Criminal and Recordable Conduct Complaints against A/Sgt 3219 Anthony Lee and

Recordable Conduct Complaints against C/Supt Clive Wain, Insp Richard Close, Civilian
Officer 717966 Helen Crosland, all engaged with West Yorkshire Police
Complaint made by: Neil Wilby (the complainant) and submitted to West Yorkshire Police
Professional Standards Department and the IPCC on 27th October 2015
The complaints are framed using the rank of the officers at the time the earliest alleged offence
occurred.

1. Events giving rise to the complaint

a. The complainant is a NUJ accredited investigative journalist. He reports primarily
on matters concerning misconduct/criminality of police officers and/or policing
bodies
b. He also acts as advocate for members of the public who have complaint issues
against West Yorkshire Police
c. One of those members of the public is Stephen Bradbury. The complainant is on
record with both the police and the IPCC as Mr Bradburys complaint advocate
d. The complainant attended Wakefield Magistrates Court on 26th October, 2015 at
a criminal trial that involved Mr Bradbury and concerned an alleged offence of
obstruction (NICHE 13140482080)
e. At the start of the trial the district judge heard an application from the complainant
which sought permission to live feed the trial onto the Twitter social media
website. After a short hearing, permission was conditionally granted.
f. That live feed is now in the public domain and can be viewed at the @Neil_Wilby
Twitter id.
g. The charge against Mr Bradbury was dismissed by the district judge
h. The complainant has subsequently broadcast, via his own website, a more
complete account of the proceedings. That piece can be viewed at this weblink:
http://neilwilby.com/2015/10/26/proportionality-and-the-public-interest/
i. During the course of proceedings it became clear that a number of Recordable
Conduct offences were disclosed. These are set out below in Section 2 and
include misconduct, gross misconduct matters and criminal offences.

2. Grounds for complaint

a. Under Schedule 1 of the Police (Conduct) Regulations 2008 all police officers are
required to perform to the highest personal and professional standards as set out
in Standards of Professional Behaviour. Officers are now also required to comply
in all respects with the College Of Policing Code of Ethics. Section 5 deals in
detail with the responsibilities of individual officers and police forces and the
consequences of breaches of the Code.
b. In this complaint, matters are seriously aggravated by the fact that one of the
officers complained about is Head of Professional Standards and, as such,
entrusted by the Force in maintaining those very Standards and disciplining
1

those that fall below them. It is both a further aggravating factor and true to say,
on any independent view, that since his appointment as Head of PSD in July
2014 C/Supt Wain has acted, unfailingly, in a grossly discourteous, totally
unprofessional, highly prejudicial and discriminatory manner towards Mr
Bradbury. Wains is the conduct of a uniformed officer who should be patrolling
pay and display car parks, not holding high rank in a police force. Even one as
corruptly rancid as West Yorkshire Police.
c. These matters are also aggravated by the involvement of the staff officer to the
Command Team portfolio holder for Professional Standards.
d. This complaint alleges, by way of Recordable Conduct, the following breaches of
those Standards and Ethics referred to in para 2 a.
e. Honesty and Integrity:
(i) A/Sgt Lee lied on oath throughout his testimony at court. His evidence
contradicted that heard by the court from Emma Littlewood and Helen Crosland.
It contradicted his own written witness evidence and it contradicted the written
evidence of PC Daniel Stoppard. More crucially, Lees testimony was
unsupported by the only independent evidence available (the CCTV film shown
several times in court). In his summing up the judge preferred the testimony of all
the other witnesses (oral and written) to that of A/Sgt Lee. It should be noted also
that A/Sgt Lees demeanour throughout his witness box appearance was
unattractive, to say the least. It reflected poorly on West Yorkshire Police. That is
not a complainable matter but adds context to what has been a litany of quite
disgraceful conduct by Lee, throughout. Lees first written witness statement was
also to a large extent a fabrication, particularly in relation to the trumped-up
allegation of an assault on him by Mr Bradbury and the false account of
obstructing the highway
(ii) Helen Crosland testified on oath that all that could have been disclosed to Mr
Bradbury, by way of his subject access requests, had been disclosed. That is
simply untrue and she knew when giving evidence that it was deliberately false. It
is well established between West Yorkshire Police and Mr Bradbury that less
than 50% of the materials to which Mr Bradbury is entitled to from the police has,
so far, been disclosed and Mr Bradbury has provided detailed schedules of
undisclosed materials to the police that are inarguable. Ms Crosland also gave
evidence that Mr Bradbury had been informed by telephone about the fact there
was to be no car parking space allocated. That evidence is contradicted directly
by the written witness evidence of Alex Kirkham. For the purposes of this
complaint, the complainant submits, that on the balance of probabilities, Ms
Kirkhams account is more likely to be true. She had no reason to lie. Ms
Crosland plainly did. It should also be noted that the entire testimony of Ms
Crosland was delivered in an unconvincing manner and reflected little credit on
her or the police force whom she serves as a senior manager.
(iii) Insp Closes written witness evidence in the case is almost a complete
fabrication from start to finish. He makes assertions about traffic backing up into
the arterial routes of Wakefield city centre that are plainly false from viewing the
film. From plotting Closes movements on the film it would be impossible for him
to form that view. He would, however, have been able to see traffic flowing along
Laburnum Road, as can be clearly seen on the CCTV film throughout the
duration of the incident. He makes assertions about the circumstances, and time
2

taken, for moving Mr Bradburys car that are again proved to be false either by
viewing the time-clock on the film or considering Ms Kirkhams written evidence.

