(2) A 

As many of you may know already the Government have proposed transferring much of the jurisdiction for resolving Park Home Disputes from the Courts to the Residential Property Tribunal Service which it “claims “ will benefit park home residents. PHRAA is apposed to this proposal, at present subject to consultation, for many reasons mainly that as usual there is no means of ENFORCEMENT.

“Department for Communities & Local Government.

Park Homes Policy Team,

1/C3. Eland House,

Bressenden Place, 7^th August 2008.

London.

SW1E 5DU.

Dear Mr. Coram,

In view of the expectation that the Government will adopt Option 2 irrespective, this response will include a number of general observations. It will then focus solely in support of Option 1 and rejection of Option 2. Option 3 is dismissed in its entirety. It is hoped that comparing the real practicalities with Option 2 , might cause those who are promoting Option 2 to reflect upon how in appropriate the RPT will be to Park Home issues.

1.0 Park Home Legal Services Ltd (the “Company“) provides:

(1) Dedicated professional legal services to park home occupiers, park owners

and locde facto voice for the interests of the vast majority of park homeowners

who chose not to join or support any national or local resident’s association.

1.1 The writer is confident the company deals thoroughly with more park home legal issues annually than any other entity or body, legal or voluntary. It is likely it deals with more individual issues than any other body or bodies taken collectively. The company operates a licensed legal helpline at 60 pence per minute (20 pence to the premium rate number provider). This helpline service, which is dedicated to park home and holiday caravan issues, apart from essential costs such as mandatory Professional Indemnity Insurance, is virtually pro bono. The helpline provides callers with practical and technical help and advice.

1.2 The company can confidently state that it sponsors more park home cases to the jurisdiction of the local County Court nationally whether legal or voluntary. It does this with the benefit of a Licensed Access to the Bar, which allows it to promote and manage cases through to the Court of Appeal should that become necessary.

1.3 The Company, through the writer, gives legal advice to hundreds of park home occupiers through the ‘Questions of Law’ pages of the Park Homes & Holiday Caravan magazine every year.

1.4 The writer is a park home owner/occupier since 1986 on a problem site, which has a trade association owner who fragrantly disregards the law.

1.5 With the background described above, it is surprising that this Company has not participated in any preliminary discussions with the Government in relation to this consultation exercise. Had this company been approached for its views earlier, the consultation document might have offered a balanced outline of the main options and what they would mean in practice.

2.0 Park Home issues are rarely clear-cut. Most cases will invariably involve other areas of law, particularly criminal with harassment, fraud, assault, criminal damage and arson. Civil issues such as contract, tort, breach of confidence and other fiduciary issues as well as planning law arise continually. With the knowledge this Government Department possesses in relation to the many instances of outrageous criminal behaviour by numerous park owners some of whom are currently in prison as a result of their behaviour, it is incomprehensible on the facts, that they intend transferring the jurisdiction of the County Court to the Residential Property Tribunal (“RPT“).

2.1 It is noted that the RPT will be virtually duplicating the general jurisdiction of the County Court. How this sits constitutionally is open to question as it would appear that the RPT will act as a de facto County Court but mirroring European models without any power to enforce its decisions. This highlights the discreet but progressive introduction of the European inquisitorial law by the ‘back door’.

2.2 A typical High Street legal practice will normally avoid Park Home Law, as it is perceived as being a ’rabbits warren’ of complexity. As his Honour Judge Colyer QC said of the Mobile Homes Act 1983 ( the “1983 Act“) in the Dartford County Court (Keen v Levi King & Nathan King, “…..I should not like lovingly to depart from the Mobile Homes Act 1983 without commenting that it is a (if not the) most appallingly drafted statute, in my view, on the statute book. It sets out to do a particular job without regard to the ordinary legal concepts of English property law and that creates tremendous confusion and difficulty in working the Act through and seeing how ordinary notions of English law can be related to it”.

Lord Denning held similar views. In the writers view, the new implied terms have done nothing to improve this position.

2.3 The vast majority of residential parks are described as ’retirement parks’. This discrimination invariably results from a provision in the Site4 Rules. ’Retirement parks’ are beneficial to the park owner simply because it is commercially desirable. Elderly people will almost certainly arrive with equity from a house sale, which makes them in effect, cash buyers. As aging members of society, they have a statistically higher probability of becoming ill with a serious illness or they well die whilst occupying the mobile home. Whichever, on each event the prospect of a 10% commission on disposal of the property presents itself, certainly more frequently than it would with younger occupiers and, more importantly , so does the opportunity to deprive the occupier or executor/personal representative of the home for nothing or a derisory sum.

