acknowledgement of your letter for further information dated 28^th June 2021 regarding the above named individual.

On 26^th August 2020, [the appellant] was working as a Carer at a children’s home. [The appellant] was in a communal area with a 12 year old male child. The child stated he had been drinking some water and [the appellant] made him laugh which caused the water to squirt out of his mouth and resulted in [the appellant] getting wet.

The child stated [the appellant] began to slap him numerous times causing slight redness to the skin. When officers arrived, there was no sign of any injuries.

The child also stated [the appellant] pushed him into a radiator and threw the child’s water bottle at him.

Another Carer heard the commotion from the room where she was working and say [sic] [the appellant] hitting the child. The Carer intervened in the altercation and escorted the child to his room.

She told [the appellant] to write her account of what had occurred. [The appellant] stated that the child spat water at her and when challenged on his behaviour, he began punching her to the stomach. She wrote that she defended herself and swung at the child.

The Carer stated [the appellant] appeared angry and said “if he hit’s [sic] me, I’ll hit him back, I am not scared of him”. The child was backing away and shouting “you f***ing bitch, you hit me”. The child shouted [the appellant] had soaked him and [the appellant] shouted that the child had wet her clothes.

The child was described as raging with clenched fists and a red face making verbal and physical threats to [the appellant]. He made various racial slurs to [the appellant].

When a Senior Staff member arrived at the home after being called in to help deal with the incident [the appellant] stated “I hit him, he was spitting water at me”. After [the appellant] had given a written account, she asked to be able to continue her shift but was told she needed to leave.

The child stated he didn’t want to go to Court and was happy for staff at the children’s home to deal with the matter internally.

The other staff member [this appears to be DJ] who intervened in the altercation did not want to provide a statement to police or attend Court.

However, whilst it was noted the children’s home would investigate the matter internally, the police concluded due to the nature of the incident that there was a duty of care to the child for the matter to be investigated by officers.

A LADO (Local Authority Designated Officer) referral was made on the 9^th September 2020.

[The appellant] was voluntary [sic] interviewed on the 7^th December 2020. She stated she along with other staff members had taken the child to McDonalds and on returning the child had started to splash her with a water bottle to her body area. She asked him to move away so he went outside then she let him back in. She stated the child often sought attention and sprayed her with water so she took the bottle off of [sic] him. As she did so, he punched her to the chest and called her a racist name.

She stated the child was punching and kicking out at her and that other staff had stood in between them. She stated the child assaulted her but she never touched him. [The appellant] stated she was fully aware of his behaviour and wouldn’t hurt him or ruin her career as she just wanted to support him.

She described the child holding the bottle with two hands and as she removed it with one of her hands, he punched her, she screamed and that was when staff came to assist. When asked by the interviewing officer if she had swung her arms she stated she couldn’t remember but said he was trying to fight her.

[The appellant] denied assaulting the child. The interviewing officer asked her if she had made the comment to the children’s home manager that “I hit him, he was spitting water at me”. She stated she had written a statement before she left the home and one for the agency she worked through. She had not been given a copy of the first account she had provided at the children’s home.

When [the appellant] was shown photograph’s [sic] of the child’s injuries, she stated she did not know how these were caused as she did not touch him.

[The appellant] was asked if she wanted to make a complaint against the child but she stated no as he was a vulnerable [sic] and special as he was in care. She had worked with him previously. She stated he did not have any relationships with anyone so staff would take him out to make him happy and engage him in activities. He was normally 2-1 staff but when this incident occurred, there was [sic] only [the appellant] and the child present. She stated she was the only black member of staff and he would often tell to [sic] “f*** off black bitch”. She stated she would never take this personally.

In February 2021, the child again confirmed he did not wish to pursue this matter. He stated he had “forgotten” about the incident. His mother was also in agreement with this decision.

A Joint Evaluation Meeting was held on the 3^rd March 2021. The meeting concluded the incident was substantiated. Full details can be obtained via LADO. The email address is [email protected]

As the child and his mother were not interested in supporting a prosecution and [the appellant] denied the allegations, no further action was taken by police. It was felt it would be difficult to evidence that there was an intentional assault on the child by [the appellant]. The other Carer who intervened had also refused to make a statement and despite being contacted several times by officers, had not made contact.

No formal statements were taken but I have attached a copy of the Tape Recorded Interview of [the appellant].

This information has been shared for Barring purposes only and not for any other purpose. Any need for sharing with the ‘Referred Individual’ should be compliant with the Data Protection Act 2018. Some shared Police information may have been deemed as relevant for risk considerations for Barring, however [sic] is not something we would consider sharing with the ‘Referred Individual’. If sharing is deemed necessary the risk assessment you make before sharing, should take into account that including all the detail may identify the source and place them at risk.

