Until the time of his death (1990),XXXX was the sole registered owner of 3, Melbourne Avenue. He lived there with his wifeXXXXand two daughters, XXXthe elder and XXX
From 1964, I was datingXXXX who was then 16 years old.
About December 1965, XXX became pregnant with XXX We were not married at the time - we were under pressure from XXX parents to be married..
XXXwas an experienced bricklayer / builder. I am a bricklayer. I had noticed what appeared to be a plot of waste ground on the E side of bungalow. In early1966, XXXand I discussed demolition of the bungalow and building 2 houses (one each). Of course, part of the deal was that XXXXand I would be married. I subsequently gave XXX £300 for the plot of land adjacent and parallel to the bungalow on the E side, the full length of the bungalow and front (N) garden to the centre of Melbourne Ave. (outlined in red on the plan A/3 Melbourne). He gave me a signed receipt (which I cannot find).
However, we decided that this plan was beyond our means.
XXXlater argued that he had sold the plot of land to me for too low a price and demanded more money - I disagreed - we "fell out" over this. As far as I know, the purchase was never registered.
XXXbegan work on brick cladding the side of the timber bungalow.
In late 1967, despite protests from XXX I bought a brand new static "mobile" home, demolished the garden wall at 3 Melbourne, and positioned my home on my piece of land, excavated, installed services and connected them to the Mains. I also laid a concrete path the full length of the house, placed paving slabs and built 2 sets of brick steps for access to my home. I also built a brick dwarf wall all around the mobile home and erected two gates - one at each end of the path. I also cultivated the garden surrounding my home.
No permission was given for this and I never asked for permission - I did not need to.
XXXX stopped work on the brick cladding and it was never completed.
The garden to the front and rear of my plot of land was/is delineated by concrete edgings.
During my occupation, right up to the present, no one other than my immediate family has ever tended the gardens surrounding my home nor entered my home or onto my plot of land - everyone has always respected my privacy and possession of this plot.
June 1968 Sandra became pregnant again.
We married on 15th.January.1969. XXXand I moved into the mobile home.
26. March.1969, Sandra gave birth to the second child, John Free.
13. Oct. 1970, Sandra gave birth to the third child, Robert Free.
We continued to live in the mobile home until 1983 after which, Sandra and I used it variously as a Summer house, study and for storage.
We continued to tend the gardens and paths surrounding our home.
This exclusive use continued until the present date.
1990 XXXX died intestate, the property passed to XXXX
In 1994 a large "Monkey Puzzle" tree at 1, Melbourne Ave. penetrated and blocked the drain serving 3 Melbourne. I excavated for and replaced/repaired the foul drain. The drain ran through my land and it was therefore my responsibility.
2006 XXXXtransferred the property to her daughter XXXX (XXX) and her grandaughter XXX in equal shares.
XXX and I continued to use the mobile home as a Summer house/storage until 2013 when I removed it to excavate for and renew the leaking water main (serving the house and mobile home) which (as Edna Jackson pointed out to me) was my responsibility due to the fact that the mains pipe is on my land (beneath the mobile home). At no time did I give up occupation of my plot of land.
After I had completed the repair of the water pipe, I replaced my mobile home with a newer model and rebuilt the front brick garden wall. I then reinstated the gardens on my plot. This work was completed 14th.July 2015.