You now need to stop trying to run this case yourself and let Jackson Yamba take over completely. At this stage the situation is far beyond “DIY complaint” territory. You have:
– An ongoing criminal allegation with a crime reference number.
– A certificated enforcement agent who has almost certainly abused his certificate.
– A company that has unlawfully seized and is detaining your vehicle.
– A potential injunction and a substantial civil claim.
Every extra call or email you make directly to LME, PPS, Thames City, or the police risks muddying the waters, creating inconsistent statements, or giving them something to twist. The whole point of instructing Jackson is that he is now your mouthpiece. From here on:
– You should not be phoning the police yourself to “update” the log.
– You should not be arguing law with random call handlers who will just parrot “civil matter” because that’s all they know.
– You should not be contacting LME or PPS at all, other than through Jackson.
On the @DWMB2 point: there is no real inconsistency. The Met has logged the matter as a crime and given you a crime reference number. That means, institutionally, it is being treated as a potential criminal offence. The fact that some call handler on a different day says “it’s civil” just shows that individual has not read the file, does not understand PoFA, and is speaking from habit rather than law. Call centre opinions do not change the legal reality.
The legal reality is this:
– It is only a “civil matter” if the car was seized lawfully under a judgment and warrant.
– Here, there is no judgment and no warrant.
– The clamp and tow therefore fall squarely within s54 PoFA and, on any sensible view, within the Theft Act as well.
– That is criminal. The Torts Act does not rescue them.
What you should do now is very simple:
1. Give Jackson a clear summary of your most recent contacts with the police and LME (including the “civil matter” nonsense and the latest LME email).
2. Tell him you do not intend to have any further direct dealings with anyone and that you want all communication with the police, LME, PPS and Thames City to go through him.
3. If the police call you, take their details and politely say that your legal representative, Mr Yamba, will respond and provide all further information.
You have done more than enough. You’ve gathered evidence, forced a crime report, exposed the misuse of the Torts Act, and identified the enforcement agent and his certification. From here on the best thing you can do to help your own case is step back and let Jackson run it.
For now, I’d keep your focus firmly on your own case now and not get drawn into trying to get involved with someone else’s. It is useful for your solicitor to know that this may not be an isolated incident at Thames City, so do mention to Jackson that you’ve heard of at least one other resident who was clamped and towed with no judgment or warrant and paid £3,000 to get their car back.
Beyond that, I would not go any further yourself. If you manage to identify that resident, the best advice you can pass on is simply that they should get proper legal advice in their own name, ideally from the same specialist you are using. You can tell them you’ve instructed Jackson Yamba at Contestor Legal and suggest they contact him directly with their paperwork and payment history so he can assess whether the removal in their case was as unlawful as yours and whether those losses can be recovered. But you should not try to advise them on chargebacks, complaints or claims yourself – let Jackson deal with that, and keep this thread clear and focused on your case.
Any response should now come from Jackson, although you can suggest to him that he should warn them of any additional financial consequences they risk by not complying with a reasonable request, such as obtaining equivalent replacement transport until your property is returned.
What you can do is send him a short instruction along these lines:
Hi Jackson,
Just to update you, LME have now replied again. They maintain that there is no conversion and repeat their offer to release the car for £575 as they are ‘closing for the holidays’. I have attached their latest email.
Given my reliance on the car for daily use and work, I would like any further response from you to make it absolutely clear that:
1. Their continued refusal to return the vehicle unconditionally is causing ongoing loss, and
2. I will be seeking recovery not only of any sum I am forced to pay to get the car back, but also all consequential losses – including the cost of any equivalent replacement transport (hire car, taxis, etc.) that I reasonably have to incur while my car is withheld.
In other words, they have now been warned that every extra day they sit on my car increases their financial exposure. If you think it appropriate, please spell this out in your next email/letter, so there can be no doubt that they are on notice of the additional damages they are inviting.
Thank you, and I will follow your lead on all further communications with LME, PPS and the landowner.
That puts Jackson on clear notice of what you want him to press as additional financial consequences, without you writing directly to LME.
Their reply is legally illiterate and actually helps you.
First, their definition of conversion is simply wrong. Conversion is not limited to “using the goods for their own use”. It covers any deliberate dealing with someone else’s goods that is inconsistent with the owner’s rights, including seizing, detaining, withholding, moving, or disposing of them. Clamping your car, towing it away, refusing to return it unless you pay, and threatening sale are all classic examples of conversion. They have openly admitted doing exactly that.
