Go back to case study – M40 J1 – the Denham roundabout (2012)
Legal Team Office
Wycombe & Beaconsfield Magistrates Court
Easton St
High Wycombe
Bucks
HP11 1LR
20st March 2012
Dear Sir or Madam,
Complaint for a Litter Abatement Order against the Secretary of State for Transport Justine Greening MP
Please find enclosed three copies of:
1. A complaint for a Litter Abatement Order
2. An accompanying map
3. An accompanying photograph
4. A copy of a S91 notice dated 29th February 2011
5. A draft summons
I am also enclosing cheque for the fee of £200 made payable to the “HMCS”
Please contact me by telephone or e-mail to confirm the documents are in order and to let me know about arrangements to issue a summons and to discuss hearing dates.
I look forward to hearing from you
Yours faithfully
Peter Silverman MA MSc
Complaint for a Litter Abatement Order
Wycombe & Beaconsfield Magistrates Court
Easton St, High Wycombe, Bucks, HP11 1LR
Date:
20st March 2012
Defendant:
Secretary of State for Transport Justine Greening MP
Great Minster House, 76 Marsham Street, London SW1P 4DR
Matter of complaint:
That the complainant is aggrieved by the defacement by litter and refuse of the verges and embankments alongside the slip roads of Junction 1 of the M40 motorway and the verges and embankments alongside the roundabout under the junction known as the Denham roundabout. These areas are shown in pink and yellow on the attached map which also accompanied the S91 notice of 29th February.
That the defendant has a duty to keep the said highway as far as practicable clear of litter and refuse under section 89(1) of the Environmental Protection Act 1990
And the complainant now therefore makes application to the Court to make a Litter Abatement Order pursuant to section 91(6) of the Environmental Protection Act 1990, requiring the defendant to clear the litter and refuse away from the said highway.
The complainant:
Peter Silverman of 20 Kingsend, Ruislip, Middlesex, HA4 7DA Tel: (Phone number removed)
Who states that the defendant was responsible for the matter of complaint of which particulars are given above.
Taken before me
Justice of the Peace / Justice’s Clerk
Summons
Wycombe & Beaconsfield Magistrates Court
Easton St High Wycombe Bucks HP11 1LR
Date:
Complainant:
Peter Silverman of 20 Kingsend, Ruislip, Middlesex, HA4 7DA Tel: (Phone number removed)
Defendant:
Secretary Of State for Transport Justine Greening MP
Great Minster House, 76 Marsham Street, London SW1P 4DR
Matter of complaint:
That the verges and embankments alongside the slip roads of Junction 1 of the M40 motorway and the verges and embankments alongside the roundabout under the junction known as the Denham roundabout are defaced by litter and refuse and that the defendant has a duty under S89(1) of the Environmental Protection Act 1990 to ensure so far as is practicable the said highway is kept clear of litter and refuse and the complainant has made an application to the court to make a Litter Abatement Order requiring the defendant to clear the litter and refuse away pursuant to Section 91(6) of the Environmental Protection Act 1990.
Date of hearing:
Time of hearing:
The above complaint has been made before me. You the defendant are hereby summoned to appear on the date and time shown above at Wycombe & Beaconsfield Magistrates Court, Easton St, High Wycombe, Bucks HP11 1LR
Justice of the Peace / Justices Clerk