2.4 Existing aged park home occupiers seek a trouble free time of their ’twilight years’. many do not achieve this desirable state on park home sites as a result of the park owners behaviour yet are disinclined to challenge, in so many instances, even criminal behaviour by the park owner. The park owner simply, ‘gets away with it’. The writer does not believe the introduction of the RPT will change this state of affairs. Indeed, the nature of the common unscrupulous park owner’s arrogance makes it almost certain that he/she would not honour any decision mad under the jurisdiction of the RPT. In fact, it is utterly predictable that in the knowledge the RPT had no ‘teeth’ to enforce its decisions it may well be they would not even participate by attending a hearing. It is not explained by what mechanism the occupier can then obtain ’justice’ in these circumstances.

2.5 Do we never learn from mistakes? Park owners have already demonstrated how competently they sidestep legislation designed to keep them in check. We saw OFWAT make the mistake, fortunately in a more modest way, with the Water Resale Order 2001. This Order empowered water consuming park home occupiers, to request the utility reselling park owner provide them with information on how the occupiers water bills were calculated and a copy of the mains suppliers invoice. However, it failed to provide a remedy should the park owner fail to supply the information sought. Park owners simply ignored the occupiers request with impunity. Once OFWAT identified its failure to add a penalty, it acted promptly to provide the occupier with a remedy. The Water Resale Order 2006 now provides an inbuilt penalty exercisable by the aggrieved consumer should the the owner fail to provide or recourse to the Court should that become necessary.

2.6 It is noted no reference is made in the paper to the Single Equality Bill, which will certainly herald the end of the ‘retirement park’ when it becomes law in view of its proposals to eliminate age discrimination in relation to the supply of goods and services. Doubtless, this legislation will force the unscrupulous park owner to become more devious in his efforts to block sales but generally, it must mean a new younger employed park home occupier who will be more inclined to challenge an unscrupulous park owner. This, I predict, will be a shock for those who have hitherto preyed on the retired and ‘vulnerable’. Whether, with an influx of younger buyers, the park home remains attractive to the elderly considering ‘down-sizing’ with the acquisition of a park home wasting asset remains to be seen. Perhaps this Government Department should consider the profound impact of a younger park homeowner on the intention to transfer the role of the County Court to the RPT. It is the writers view that a younger occupier with a dispute will not countenance a tribunal unable to enforce its own decisions and with no statutory recourse to the Court should that become necessary.

2.7 Virtually all major town or city colleges run courses on Landlord and Tenant Law, tuition in the subject is prolific. There is not one established course available covering park home law. The writer is intrigued to know where the RPT members will receive their ‘training’ in park home law and, more so, the need for advanced training for the members of the Lands Tribunal (“LT“) as the appeal authority.

2.8 Arbitration. Of the thousands of Written Statements I have perused, only a handful have contained a clause providing resolution of disputes by way of arbitration. It is simply never an issue. It would be quite deceptive to promote the RPT as a logical next step from arbitration. Indeed, having considered the Lords exchanges in relation to the manoeuvring that took place recently in relation to the ‘Mobile Homes Act; arbitration’ (Lords Hansard text for 23^rd June 2008 (pt0002) the writer’s only question is, “What brought this issue up and importantly, why?”

2.9 Many park owners, including members of the Trade Associations, flaunt the law with impunity in the knowledge that even if an elderly person has the stamina or money to challenge them or their behaviour, they are unlikely to take the issue to Court. They know that the Fraud Act is indeed a ‘fraud’ in itself. The Police are disinclined to enforce either fraud or harassment and the local authority? Well, suffice it to say the writer is aware only of Hooper v Eaglestone [1977] 34 P&CR 311, 76 LGR 308, 245 EG 572 as the only case under S.3 of the Caravan Sites Act 1968 reaching the higher courts since the Act came into force 40 years ago and even then, it had to be the occupier who took the criminal case to the Magistrates Court. I know of not one other instance of local authorities exercising their powers under S.3 of the 1968 Act. Both the Police and local authorities will see every issue that occurs on a residential park as a ‘civil issue’. When the Company has been involved, virtually all cases promoted in the County Court result in the park owner conceding when the hearing becomes a reality and they are faced with a court appearance. Court fees are recovered indeed, where a park owner is forced to withdraw a frivolous claim, the Defendant occupiers legal expenses are routinely recovered.

