1. As to paragraph 1 of the Statement of Claim it is not admitted that
Stonehenge was made or ever used for such purposes as in the said
paragraph mentioned or any of them or for any public purpose. Stonehenge
is and has been from time immemorial and in fact at all times private
property and not national or public property and resort thereto by the
public has always been by permission of the owner of the land and not as
of right.
2. As to paragraph 2 the principal part of Stonehenge lies in an angle
between and near to two public roads leading from Amesbury to Shrewton
and to Winterbourne Stoke respectively. A public way or track leading
from Netheravon to Lake crosses these two roads and also crosses part of
Stonehenge but except the right to use this way or track (which is
outside the fence erected by the Defendant and has not been in any way
obstructed by him) there never has been any access for the public to
Stonehenge otherwise than by permission of the owner of the land on which
it is situate. The alleged road running up to and through Stonehenge the
sites of which are purported to be shown on the plan annexed to the
Statement of Claim and are thereon coloured green (except the way or
track from Netheravon to Lake aforesaid) do not exist either in law or in
fact and never have existed.
3. Paragraph 3 of the Statement of Claim is denied except as to the way
or track from Netheravon to Lake aforesaid.
4. Paragraph 4 is altogether denied. Stonehenge is not and never was
subject to any trust for user or access by the public or to any public
trust.
5. As to paragraphs 5 and 6 the Defendant has for the better
preservation of Stonehenge erected and maintains a fence round the land
lying within the triangle formed by the said two public roads and the way
or track from Netheravon to Lake not obstructing or interfering with any
public right of way. Save as aforesaid paragraphs 5 and 6 of the
Statement of Claim are denied.