summary, the evidence of the second witness statement of Chris Williams details the following:
(1) That which has already been set out above about the extent of the encampments before the first injunction was imposed.
(2) The fact that the injunction area comprised about 10 per cent of the borough but was an area where 88 per cent of the encampments that have taken place up to then had occurred. (3)Following the grant of the injunction in the period between April 2019 and January 2024, the borough experienced 35 unauthorised encampments, 18 of which were in the injunction area. That equated to just over 10 per cent. It was therefore the case that about 51 per cent of the encampments were formed in the injunction area. This shows that there was a decrease in the number of encampments, both in the borough as a whole and in the injunction area, since the injunction had been ordered. Further, as Mr Williams explained in his evidence at paragraph 28, the duration of encampments within the injunction area decreased significantly since the grant of the injunction.
(4) At paragraphs 41 to 74, Mr Williams gave specific details of each of the 35 post- injunction encampments and specific harm that were caused by each.
(5) At paragraphs 75 to 88, Mr Williams gave further details of harm suffered by reason of unauthorised encampments. Those harms include risk to public health, including by the depositing of untreated human waste, threats and intimidation to the local community, nuisances including noise and smoke, and the financial impact of encampments including cleanup costs and enforcement costs. (6) At paragraphs 96 to 107, Mr Williams explained why there was a continuing need for injunctive relief and why the claimants apprehend that absent that relief, further and increased instances of unauthorized encampments and resulting harm will or is likely to be suffered.
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