Second, saying “we have notified the Police of its removal and the reason why” is meaningless. The police already know it was removed; you have a crime reference number and the Met has accepted that an offence has been committed. Telling the police “we removed it because of the Torts Act” just puts their bogus legal justification on record as evidence against them. It does not cure the lack of lawful authority, it just hardens the proof that they have none.
Third, the “we are closing this week for the holidays” and “the offer still stands” line is nothing more than pressure. It confirms that this is a ransom demand. They are trying to leverage the holiday period and your need for the car to force payment. That will look very bad in front of any judge.
The important thing now is that you have instructed Jackson Yamba. That is absolutely the right move. From this point:
– Let Jackson take the lead on all contact with LME, PPS and the landowner.
– Do not call their number. Keep everything in writing and let your legal representative handle it.
– Preserve all emails and notices; they are excellent evidence of deliberate unlawful interference and a complete misunderstanding (or misrepresentation) of the law.
In short, their latest response doesn’t weaken your case in any way. It reinforces that they do not understand conversion, have no lawful authority, and are relying on an obviously wrong reading of the Torts Act. Have you informed Jackson of this response?
You should also start the process of getting their supposed "enforcement agent", Khoshal Ebrahim sanctioned. In practice, complaints about a certificated enforcement agent go back to the County Court that issued the certificate – in this case Hertford County Court. The judge who granted or last renewed the certificate has power to suspend or revoke it if the agent is unfit or has abused their powers.
Here is what you should do, step by step.
1. Gather the key information
You need to have all of this ready:
– Full name of the enforcement agent: “Khoshal Ebrahim” (as per the register).
– Certificate details: certificated by Hertford County Court, valid from 16/04/2025 to 15/04/2027, employed by Newlyn Plc.
– Evidence of misconduct:
• Photos of the clamp and tow.
• Copies of the 7 Day Tort Notice, Warning of Immobilisation, Notice that Goods Have Been Secured, etc.
• LME’s emails admitting reliance on the Torts Act as “lawful authority” and offering the “Christmas” reduction to £575.
• Any correspondence notices showing he acted for LME Services, not Newlyn.
• The crime reference number and a short note of the police accepting that an offence has been committed.
2. How to send the complaint
Complaints are made by written application to the court that issued the certificate. There isn’t a fancy form
– you write a witness statement or detailed letter and send it to “The Manager” or “The District Judge” at Hertford County Court, clearly marked as:
“Complaint regarding certificated enforcement agent – Mr Khoshal Ebrahim”
You send it by post (first class and a free Proof of Posting certificate form any post office) to PO Box 373, Hertford SG13 9HT and ideally also by email to enquiries.hertford.countycourt@justice.gov.uk and CC hello@lmeservicesltd.co.uk, contact@newlynplc.co.uk and yourself.
3. What to say – structure of the complaint
The complaint should:
– Identify the enforcement agent and certificate.
– Explain who you are and your connection to the case.
– Set out the facts clearly and chronologically.
– Explain why his conduct is a misuse/abuse of his certificate and contrary to the Taking Control of Goods regime.
– Ask the court to list the matter for a hearing to consider suspension or revocation of his certificate.
Here is a draft you can adapt:
For the attention of:
The District Judge/Court Manager
Hertford County Court
Shire Hall
Fore Street
Hertford
SG14 1DF
Complaint regarding certificated enforcement agent – Mr Khoshal Ebrahim
I, [full name], of [address], make this complaint regarding the conduct of Mr Khoshal Ebrahim, a certificated enforcement agent whose details appear on the Certificated Enforcement Agent Register as follows:
– Name: Khoshal Ebrahim
– Court of certification: Hertford County Court
– Certificate period: 16 April 2025 to 15 April 2027
– Employer: Newlyn Plc
I understand that Hertford County Court has power to suspend or revoke his certificate if satisfied that he is not a fit and proper person to hold one or has abused his position. I respectfully submit that his recent conduct demonstrates serious misuse of his certificate and unlawful enforcement behaviour.
Background
1. I am the owner and keeper of a BMW 530e motor car, registration [VRM].
2. Private Parking Solutions (London) Ltd (“PPS”) has issued a number of disputed Parking Charge Notices in respect of the vehicle. No County Court claim has been issued, no judgment obtained and no warrant of control has been granted in respect of these PCNs.
3. On 5 December 2025 my vehicle was clamped and then removed from the private access road at Thames City, Carnation Way, London SW8 5GZ by an operative of LME Services Ltd (“LME”). The clamp was applied and the removal carried out in the presence of Metropolitan Police officers. I attach photographs.
