30/12/2021: In this linked document, you can see pages 1 to 17 of my 37-page complaint.
I would direct the reader to paragraph (A) 6.b. on page 9, where path ‘B’ is explained as the crucial and primary pathway that should have conclusively led to the issuance of the Certificate without any further consideration. This position was solidly backed up by documented evidence showing the operation of a commercial office before the 2005 Planning Law came into force, a fact confirmed by email correspondence both from myself and the Cadastre and known to the Department from the outset.
This central point to my complaint was sidestepped by all 3 reviewers. It was the fundamental point that I made.
It was elaborated upon further, both in correspondence with the Board and at the hearing itself. It was, therefore, squarely within the terms reference set for the third review. Yet it was omitted. And the Board allowed this.
As an aside, I have been waiting for an explanation of the conduct mentioned from mid-page 13 to page 17 of this document for over 10 years from our Civil Service. They simply will not explain themselves.
I made a previous request for Administrative Review in 2014 on this topic but this request was declined by HM Greffier acting as the gatekeeper (this was the process before the Independent Complaints Panel was created). Had this review happened, and been conducted properly, I believe matters could have changed for the better. Not just for my family, but for the Island as a whole.