Close further makes an assertion about him parking Mr Bradburys car in a safe
and legal place. It is clearly seen both in photographs exhibited by Mr Bradbury,
and on the CCTV film, that the car was parked on double yellow lines and directly
in front of a No Parking sign.
f. Challenging and Reporting Improper Conduct: There is prima facie evidence
on the film of the Bradbury incident at the car park barrier that neither Inspector
Richard Close nor C/Supt Clive Wain challenged the improper conduct of A/Sgt
Lee in assaulting and maliciously arresting Mr Bradbury and damaging his motor
vehicle, aggravated by the fact that neither made any attempt to prevent the
assault taking place, having formed a reasonable suspicion that a confrontation
was likely, or intervening throughout its prolonged duration. C/Supt Wain also
failed to challenge the manifest breaches of PACE committed by A/Sgt Lee
(Inspector Close was focused on removing Mr Bradburys vehicle)
g. Abuse of Authority
(i) C/Supt Clive Wain: It became increasingly apparent through the course of the
trial that Mr Bradbury had, in fact, been the victim of an ambush laid for him at
the police car park barrier. Three people told Emma Littlewood that there was
NOT a car park space for Mr Bradbury (Wain, Crosland, Lee). Yet no-one had
informed Mr Bradbury of that fact. He was expecting to drive up to the barrier and
be admitted to a pre-reserved space, as he had been in the past. A/Sgt Lee
appears to have lain in wait near the corner of the police building and arrived at
the scene shortly after Mr Bradbury turns up at the barrier. He doesnt introduce
himself at the vehicle as one of the officers due to meet with Mr Bradbury and
seems more intent on escalating the situation, than simply arranging for Mr
Bradbury to pass through the barrier and find a space in the empty visitors car
park. The orchestrator of that ambush is plainly C/Supt Wain. He makes the
original decision not to grant access to the car park to Mr Bradbury and cascades
that decision down the ranks. Wain appears on film throughout most of its
duration, once Mr Bradbury is removed from his vehicle and is seen supervising
operations with a smug look of a job well done. At no time, does he exercise his
authority appropriately, de-arrest Mr Bradbury, arrange for his car to be safely
parked in the police yard and continue with the meeting as planned. It emerges
that he then decides not to rearrange the meeting that could not take place on
12th December 2014, after Mr Bradbury had been arrested. That lends weight to
the view, taken by most people in the courtroom during the trial, that Wain never
intended for a meeting to take place with Mr Bradbury, at all. The complainant
has also obtained information from a confidential source that the CPS were being
railroaded into proceeding with the Bradbury case by C/Supt Wain when the view
of the Crown of the case was that it had very little merit. If proven, on the balance
of probabilities, this is abuse of the worst possible type: Pursuing personal
vendettas using vast amounts of police resource and huge sums of public
money.
(ii) A/Sgt Lee breached PACE at every stage of the process leading to the
unlawful arrest and detention of Mr Bradbury
3

(iii) A/Sgt Lee and C/Supt Wain conspired together to bring about a malicious
prosecution of Mr Bradbury
(iv) After joyriding in Mr Bradburys car, Insp Close parked it on double yellow
lines and in front of a large No Parking sign. Presumably, in the hope that it
would be clamped and/or towed away whilst Mr Bradbury was unlawfully
detained at Normanton police station.
h. Criminal allegations
(i) A/Sgt Lee inflicted an unannounced, unprovoked and gratuitous assault on Mr
Bradbury, contrary to common law. He used grossly excessive force on a small,
64 year old man causing him to scream with pain. His evidence when asked to
rebut that in court was, in the judges words, weak and unconvincing.
(ii) Lee also criminally damaged Mr Bradburys car by deliberately forcing the
offside door into the car park barrier pillar. Mr Bradbury holds photographs of the
damage, taken contemporaneously.
(iii) Insp Close committed the offences of taking a motor vehicle without the
owners consent, and driving without insurance, when he took Mr Bradburys
Porsche motor car for a joy ride

3. Requested Outcome
a. That the West Yorkshire Police refer itself to the IPCC over these specific issues
of Recordable Conduct and, preferably, over the wider prejudice and
discrimination visited upon Mr Bradbury by senior officers in the force. A subject
touched upon by the judge in his closing remarks, after dismissing the case
against Mr Bradbury.
b. That an outside police force be appointed to investigate all West Yorkshire
Polices dealings with Mr Bradbury, the flagrant mismanagement of police
resources and public funds, and the manifest and continuing breaches of
common law, the Data Protection Act, Police Reform Act, Police and Social
Responsibility Act, Police (Conduct) Regulations, Code of Ethics and IPCC
Statutory Guidance

Neil Wilby
Complainant
neil.wilby@btinternet.com
27th October 2015