4. A “Warning of Immobilisation” notice dated 05/12/2025 was placed on the vehicle, giving the company name LME Services Ltd and naming the person involved as “K. Ebrahim” described as an “Enforcement Agent”. This notice stated that the vehicle was immobilised because it was “trespassing and/or abandoned on private land”. I attach a copy.
5. A further document entitled “Notice that Goods Have Been Secured and Notice of Intention to Sell Goods” purporting to rely on section 12 of the Torts (Interference with Goods) Act 1977 was left. It demanded a “release fee” of £5,325 (broken down as 29 private parking charges plus a “removal truck fee”) and £40 per day storage, and threatened that my vehicle would be sold after three months. I attach a copy.
6. At no time have I been provided with any County Court or High Court claim number, judgment, warrant of control, writ of control or any other enforcement authority. No such warrant exists. The seizure was not carried out pursuant to any court order.
7. Following complaints, LME have now written to me admitting that they rely entirely on the Torts (Interference with Goods) Act 1977 as their “lawful authority” to remove vehicles, and offering to return my vehicle on payment of a “keyless removal truck fee” of £575 “in the spirit of Christmas”. They no longer seek to enforce the alleged parking charges. I attach a copy of their email.
8. I have separately confirmed via the Certificated Enforcement Agent Register that Mr Khoshal Ebrahim is certificated by Hertford County Court only in connection with his employment with Newlyn Plc for the period 16 April 2025 to 15 April 2027. LME Services Ltd is a different company and there is no suggestion that Newlyn Plc is involved in this matter.
Misconduct
9. On the above facts, I say that:
a) Mr Ebrahim has held himself out as an “Enforcement Agent” enforcing alleged debts when there is no judgment and no warrant of control. He has therefore used his certificated status to give a false impression of enforcement powers he does not possess.
b) He has purported to exercise powers of taking control of goods and removing goods in the complete absence of any lawful authority under the Tribunals, Courts and Enforcement Act 2007 and its Regulations.
c) He has relied on the Torts (Interference with Goods) Act 1977 as if it provided him with a power to seize goods, which it plainly does not. The Act deals with disposal of goods already in a bailee’s lawful possession and does not override section 54 of the Protection of Freedoms Act 2012 (which criminalises clamping and towing on private land without lawful authority).
d) He appears to have carried out enforcement activity on behalf of LME Services Ltd, a company other than his certificated employer Newlyn Plc. If that is correct, he has acted outside the scope of the employment for which his certificate was granted.
e) His actions have resulted in the unlawful immobilisation, removal and detention of my vehicle and a continuing demand for payment as a condition of its return.
10. I have reported the matter to the Metropolitan Police. They have accepted that a criminal offence has been committed and have issued a crime reference number: [crime ref]. The police are investigating offences including unlawful immobilisation/removal of a motor vehicle on private land and theft of a motor vehicle.
Outcome sought
11. In the circumstances, I respectfully request that Hertford County Court lists this complaint for consideration by a District Judge with a view to:
a) Investigating the conduct of Mr Khoshal Ebrahim as set out above; and
b) Suspending and/or revoking his enforcement agent’s certificate on the basis that he has abused his position and is not a fit and proper person to hold a certificate.
12. I am willing to attend a hearing and give evidence, and I can provide any further documents the court may require. I would be grateful if the court would acknowledge receipt of this complaint and inform me of the next steps.
Statement of truth
I believe that the facts stated in this complaint and the attached documents are true.
Signed: [full name]
Dated: [date]
– Attach copies of all relevant documents, paginated.
– Keep the tone firm but measured – you are helping the judge, not ranting.
– Send a copy of the complaint to LME and to Mr Ebrahim (care of Newlyn Plc) after filing, so nobody can say they were ambushed.
– Keep proof of postage and any email acknowledgements from the court.
That is the process. Once the complaint is lodged, it is up to the Hertford DJ to decide whether to list a hearing. The fact pattern here is strong enough that the court is likely to take it seriously.
Send the following response to LME immediately:
Subject: Immediate Return of Stolen Vehicle – Further Action Imminent
LME Services,
Your latest email confirms beyond any doubt that you have unlawfully seized my vehicle and are now attempting to justify it with a completely fabricated interpretation of the Torts Act. Let me be absolutely clear: everything you have done is illegal, and you are now in very serious trouble.
You have admitted in writing that you removed my vehicle without a warrant, without any judgment, and without any lawful enforcement authority. Your claim that the Torts (Interference with Goods) Act 1977 gives you power to seize goods is false. It is a blatant misrepresentation of the law and will be used as evidence of deliberate wrongdoing.
