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Messages - NBSCMN

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1
the is the only PCN we have.

and for the date, is it 14 working days - so should be 16/1 instead of 13/1?


2
here is the route

https://imgpile.com/p/4C6TGYS


the only permit sign that was visible was (51.4905936, -0.1494346)

this sign is quite far from the parking area surely?


3
hi and merry christmas.

https://imgpile.com/p/0ifO4qL

posting on behalf of a friend.

they parked at https://maps.app.goo.gl/3Rgzm3yJBXcjy79v7?g_st=ipc

in the bays, the sign says permit holders until 10pm, they parked on a single yellow. I have looked around on the area and there is not a sign that tells you if you can park at specific times on a single yellow.

the link on the westminster parking page states:

Sat, 27 Dec 2025 11:57:44 - No Valid Permit or Paid for Parking Found

the pictures given also do not show the permit sign or any other sign.

can this be contested? thanks

4
Thank you. It's quite unfortunate that NCP can have legal representation that does not bother to come to the hearing and yet still win the case.

With the payment, i've attached the letter. I want to double check this will still register a CCJ to my name, just as I am universal credit so I would rather pay monthly if possible but I definitely dont want a CCJ for 6 years

If i were to pay upfront, I would need to contact moorside to get bank information? as there is nothing on the letter.

https://ibb.co/9kbtbt4g

thanks

5
❌ LOST HEARING REPORT: - October 8th, 2025

Outcome: Judgment for the Claimant (NCP). Ordered to pay £280 over 12 months.
Claimant Attendance: No one from NCP or Moorside Legal attended the hearing.

Summary of the Hearing

1. Claimant Non-Attendance & Initial Comments:

  • The hearing proceeded with only myself and the Judge, as the Claimant's representative (Moorside Legal) did not attend.
  • The Judge stated that Moorside should have sent an email notifying non-attendance, but I confirmed I had received no such communication.
2. Procedural & CPR Arguments (Defense Main Focus):

  • Defective Particulars of Claim (PoC): I argued the PoC failed to provide key details, including the sum breakdown and the contract wording.

    • Judge's Ruling: The Judge rejected this, stating that all the missing specific wordings and necessary details were cured by being included in the Witness Statement (WS). She was satisfied the WS mentioned I was pursued as the keeper, the nature of the breach, and the wording of the contract.
  • Case Law (CEL v Chan / CPMS v Akande): I cited these cases where identical PoC failures led to strike-outs.

    • Judge's Ruling: The Judge stated these were County Court decisions and were therefore not binding on her court, and she would not consider them.
  • Failure to File a Motion to Strike: The Judge noted that my arguments were procedural, but I had not formally filed a separate motion/application to strike out the claim. This significantly undermined the procedural point.
3. Solicitor Misconduct & Regulatory Arguments:

  • SRA Reports / Mazur Issue: I raised the Mazur point regarding Ms. Safina Zubair having conduct and the SRA report regarding the use of Mr. Ibrar Ahmad's name (a solicitor from another firm).
    • Judge's Ruling: The Judge dismissed this entirely, stating that the SRA report was irrelevant to this hearing. Regarding Mr. Ahmad, she found it "very likely" he worked for Moorside when the claim was filed seven months ago and has since moved firms, and she would not accept my lack of proof to the contrary.
  • N180 Form & Tom Clough: I mentioned the N180 form being signed only by 'Moorside Legal' and the contradictory information about Mr. Tom Clough having conduct.
    • Judge's Ruling: The Judge did not comment or give weight to these specific points.
  • Relief from Claimant's Costs: I asked for the Claimant's fixed costs to be relieved due to their conduct issues.
    • Judge's Ruling: This was rejected.
4. Factual Arguments (Parking):

  • Denial of Driver / 13 Minutes: I mentioned I was not the driver and the vehicle was only present for 13 minutes.
    • Judge's Ruling: The Judge did not consider these points to be material.
  • Signage: The Judge showed photos of the signage.
    • Judge's Ruling: The Judge found the signage to be "legible enough to be read," which satisfied the requirement for forming a contract.
5. Conclusion:
  • The Judge concluded that my case was "not very well defended."
  • Order: I was ordered to pay £280 to the Claimant over a 12-month period.


I feel quite defeated to be honest. I didn't have a great understanding of my case and the judge was asking difficult questions which I couldn't answer. Law is not my speciality and I believe this made me lose the case.

This has put me off any appealing any other fines I may get to be honest as from the information I was given it seemed that this case was very easily won, but the outcome was very different.

:(

6
Thank you ive done all that. Can you please see if this plan below is good for tomorrow?

SMALL CLAIMS HEARING PLAN (NCP PCN) DATE: OCTOBER 8TH

1. Opening Statement

"Your Honor, I maintain this claim is fundamentally flawed and discloses no reasonable cause of action due to the Claimant's failure to comply with the Civil Procedure Rules and issues of solicitor misconduct."

2. Core Legal Defence: CPR Non-Compliance (Priority 1)

  • The Claimant's Particulars of Claim fail to meet CPR 16.4(1)(a).
  • The claim is defective because it fails to state:
    • The exact wording of the contract I am alleged to have breached.
    • The precise nature of the breach.
    • Whether I am being pursued as the driver or the keeper.
  • I rely on the persuasive judgments in CEL v Chan and CPMS v Akande, which confirm that claims with these flaws must be struck out (dismissed).

