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Henderson v Blackwood Estates — Master Brief

MASTER BRIEF

Henderson v Blackwood Estates

Property Dispute — Boundary & Easement

Position

The claimant asserts that the boundary between the properties was agreed in 2018. However, a 2019 survey indicates a materially different boundary line. The knowledge state is contested.

Key Strengths

Three independent witnesses confirm the original boundary understanding. Title deed plans from 2006 support the claimant's position.

Exposures

Evidence of prior warning letters weakens the argument of good faith reliance. The 2019 survey was commissioned by the claimant but not disclosed.

Questions & Gaps

Missing correspondence from Q3 2018 is referenced in three documents but no direct evidence exists.

Next Actions

Request disclosure of 2018 correspondence. Commission independent boundary survey. Prepare witness chronology.

CIRCA

You

What are the main risks to our position?

C

Three main risks identified:

1. Evidence of prior warning letters

2. Alternative interpretation of policy guidance

3. Limited case law directly on this point

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SOURCE DOCUMENT

Witness Statement

Paragraph 17

“The boundary between the two properties was agreed in 2018 following discussions with the claimant's surveyor.”

CIM

EXTRACTS

ANALYSES

CONNECTS

CONTEXTUALISES

DERIVED INTELLIGENCE

CLAIM

Boundary agreed in 2018.

CONTRADICTING EVIDENCE

2019 survey indicates different boundary.

KNOWLEDGE STATE

Contested

Survey.pdf · Page 14

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PositionReasoningExposuresQuestions & GapsNext Actions

POSITION

The claimant maintains that the boundary between the two properties was definitively agreed in 2018 following professional survey.

However, the defendant has produced a 2019 survey that indicates a materially different boundary line, creating a direct factual conflict at the centre of the dispute.

Knowledge State: Contested

KEY REASONING

Three independent witnesses support the original boundary. Title plans from 2006 are consistent with the claimant's position. The contradiction arises primarily from the 2019 survey which the claimant commissioned but did not disclose.

Witness Statement — Para 17Page 4

SOURCE DOCUMENT

Witness Statement of J. Henderson

Filed 14 March 2026 · Page 4 of 12

... paragraph 16 ...

17. The boundary between the two properties was agreed in 2018 following discussions with the claimant's surveyor. The agreement was verbal and no written record was produced at the time.

... paragraph 18 ...

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PositionReasoningTimeline12 entities · 14 relationships

INSPECTOR

Contradiction

Boundary Contradiction

2018 agreed boundary directly contradicted by 2019 survey measurements.

CONNECTIONS

Boundary Agreed 2018

contradicts

2019 Survey

evidenced by

Disclosure Obligation

triggers

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CIRCA

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C

CIRCA

Henderson v Blackwood Estates

Connected

You

What are the main risks to our position?

C

Three main risks identified:

1. Evidence of prior warning letters weakens the good faith argument

2. The 2019 survey was commissioned but not disclosed — this creates a disclosure risk

3. Missing Q3 2018 correspondence leaves a gap in the chronology

Warning Letters Bundle — Page 3→

Survey Commission — Email dated 14.06.2019→

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Your organisation already has the information.
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From thousands of pages to a position you can actually understand.

CIM understands the difference between what someone said and what the evidence establishes.

Your documents, continuously understood.

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Your professional history, still available when you need it.

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Intelligence you can trust because you can verify it.

Your documents already contain the answers. Let CirclAI find them.

Your organisation already has the information.CirclAI turns it into intelligence.

From thousands of pages to a position you can actually understand.

CIM understands the difference between what someone said and what the evidence establishes.

Your documents, continuously understood.

Your documents, mapped.

Ask the matter, not just the document.

Your professional history, still available when you need it.

One intelligence engine. Configured for your profession.

Intelligence you can trust because you can verify it.

Your documents already contain the answers. Let CirclAI find them.

Your organisation already has the information.
CirclAI turns it into intelligence.