You also describe yourselves as “involuntary bailees”, which is an admission that you took possession of the vehicle without lawful authority. That is not bailment – it is conversion. It is an unlawful interference with goods. It is also a criminal offence under section 54 of the Protection of Freedoms Act 2012. The police have already accepted this and issued a crime reference number.
In addition, I have checked the enforcement agent register. Mr K. Ebrahim is certificated by Hertford County Court only in connection with his employment for Newlyn Plc. He is not authorised to carry out enforcement action for LME Services Ltd. Even if he were, he cannot lawfully seize any goods without a warrant of control — which does not exist. Acting outside the scope of his certificate is professional misconduct and I am now reporting him to Hertford County Court for abuse of his position.
Your claim that you can demand a “Removal Truck Fee” is absurd. You created that alleged charge by committing the unlawful act yourselves. Offering a “Christmas reduction” from £5,325 to £575 only proves you know you have been caught and are scrambling to minimise the consequences.
Here is what is going to happen:
1. You will immediately confirm the exact location of my vehicle.
2. You will immediately confirm that it will not be sold, damaged, or interfered with.
3. You will immediately return the vehicle to me.
4. You will cover the cost of returning it.
If you insist on demanding £575, understand that I regard that demand as further unlawful coercion. Because I require the vehicle for work, I may pay the £575 strictly under protest, solely to recover my property and mitigate loss. That payment will be used as further evidence of your illegal activities and will be recovered in full through the courts along with damages and costs.
If the vehicle is not returned immediately and in full, intact condition, I will:
– issue a County Court claim without further notice;
– seek an injunction and full damages;
– escalate my criminal complaint; and
– pursue all regulatory bodies involved.
You are now on notice. I expect a response today.
[Name]
[Address]
[Contact details]
As already mentioned, I have sought legal advice based on what we know. That advice (a District Judge no less) agrees that it is "theft". I have put the OP in contact with Jackson Yamba who has agreed to consider taking this on or at least referring it to a suitable solicitor to get an injunction against LME. So, real legal advice is on offer.
Back to my untrained but experienced knowledge that there is a very strong argument that what LME have done fits the Theft Act definition, but in law it is not quite as “pure and simple” as it feels, because of the way “dishonesty” works.
The legal test for theft under the Theft Act 1968 is:
1. Appropriation
2. Of property
3. Belonging to another
4. Dishonestly
5. With the intention of permanently depriving the other of it.
On the facts as we know them so far:
– LME have clearly appropriated property: they physically took the car and now control it.
– It is property, and it belongs to the OP.
– They are demanding a ransom and threatening to sell it. That is very strong evidence of an intention to permanently deprive the owner, or at least to treat the car as their own to dispose of regardless of the OPs rights (which also satisfies the Act).
So the only real legal argument is about “dishonesty”.
This is where it stops being “pure and simple”. Section 2 of the Theft Act says a person is not dishonest if they honestly believe they have a legal right to deprive the other of the property, even if that belief is unreasonable. LME will say: “We believed we had a legal right under the Torts (Interference with Goods) Act and under the contract with the landowner to remove and hold the vehicle for these debts.” That belief can be utterly wrong in law, but if a court or jury accepted that it was genuinely held, it defeats theft.
That is why my relative, the District Judge, quite reasonably describes it as “straightforward theft on the facts”: to an experienced judge it looks like exactly that – taking someone’s car with no lawful authority, keeping it until they pay, and threatening sale. But the criminal law still has to grind through the section 2 “honest belief” point. The police and CPS will often shy away from charging theft in civil-flavoured disputes because of that, even where a judge looking at it in the round calls it “obvious theft”.
Crucially, the PoFA offence does not have that complication. Section 54 PoFA and wrongful interference with goods/conversion in civil law do not turn on proving dishonesty; they turn on the absence of lawful authority and on possessory rights. Here, there is no judgment, no warrant, no statutory power. On that basis:
– It is almost certainly a criminal offence under section 54 PoFA.
– It is almost certainly a civil wrong in conversion/wrongful interference with goods.
– There is a powerful argument that it is also theft, but whether the police/CPS run with “theft” as the charge will depend on how much weight they give to the supposed “honest belief in a legal right”.
So: morally and practically, it looks and feels like theft. Legally, there is a strong case for theft, but it is not quite as clean-cut because of the way the honest-belief defence to dishonesty works. That is why it makes sense to keep pushing both angles with the police (theft and PoFA) while using conversion/wrongful interference and an injunction in the civil courts.