3.0 The continuing jurisdiction of the Court is of paramount importance to improving the ’lot’ of the park home owner/occupier. During its relatively few years of operation, this Company has promoted use of the County Court to resolve issues on many occasions and it has a rather embarrassing record of success. Indeed, to use the Ministers off-cited expression, the Company’s abilities in this respect are just “bedding in”. The Company is far from reticent in ’taking on’ a number of unscrupulous park owners when the opportunity presents itself. The unscrupulous park owners only understand a judgement against them and the likelihood of a charge on their property or some other financial penalty if they do not settle a claim. Substitute this, as the Government intend, with a decision made by the RPT which cannot be enforced, where there is effectively no penalty and no recourse to the Court to obtain complete satisfaction and you have a recipe for increasing levels of abuse. This is no time to introduce a system which, by its nature, is a ’get together’ of the parties and a discussion of the dispute(s). The reality is that it is an industry riddled with many bad people who have no regard for the occupier or indeed, the law. They are ’street wise’ with terms such conciliation or concession forming no part of their vocabulary.

3.1 It is noted the Government make no mention of the work of the Small Claims Court in comparison to the RPT. This is rather surprising but understandable in view of the imminent introduction of the RPT and no doubt not wishing to be deflected from their chosen ’Option 2’. It is noted the RPT is described as being, ’…informal in nature, with tribunal members taking an active role in the proceedings’. This is a description, mirroring the description of the Small Claims procedure in the County Court when the Judge takes an active part in the proceedings in terms of examining the parties evidence. Fees in the County Court can be waived where the Claimant is on a low income or they may well be entitled to legal aid. In any event , claims to recover money (as happens often where the occupier has been subjected to an unlawful pitch fee increase) are graduate staring at £30 to recover sums up to £300, to a maximum of £108 for sums up to £5,000. Far less than the intended ’one off’ payment of £150 with the RPT. Indeed, if the RPT adopt the Courts role in park home matters how will the occupier recover from the owner when the issue results from a park home dispute? The recovery of money is best suited to the Court system. Claims can be made simply online at far less cost than an application to the toothless RPT. Most claims under the 1983 Act against a park owner or indeed occupier are for sums of money which makes the Small Claims procedure the only practical method or recovery AND importantly, it provides a means where a judgement may be enforced. It is concerning that the Government omit mention of the higher cost of using the RPT compared to the informal Small Claims procedure. Why should this be?

3.2 Very often mobile home owners have claims against the owner which relate to the period between having decided to buy a new park home and taking up residence when and only when the 1983 Act can apply. These, quite rightly, are classed by the occupiers as a ’park home dispute’. Many park owners wrongly claim the 1983 Act applies throughout the process. Will the RPT deal with these purely contractual issues occurring before the buyer takes up occupation and the 1983 Act applies? These are pure contract cases not suited to the RPT. Only a Court could order a Defendant park owner to refund ’deposits’ taken unjustifiably as ’non-refundable’ under the Unfair Terms in Consumer Contracts Regulations 1999 or will the RPT will be taking on this responsibility as well?

3.3 Regularly, issues arise where a park owner decides to expand his site without the benefit of planning permission. ’Creep’. The owner usually tries to legitimise their ’creep’ by acquiring the land they have unlawfully expanded into. Mobile homes so sited are off the ’protected site’ so again, the 1983 Act cannot apply. This Company regularly deal with a number of these issues. One case currently on file involves the owner who has discreetly and over a period of time, crept into adjoining land such that in excess of 20 homes are off the protected site. The issue involves planning law and local authority licensing. Will the RPT dael with these issues? The Court would.

3.4 Subject to the nature of an appeal i.e. decisions concerning points of law, the Court of Appeal is nthe next step from the County Court. The Court of Appeal can and does create precedence. In view of Mr. Iain Wright MP’s assertion that the new impied terms simply need to ’bed in’, which the writer defines asw obtaining precedence through case law, I ask how precedence can be achieved using the RPT or indeed the LT as the appeal route? Does this Government truly believe that the average park home occupier with a dispute, having taken a case through the RPT then move on to the more expensive LT will then consider the expense of the Court of Appeal for a critical judgement? I think not.