Any other Relevant Information

Not applicable at this time.

If you have any further questions, please do not hesitate to contact me on the above number provided.

Yours sincerely

[Redacted]

Disclosure and Barring Service Quality Assurance Officer”.

Letter from the appellant’s solicitors

Re: Our client, [the appellant] – D.O.B. […]

We have been instructed by our aforementioned client in connection with your letter dated 8^th February 2022.

Our client has instructed us to put forward representations, that she is not barred from working with children and / or adults.

We were instructed by [the appellant] in connection with a voluntary police interview at Northampton Police Station on 7^th December 2020. Disclosure had been provided by the Officer in the case, relating to the alleged victim, [L], who was a resident at [the home] in […].

In connection with the allegation, our client instructed us that she had worked at the above children’s home for at least two months on a part-time basis, this was prior to the incident on 26^th August 2020. She instructed us that [L] had been looked after by our client in the past, in her role as a Support Worker. She explained that he was a troubled child with many issues, and on most occasions it was necessary to keep him engaged.

On 26^th August 2020, [L] had returned with other members of staff at [the home] from McDonalds. Our client was in the reception area when she was seen by the young male, who was also in the reception area. Upon seeing our client, he began to spit water from his mouth in our client’s direction, causing the water to connect with her jumper, and thereby wetting that jumper. He continued to do this despite our client telling him to stop.

Our client believed that he was doing this in order to attract her attention. He proceeded to refill the bottle he had been drinking from and then squirted water from the said bottle at our client. At this point, our client took the bottle from him, making sure she did not make contact with any part of his body. As soon as she did this the young male punched our client in the chest area, causing the bottle to fall to the ground. Our client screamed out in pain, it was at this point that another member of staff, [AD], came to the scene.

Despite [AD]’s presence, the young male continued to act aggressively towards our client, trying to kick at her and flailing his arms about, making contact with her. This was despite [AD] being present.

Our client was asked by [AD] to leave the reception area and to wait in the staff room, but our client could still hear the young male shouting that he was going to kill her. Throughout this incident, our client vividly recalls the male shouting racist abuse at her, using deplorable and criminal language, namely “black bitch”, “black monkey”, “black cunt”.

Despite his racist language, at no stage did our client rise to that provocation.

Our client never admitted that she had assaulted the young male. [AD] claims that she witnessed our client ‘flailing her arms’ about making contact with the young male’s chest area, we would like to stress that she was not present during the start of the incident. This is noted in the incident 194 report, entitled “Debrief Meeting”.

In the debrief meeting, it was noted by Mr [TM] as follows:-

In that report, he ([TM]) goes on to state “I cannot ignore that an agency staff member was alone at the time the incident occurred… this is something that could be highlighted”.

In our assessment, this is a clear admission by the care home that their procedures were defective and the care towards agency staff was not given any consideration.

[AD] was not in a position to comment as to how or what occurred at the start of the incident. It was our client who was the victim of a sustained assault against her. Any “flailing of arms” by our client was in complete self-defence, which was explained in her interview conducted under caution on 7^th December 2020.

We are extremely concerned to note, from the paperwork that has been supplied to us by our client (which was attached to your letter to her), the distressing events that unfolded on 26^th August 2020. We refer to the fact that our client was being physically assaulted, threatened with violence, threatened that her private property would be destroyed, and racially abused. No attempts were made by the care home to report the criminal behaviour of [L] to the Police. The care home’s response was woefully inadequate.

Words such as “fucking nigger” were used by [L] in presence [sic] of other staff members, and although staff members told [L] that this was criminal behaviour, no actual steps were taken to report him to the Police. Whilst we appreciate that [L] is a young person, this would not have barred him from having been reported to the Police or for the Police taking criminal action against him for his racist, violent and threatening behaviour.

We further note that, not only was [L’s] behaviour out of control towards our client, but also violence was threatened against [DJ], he said “If you don’t let me pass, I will punch you in the face as well”.

Our client instructs us that whilst she was standing in the doorway, [L] picked up a stone and threw it in her direction. Had our client not moved out of the way, that stone would have struck her. Again, there appears to have been inaction by the care home towards [L], despite his further acts of violence towards our client.

It goes without saying that our client does not accept that she admitted to any member of staff that she would “hit the boy if he hit her”, and that “she was not scared of him”. These words were never said by our client, in fact our client was scared and frightened by the boy’s violent and uncontrolled behaviour.

