Example Witness Statement for Civil Proceedings

Example Witness Statement for Civil Proceedings

Example Witness Statement for Civil Proceedings

Spittalgate Community Law Centre,

31 George Street,



Spittalgate Community Law Centre


Our Reference: LS I 1

Your Reference:  LSI1



Witness Statement of:


Ms Louise Sandwell,

43 Glebe Terrace,

Spittalgate South,



For Defence Counsel

1)     I, Ms Louise Sandwell stopped working as a self-employed taxi driver for personal reasons in March 2008, and pursued a job with Merrigate Buses, even though my previous occupation was better paid.

2)      I saw an advertisement in the newspaper regarding Merrigate Buses, and thought, even though the pay was not as good as my previous employment, it offered more sociable hours.

3)     Chris Langdon, the manager of Merrigate Buses, initially interviewed me for the job. At interview he told me I had to complete the training course, upon which I could start my employment with the company, at the end of March. There was no mention of the training course in the advertisement I read, nor did it state that any experience was required. I would not have gone to a job interview had I known there was going to be a training course. I believed it was unnecessary to do the training course because I knew of all of the routes as a result of my previous job, and that the skills I had from my previous employment were transferable to this one, but I still agreed to do it because I needed a job.

4)      Before undertaking this course the local secretary typed a document and made me sign it. (See Exhibit LS1.1 and LS1.2) It stated that I would be liable for the value of the training course of £1,000. I objected to this and made my views known to the manager, Chris Langdon, who reassured me in saying “don’t worry, we only make people sign this so they don’t get the benefit of the course without joining the bus company,” or words to that effect. I was told by Chris Langdon it was not an issue as I had joined the bus company, and therefore I would not be liable. Believing this to be the case and knowing that if I did not sign the document, and take the training course, I would not be given this job as a bus driver I subsequently signed the document and took the training course.

5)     After completing the training course I was sent an offer of employment (See exhibit LS2.1 and LS 2.2) I was then made to sign another document before I could commence employment. (See Exhibit LS 3.1) The document was with a Standard Form ‘terms of employment document’ which all of Merrigate Buses’ employees have to sign before beginning employment.

6)     The training course consisted of driving around the regular bus routes accompanied by someone who was currently employed by Merrigate Buses. Following that there was a theoretical driving test, conducted out of house, which I passed with flying colours. I felt it was completely pointless to have to run this training course.

7)     At the start of my employment everything was going well and I worked regular eight hour shifts. However I began encountering a problem shortly after  starting work, when I was assigned on the university to town bus route. It was very difficult to do because the university students were very loud and aggressive. There was no particular incident regarding the students. They are simply very loud and drunk, and being a woman, I felt unsafe around them.

8)     I made a complaint about the route I was assigned to. I don’t like dealing with students, and I have expressed that to no effect but being given that route more and more often by Alex Riley, my immediate superior at the time, who allocated drivers to the respective routes. No bus driver from Merrigate Buses liked the university route. They all hated it, and made this clear to me. As a result, I felt victimized by being assigned this route as often as I was, and believe it was done deliberately by Mr Riley. This made me unhappy at work and subsequently unhappy at home, to the point of depression. I was being put on this route throughout June and July, and maybe even May.

9)     Upon expressing my distaste for the university route a second time to Mr Riley, he simply told me to “bugger off” if I didn’t like it. I felt that this was a very strange response. Before this incident we got along normally, and I have no reason to believe any particular incident had occurred that would change that. I suspect it may have been a reciprocation of my attitude at the workplace, but my attitudes were mainly generated by being made to run the university route. No one saw that altercation between Mr Riley and I. It was behind closed doors, as most of our communications were.

10)     On the 4th of August 2008 my husband left me because we were fighting more often than we had before I started this job. I thought my job as a bus driver would make us argue less than we did, but as a result of being as upset as I was at the workplace, it made our altercations worse, so he left.

11)     My husband left so suddenly that I had to stay home to look after my five year old son, Mikey, as I did not have time to make other arrangements. I became so depressed that I could no longer get out of bed. I asked my sister, Toni Sandwell, to call Merrigate Buses and tell them that I was ill and could not go into work. I did not want my sister to disclose the reasons for not coming into work because I did not feel comfortable sharing that information with the people whom I worked with.

12)     On August 11th I made an appointment to see a doctor because of how depressed I had become. My doctor at the Spittalgate South NHS Center said that I was clinically depressed. I started to take antidepressant medication, and was advised to seek the help of Social Services.

13)     On August 12th I received a letter from Merrigate Buses warning me that I had to go work, (See exhibit LS 4.1) having missed a week without giving any reason. The letter stated that if I did not go back to work the following day I would be fired. I did not respond to the letter.

14)    On August 13th Mr Riley turned op on my doorstep. He greeted me by saying, “Oh, so you are alive then.” He followed this by saying that I did not have to worry about driving the university route anymore and subsequently handed me a letter saying that I had been fired (See exhibit LS 5.1) Mr Riley had never come to my house before this. I believe he knew my address from my work file, but we were never close enough to be visiting one another outside of working hours.

15)     The letter confirmed that I was fired effective immediately, but was not compensated in pay for the hours I worked before my last pay cheque.

16)     Since then I have had to go on to benefits and now receive roughly £75 every week to support my son and I. I am unable to seek other forms of employment because of my depression.

17)     On September 15th I received a letter from Merrigate Buses stating that I owed them £1,000 for the cost of the training course which I was made to complete at the beginning of my employment. (See exhibit LS 6.1)

18)     I do not want to pay back the £1,000 for a training course. I maintain the belief that I don’t have to pay £1,000 because I had, as per Chris Langdon, joined the bus company.

19)      I find it unreasonable to be legally threatened and coerced into paying back £1,000 when I myself have yet to receive pay for some of the days I worked with Merrigate Buses, prior to me illness

20)    To this point, 27/11/08, I have had no further oral or written communications with Merrigate Buses following their letter of 15th September, upon which I immediately contacted Spittalgate Community Law Center.

I Ms Louise Sandwell hereby confirm this statement is truthful and in accordance with the events recalled to the best of my knowledge.