3.5 Before moving on to consider the RPT, I mention two current cases this Company is directly dealing with.

Case 1 involves a park owning member of the British Holiday & Home Parks Association ( the BH&HPA) who routinely increases pitch fees substantially to incoming buyers of second-hand mobile homes. The BH&HPA are well aware of this particular abuse by their member but fail to display any inclination to regulate their member. We represent one occupier. We have calculated the overcharges (within limitation) and we now seek an Order from the County Court that the site owner refunds the money taken. We also seek a Declaration from the County Court that it was unlawful on the facts for the owner to have increased the pitch fees in the manner he did. The Declaration will eventually found claims from the other occupiers subjected to the same abuse. If the owner fails to pay, the Court has a number of well established ways of dealing with such people including, as a last resort, charging the property. How would the RPT deal with it? It appears the RPT might order the owner to refund the money but what then should he fail to pay? (and this one arrogantly would). There is no recourse to the Court from the RPT to enforce the judgement. Even if there were, it would then beg the question, ’why use the Rpt in the first place rather than the Court?’

Case 2 involves a park owning client who has followed the law and served the correct notice on the occupiers in relation to this years RPI increase. Three fifths of the occupiers led by a persuasive troublemaker have refused to pay the RPI , claiming (very wrongly as it happens) the ’amenity’ of the park has deteriorated. We present a claim to the County Court to recover the payments from the trouble making Secretary of the Qualifying Residents Association (“QRA”) by way of a Court order AND a Declaration that the amenity of the park has not deteriorated. This will require the Court to decide upon the issue of ’amenity’ and set some parameters (’bedding in’?) Once the Declaration has been obtained, it will be a foolish occupier who then fails to pay the increase. As the new implied terms make clear, it is ONLY the individual occupier who can agree a pitch fee increase NOT a QRA or any officer of that association. Again, the RPT would have to deal with all the defaulting occupiers on the basis, presumably if the legislation permit’s a consolidated action. Using the schedule on pages 32 and 33 of the Paper, the alternative:

Let us take the worst case scenario for the Court alternative. Let us hypothetically say we have obtained our Order against the Secretary and our Declaration for the site as a whole. In the very unlikely event the remaining 40 occupiers continue to refuse to accept the £5 per month increase what do we do? The owner can only prepare each case individually and obtains Orders and costs which. In our example, would mean the owner recovers from the 40 occupiers, 40 x £150 (Court fee) = £6,000 ( assuming no lawyer’s costs to recover). It may be disproportionate but it would be a rather costly exercise for the occupiers to maintain their position in the face of a Court Declaration not in their favour.

Again, taking the worst case scenario with the RPT alternative if the remaining 40 refuse, how will our owner obtain his lawful pitch fee increase? Where will he obtain his enforcement? Where is the answer to this question?

It is noted that the ’Small Firms Impact Test, page 60 states that use of the RPT, “….will save business money in terms of legal and other costs”. The current example above suggests otherwise. A number of other examples should be made and they should include speculation on the cost of an appeal to the LT.

The County Court can dael with complex legal issues involving all the relevant areas of law in one hearing.

A Judge is legally qualified to a high level and their experience and knowledge will be broad based; it is cheap if the Small Claims system is used.

As the practical example shows in paragraph 3.5, it is cost effective when dealing with a number of residents on the same protected site;

It can make Declarations;

It can award damages;

It can importantly deal with tortuous interference issues;

It can enforce its own decisions;

It can order a charge be put on a persons real property;

In this Company’s experience it is quick enough (as part 8 claim) certainly compared with the period given for RPT in Annex D of the Paper i.e. “cases normally take about three months to process from application to decision”. [ The target mean is 12.75 weeks - page 12 RPT Annual Report 07/08]

4.0 The fatal flaw (“the fatal flaw”) with intended use of the RPT is enforcement. It is the writer’s view that the Government has seriously underestimated the cunning of the bad owner with an almost reckless naivety. Using the RPT to deal with park home issues is, in effect, an unscrupulous park owners charter to do their worst with even more impunity than they have at present, which leaves one uncomfortably feeling the Government has paid no attention to the vast number of examples of bad park owners behaviour they have been continually provided with. These people will resort to anything to feed their greed; They lie with ease; They are prepared to defraud occupiers, the social security system as well as grieving relatives. They regularly break the criminal law but only infrequently suffer the consequences. The litany of abuse is endless.

