INJUNCTION

WARNING: HIGH COURT INJUNCTION IN FORCE

HIGH COURT CLAIM NO: HC-2017-002125


NOTICE AND SERVICE OF HIGH COURT INJUNCTION ORDER DATED 20 SEPTEMBER 2017

 

TO: PERSONS UNKNOWN AS MORE PARTICULARLY DEFINED IN AND DESCRIBED AS THE FIRST, SECOND, THIRD, FOURTH AND FIFTH DEFENDANTS IN THE ORDER (THE "DEFENDANTS")

FROM: (1)INEOS UPSTREAM LIMITED, (2) INEOS 120 EXPLORATION LIMITED, (3) INEOS PROPERTIES LIMITED, (4) INEOS INDUSTRIES LIMITED, (5) JOHN BARRIE PALFREYMAN, (6) ALAN JOHN SKEPPER, (7) JANETTE MARY SKEPPER, (8) STEVEN JOHN SKEPPER, (9) JOHN AMBROSE HOLLINGWORTH, AND (10) LINDA KATHARINA HOLLINGWORTH (THE "CLAIMANTS")

IF YOU THE WITHIN-NAMED DEFENDANTS OR ANY OF YOU, DISOBEY THIS ORDER YOU MAY BE HELD TO BE IN CONTEMPT OF COURT AND MAY BE IMPRISONED, FINED OR HAVE YOUR ASSETS SEIZED. ANY OTHER PERSON WHO KNOWS OF THIS ORDER AND DOES ANYTHING WHICH HELPS OR PERMITS THE DEFENDANTS OR ANY OF THEM TO BREACH THE TERMS OF THIS ORDER MAY ALSO BE HELD TO BE IN CONTEMPT OF COURT AND MAY BE IMPRISONED, FINED OR HAVE HIS OR HER ASSETS SEIZED.


THIS INJUNCTION PROHIBITS:

1. THE FOURTH DEFENDANTS FROM PURSUING ANY COURSE OF CONDUCT AGAINST THE CLAIMANTS AND/OR THIRD PARTIES SUCH AS AMOUNTS TO HARASSMENT OF THE FIFTH TO TENTH CLAIMANTS OR ANY OF THEM AND / OR THEIR SPOUSES OR IMMEDIATE FAMILY AND / OR ANY OFFICERS, EMPLOYEES AND / OR PERSONS ENGAGED BY ANY OF THE CLAIMANTS WITHIN THE MEANING OF THE PROTECTION FROM HARASSMENT ACT 1997

2. THE FIFTH DEFENDANTS AND EACH OF THEM FROM COMBINING TOGETHER TO COMMIT ANY OF THE FOLLOWING OFFENCES OR UNLAWFUL ACTS:

  • PURSUING ANY COURSE OF CONDUCT, WITH A VIEW TO COMPELLING ANOTHER PERSON TO ABSTAIN FROM DOING OR TO DO ANY ACT WHICH THAT PERSON HAS A LEGAL RIGHT TO DO OR ABSTAIN FROM DOING, WRONGFULLY AND WITHOUT LEGAL AUTHORITY, SUCH AS AMOUNTS TO AN OFFENCE UNDER SECTION 241(1) OF THE TRADE UNION AND LABOUR RELATIONS (CONSOLIDATION) ACT 1992;
  • PURSUING ANY COURSE OF CONDUCT THAT AMOUNTS TO CRIMINAL DAMAGE OR THEFT;
  • OBSTRUCTING THE FREE PASSAGE ALONG A HIGHWAY UNREASONABLY AND/OR WITHOUT LAWFUL AUTHORITY OR EXCUSE, INCLUDING (BUT NOT LIMITED TO) BY SLOW WALKING IN FRONT OF VEHICLES AND ATTACHING THEMSELVES TO ANY VEHICLES OR OTHER OBJECTS ALONG THE PUBLIC HIGHWAY;
  • CAUSING ANYTHING TO BE DONE ON OR OVER A ROAD, OR THAT WHICH INTERFERES WITH A MOTOR VEHICLE, TRAILER OR CYCLE, OR INTERFERES (DIRECTLY OR INDIRECTLY) WITH TRAFFIC EQUIPMENT, IN SUCH CIRCUMSTANCES THAT IT WOULD BE OBVIOUS TO A REASONABLE PERSON THAT TO DO SO WOULD BE DANGEROUS


IN EACH CASE WITH THE INTENTION TO OBSTRUCT, IMPEDE OR INTERFERE WITH THE LAWFUL ACTIVITIES UNDERTAKEN BY THE CLAIMANT(S) WHETHER THEMSELVES OR VIA THEIR AGENTS, SERVANTS, CONTRACTORS, SUB-CONTRACTORS, GROUP COMPANIES, LICENSEES, EMPLOYEES, PARTNERS AND/OR CONSULTANTS IN CONNECTION WITH THE CLAIMANTS' SEARCHING OR BORING FOR OR GETTING ANY MINERAL OIL OR RELATIVE HYDROCARBON AND NATURAL GAS EXISTING IN ITS NATURAL CONDITION IN STRATA AND ALL ASSOCIATED AND CONNECTED ACTIVITIES.

The Order will be further considered at a hearing in a 2 day window from 30 October 2017 with a time estimate of 3 days "THE FURTHER HEARING".  Any Defendant(s) is/are entitled to file evidence with the Court and to serve it upon the Claimants by 4pm on 3 October 2017.

Copies of the Order dated 20 September 2017, Schedule 20 to the Order, Application Notice dated 31 July 2017, Amended Claim Form and Notice of Further Hearing can be accessed below.

Court communications: all communications about the Order should be sent to the Court Manager, High Court of Justice (Ref: HC-2017-002125) (details found at https://courttribunalfinder.service.gov.uk/courts/rolls-building)

Claimants' solicitorsFieldfisher LLP whose address is Riverbank House, 2 Swan Lane, London EC4R 3TT (Telephone number: 0207 861 4000; Email address: IneosTeam@fieldfisher.com). Subject to the Defendant(s) providing their name(s), address(es) and proof of identity when making a written request to the Claimants' solicitor (quoting reference OTD/INEOS), the Claimant will promptly make available to the Defendant(s) the Court documents, witness evidence and exhibits via an online file hosting service.