We are concerned to note that although our client was asked to write down an account of what had happened, she was never shown nor given a copy of that account, despite requesting it on many occasions.

If her written account is available, we would like to see this. If it is not, we would like to know why not?

We are also concerned to note that at no stage was our client provided with any written and signed statements of any witnesses, including the alleged victim in this case.

It is disappointing to note that this incident took place in an area where there was no CCTV. Had there been CCTV, our client’s account would have been further corroborated.

We would like to refer you to the copy of the Serious Incident Report, which specifically refers to [L’s] behaviour, in that he was “in a heightened state, physically and verbally threatening, and that staff felt he needed to be removed from the area for his and the staff’ safety”. The same report confirms his use of sexist and racist language, that he was intimidating, both physically and verbally, and that he had threatened to damage property not belonging to him.

We have considered the JEM notes, following that meeting, it clearly states that “If staff are concerned about safety, they can use physical intervention, but [the appellant] did not attempt to do this in this situation, nor was it deemed necessary”. The meeting makes it plainly clear that in a situation where staff were concerned about their safety that they could have deployed physical intervention, although this option was available to our client, our client did not at any stage attempt to do this, other than to defend herself, despite the fact that our client found herself in an extremely challenging situation.

We are concerned to note that [the home] did not make any effort to train our client or to explain any restraint skills, and would ask why no training was given to her. There is clear reference to the fact that Team Teach was something that our client was not trained in. The JEM meeting goes on to state that “If she had attempted a restrain, she was not equipped to be able to do so”.

In connection with the alleged injuries to [L], it is far from clear as to how those injuries were caused. We note that this alleged victim suffered with ADHD, ASD and Oppositional Defiance [sic] Disorder. Any injuries caused to him were not as a result of anything that our client did.

In respect to the comments made by [BD] that our client “openly admitted to hitting L”, as indicated above our client completely refutes that at any stage she admitted hitting [L]. The so called admission, does not appear to have been recorded in any way, such as through any mobile phone video footage or on CCTV.

A disciplinary meeting took place in our client’s absence, it concluded that “disproportionate force on a young person causing injury could have been handled much better”. We reiterate that the start of the incident was not witnessed by any other person, and the behaviour of the young male speaks for itself. This is a situation, as we have already mentioned, where our client was in fact the victim.

In respect to comments that our client “showed no empathy”, and that she “did not realise the gravity of the situation”, we do not accept this assertion. Our client was in a state of shock following the racial and physical abuse perpetrated against her, and threats of violence to her and to her property.

During the course of our client’s Police interview, she provided a full and candid account. At no stage did she hide behind any “no comment” answers, despite her right to silence. Further, she did not rely upon any prepared statement. During the course of that interview, our client was extremely distraught and at the end of the interview a welfare check was conducted in respect to her.

You are aware that the conclusion of the Police investigation was no further action against our client. This must not be conflated with the fact that the young male failed to make an official complaint against our client. The Police have every power to pursue a criminal prosecution whether or not an alleged victim supports Police action. The Police are entitled to pursue a “victimless prosecution”, and very often this is exactly what they do. The Police would have been acutely aware of the fact that the young person in this case was a vulnerable male in a care home, and therefore with or without his or his parent / guardian’s consent, the Police could have pursued a criminal prosecution against our client. They did not do so, because there was no evidence in order to do so.

There is reference in the paperwork provided to another carer who apparently “intervened”, but that this carer refused to make a statement to the Police, despite the Police attempting to contact the person on several occasions. Had our client been in the wrong, we have no doubt whatsoever that this person would have made a statement against our client.

Our client is a lady who arrived from Nigeria in 2019. She completed her Master’s degree in Project Management and is a woman of good character, both in this country and in Nigeria. Our client being barred from working with children or young persons or young adults will have an adverse impact upon her livelihood, her reputation, and we would respectfully argue that it would be in breach of her human rights.

To bar her would be utterly unjustifiable.

You have now been presented with the full facts in this case, and we have no doubt whatsoever that having considered our representations, you will agree that our client should not be barred.

We enclose a signed form of authority enabling us to make the representations on our client’s behalf, and look forward to hearing from you as a matter of urgency, because this incident has been extremely shocking and upsetting to our client. It is compounded by the fact that our client is unable at the moment to pursue work that she enjoys and, despite what has been said about her, is efficient and skilled at.

Yours faithfully,

Pickup & Scott Solicitors”.

Barring Decision Summary

[Agency’s name] have verified successful completion of the following courses directly from the training provider or have seen the original certificates relating to:

Printed training materials handed in by the appellant at the hearing