4.1 It is asserted that “ RTP’s are low cost tribunals and do not award costs against a losing party”. The examples above makes a nonsense of the ’low cost’ assertion and that it is “….significantly less than going to Court”. Use of the Small Claims procedure with a professional Judge will be significantly less. No prudent person would simply apply to the Court or, as intended, the RPT without first establishing whether they had a case and the case was prepared properly and thoroughly. It is deceptive to suggest that either party using the Rpt will be, ’lawyer (and therefore cost free)’.

4.2 Contrary to the Governments assertion that they believe there will not be a “significant number of appeals”, the writer believes there will be many and indeed many frustrated parties who were intent upon recovering money but have realised through the process that the RPT could not help them. Misguidedly, they will assume that the LT will be able to help them recover overpayments and/or other money owed. Clearly, use of the RPT will need issue of a clear and unambiguous ’ Health Warning’ as to what it can or cannot do and the Health Warning must advise where the Claimant can obtain the satisfaction he/she seeks in relation to his/her particular case. The writer observes that can only be the County Court provided the Government do not, under the Act, sever that recourse.

4.3 Under the savings’ heading, page 54 of the Paper, it is stated that there will be savings, ’….to both the site owners and residents in terms of legal costs’. The writer disputes this. Indeed, the writer submits that nothing will change and that the participants will continue to engage lawyers but now, with no hope of recovering costs.

4.4 What is not clear is how many members of the RPT will sit on the tribunal. Page 41 of the Paper explains that, “Normally a tribunal will consist of three members. The chair is usually the legally qualified member. “Usually” What weasel word is this? The passage continues, “….he or she sits with a professional member normally a qualified surveyor or environmental officer and in most cases a lay member, with specialist knowledge of the subject or of the local areas”. Futher down page 41 the Paper conflictingly advises the reader, “Normally one member of the tribunal sits to hear the case….” Which is it one member or three? I emphasised, “usually” above in the first cited passage because if there is no legally qualified member sitting and/or, ’Normally one member ….sits’ then what quality of decision making can the Claimant expect? Could it be that a completely unqualified person (perhaps the ‘lay member‘) makes decisions? This could lead to the bizarre situation where either the Claimant or Defendant (or both) is represented by a professionally qualified legal person yet a decision is reached by a legally unqualified ’member’ of the RPT. It is noted in the RPT’s Annual Report that they are, “making greater use of two members rather than three….in appropriate cases”. Perhaps the use of one member is planned to apply to park home issues as, ’appropriate cases?

4.5 The writer is glad to note that the comments made by the Lords (Lords Hansard text for 23^rd June 2008 (pt 0006) in relation to the RPT will be ’…..fed into the consultation’. I summarise those views:

* Parties can and no doubt will, be represented by legally qualified people;

*Legal Aid is not available;

*Tribunals can be very drawn out;

*The experience and the briskness of a Judge have considerable advantages;

*The DCLG is wrong to claim that RPT’s are more informal than Courts;

*Tenants, ’….in similar circumstances should be able to take the matter to Court, whereas mobile home site residents, would be precluded from that opportunity.

* In theory, tribunals are an economical and accessible form of justice.

4.6 It is noted that the Paper is virtually silent about where the occupier obtains their advice prior to submitting a claim. It is also noted on the RPT’s website that the staff cannot give advice.

4.7 It is noted in the ’Foreword’ to the RPT’s Annual Report 07/08 that the 2004 Housing Act workload is, “….still below the levels originally predicted for it” (Siobhan McGrath). It is hoped the intended and (in the writers view) disastrous shift of park home disputes from the County Court jurisdiction to the RPT is not founded upon the need to bolster the RPT’s shortage of work simply to justify its existence.

4.8 The Housing Ombusman who believed they had a legislative remit to hear park home disputes dealt with, ’one or two cases a year’ (statement by Mr. Rafael Runco, Deputy Ombudsman to the writer).

5.0 “If it aint broke, don’t fix it”.

5.1 Previous efforts by this Government to eradicate the bad park owner have failed miserably. They are still out there practicing teir abuse on a daily basis unfettered by the 1983 Act and certainly unscathed by its ’new’ implied terms. They continue unaffected by the amended 1968 caravan Sites act thanks purely to local authority intransigence. The writer observes that use of the RPT will simply enhance the bad park owners behaviour. It needs a ’stick’ not cosy unenforceable ’negotiation’ to deal with the kind of behaviour this Company deals with on a daily basis.

5.1 One hopes all of the foregoing will demonstrate tha, contrary to the Governments assertion in the Paper, (Introduction, final paragraph) use of the RPT will not create, ’….a level playing field between residents and site owners in resolving disputes”. Indeed, the writer suggests that the fatal flaw will simply create occupier (not to mention MP) frustration and further demands that ’justice’ is obtained by other means.

5.2 What is of greater importance in dealing with park home issues over transferring the County Courts jurisdiction to the RPT is amending legislation, which will force local authorities to act within the law they already possess. This equally applies to the Police.

5.3 To achieve the goal of a ’level playing field’ and to obtain justice, legislatively enhance the remit of the Small Claims Court.

Yours Sincerely

Graham Watts LL.B (Hons) LL.M

For Park Home Legal Services.

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PHRAA’s Comments.

COCK UP TO COVER UP COCK UP ??????

First I must thank Mr. Watts (Park Home Legal Services Ltd ) once again for kindly permitting PHRAA to reproduce the above excellent Paper submitted to Government as his expert Legal response to the Government Consultation Document issued recently inviting comments on the Governments proposal (or I should say intention) to transfer the jurisdiction of park home law from the County Courts to a Residential Property Tribunal next year.

On receiving a copy of this excellent Paper from Mr. Watts and carefully studying its contents we at PHRAA felt it was vital that instead of just going to Government, never to be seen again, this Paper should be placed on the PHRAA website, which averages 100 hits per day, where it would be available to as many Park Homeowners and others as possible. It is also available on the Park Home Legal Services Ltd Website www. phls.net. Which if you need Expert Legal Advice and Help on your park home or holiday caravan problems is well worth a visit.

It is to be hoped, (but don’t hold your breath) that this above Paper is seriously considered by Government when deciding whether or not to introduce this latest ill-conceived legislation described (rightly in PHRAA’s view) by Mr. Watts in paragraph 4.0 as “… an unscrupulous park owners charter to do their worst with even more impunity”, but if previous experience is anything to go by, this Paper is now languishing in the Department for Communities & Local Governments waste bin along with all other park home residents, local and national residents associations responses except those responses favourable to the proposal, submitted by the industry’s Trade Associations and Park Owners and their industry biased Legal Teams. No doubt Mr. Watts’s Paper is now sharing the same Department or Ministers waste bin as the Petition calling for changes in park home law, produced and distributed nationwide by PHRAA late in 2007 and containing over 1100 signatures presented by myself to Lord Graham of Edmonton, (Secretary of the All Party Working Group for the Welfare of Park Homeowners at a meeting of the group early in 2008 (note the title of the group) who in turn kindly passed it on to the Minister Mr. Iain Wright MP. PHRAA did receive an acknowledgement of receipt from Lord Graham, but to date, many months later, no such courtesy has been received from either the Minister or any other officer of that Department.

Unfortunately for the long suffering park homeowners, this Government has a record of obviously dismissing or failing to take into account the copious amount of evidence submitted by park home residents, local and national park home residents associations and THE LEGAL EXPERT (Graham Watts) into consideration during the various consultation periods preceding the introduction of other equally ill-conceived park home legislation such as the 2006 implied terms, one clause of which took away the right of wives or partners to a vote on matters directly affecting their lives and homes, followed by the fiasco of the retention of the 10% commission payment on home sales. It appears, (in PHRAA’s view) that the Governments attitude towards the elderly and vulnerable park home owner is, “put up and shut up” or similar to that of the stern Victorian fathers attitude towards his children in that “they should be seen and not heard” and, in common with unscrupulous park owners, “do as they are told without question at all times”.

One thing is certain whilst this Government continue to encourage the aspirations of the unscrupulous park owners and totally ignoring, in spite of the overwhelming evidence, the ever worsening plight of the helpless and vulnerable park home owners, they are not only condoning, but encouraging ABUSE OF THE ELDERLY.

Please let PHRAA know of your experiences. All information treated in strict confidence.

Ron. General Secretary PHRAA.

Contact Details for Graham Watts LL.B (Hons) LL.M.

Park Home Legal Services Ltd.

Registered Office, Station House,

Station Road,

Pill,

North Somerset.

BS20 0AB.

Tel. 01275 373762.

Fax. 01275 371789

Email. This e-mail address is being protected from spam bots, you need JavaScript enabled to view it

Website. www. Phls.net.