3. Improper Conduct & Regulatory Issues (Priority 2)

  • The Mazur Issue: The Claimant's paralegal, Ms. Safina Zubair, stated in her Witness Statement that she "has conduct of this matter." This contradicts the High Court ruling in Mazur & Anor v CRS LLP, which makes conduct by a non-authorised person improper.
  • The Claim Form Issue: The Claim Form was issued under the name of Mr. Ibrar Ahmad, who is registered with the SRA as a solicitor at a different firm (Osbourne Pinner Ltd), not Moorside Legal. I have reported this to the SRA.
  • Summary: This constitutes a pattern of unreasonable conduct in proceedings.

4. Conclusion and Request

  • Primary Request: I respectfully request that the Court strike out this claim pursuant to CPR 3.4(2)(a) and (b).
  • Costs Request (If Successful): I ask for my costs under CPR 27.14(2)(g) for the Claimant's unreasonable conduct, referencing the Costs Note I provided.
  • Costs Request (If Unsuccessful): I ask that I be relieved of the Claimant's costs due to their documented history of improper conduct.

7
I can only see Ibrar Ahmad on that form. no one else

8
Thank you.
I have also now just now received an email for Moorside



Quote
Thank you for your email.

We acknowledge your concerns and note that you have submitted a report to the SRA. We now respond to your queries as follows:

        1. Tom Clough, a solicitor qualified to conduct litigation in England and Wales, has conduct of this matter.

        2. The cover letter was drafted and sent by Safina Zubair, a paralegal assisting with the matter. All litigation decisions have been made by Tom Clough, as noted above.

        3. We confirm that all reserved legal activities have been carried out by an authorised person.

We trust this addresses your queries. Should you require any further clarification, please do not hesitate to contact us.

Kind regards

Safina

9
SRA form was sent on 30/9

No emails received from any party yet. Can anyone give me guidance on what I need to do for my hearing this Wednesday please

Thank you


10
Thank you for this. I have done all but completed the SRA form, I need to confirm the dates and upload the documents which I will when I get home from work today.

11
I still haven't received a reply from Moorside/

I've sent a chase up email today but their auto email said they reply within 5 days which they havent.



12
Hello

I have sent that email to moorside.

I have also called to see if the trial fee has been paid and they told me that there is no logs to confirm payment has been made however it may be still processing and that I should assume it has been paid unless I am notified otherwise.

13
`Safina Zubair

--- signed the witness statement 


and 

Ibrar Ahmad  signed the N1SDT claim

The N180 copy that was sent to me was just signed by 'Moorside Legal'


I cant seem to find anything else at the moment. I will contact the court tomorrow.

https://imgur.com/a/i58L2WF

14
The first thing you ask is whether there trial fee has been paid by the claimant. If it has, this means that there is still a possibility that the hearing will go ahead. However, Moorside Legal are known to discontinue 24 hours before the hearing date. If they do, you will be able to ask for costs.

Due to a very recent High Court appeal case which is binding on the lower courts, it has been found that paralegals/non-admitted staff cannot conduct litigation merely because their firm is authorised; they may only support an authorised litigator. SO, we need to see the names of every person that has signed anything or written to you since the claim was issued.

Any person conducting litigation without the prior authorisation is committing a criminal offence. So, who signed the N1SDT Claim Form with the PoC, the N180 DQ, their Witness Statement and anything else that has been corresponded to you since the claim was issued. This firm of utter incompetents masquerading as a bilk litigator, will get their comeuppance soon.

Where on earth is the first page of their WS with points 1-4 and where is the Statement of Truth (SoT)? You should have shown EVERY page of their WS, especially if it contains a name or a signature!!!

Please answer the above questions first.



the first page of the WS i reuploaded the document as per my previous message

https://drive.google.com/drive/folders/1-pRIcabSZ1m8F1e1dPJrjjQzKZNlSpza

15
Hello,

My hearing is coming up on 8th October and I am trying to fully understand to get a good idea of what to say during the hearing as this sort of information is quite confusing.

In a previous letter I received on 20/5/25 it states:

Quote
Unless the claimant does by 4 pm on the 10th of September 2025 pay to the court the trial fee of £27 or file a properly completed application  (i.e. one which provides all the required information in the manner requested) for help with fees then the claim will be struck out with effect from 10th of September 2025 without further order and unless the court orders otherwise you will also be liable for the costs which the defendant has incurred

Should I have received a letter saying the hearing has been struck out by now?

And any sort of pointers or tips please for the hearing!

I have got the following from AI mind u:

The Claimant's Particulars of Claim fail to disclose a reasonable cause of action as required by Civil Procedure Rule 16.4(1)(a). The claim is inadequately pleaded."

List the specific failings: Explain what is missing from their claim. Use a list to make your points clear and easy to follow:

  • They haven't stated the exact terms of the contract I supposedly breached.
  • They haven't explained how I am alleged to have breached it.
  • The claim does not clarify if I am being sued as the driver or the keeper of the vehicle.
  • They have not provided a breakdown of how the claimed sum is calculated.
Reference case law: This adds significant weight to your argument. Mention that similar cases have been struck out. "This isn't a technicality. The court has repeatedly held that such claims are deficient. I have referenced the persuasive appellate decisions of CEL v Chan and CPMS v Akande in my defense, where similar claims were struck out for these very same reasons."
2. Addressing the Claimant's Evidence

  • Critique their WS: Point out the shortcomings of their witness statement. "The Claimant's Witness Statement does not cure the deficiencies of their original claim. It's drafted by a paralegal and is not a first-hand account of the events. It's a templated document that simply repeats the same inadequacies as the Particulars of Claim."
  • The 13-minute stay: The claimant's evidence mentions the vehicle was on-site for 13 minutes. You should have a plausible explanation ready. "The driver's presence for only 13 minutes suggests they may have been seeking to find parking or payment options before deciding to leave. This is not evidence of a breach of a contract, especially with a lack of clear and accessible signage.


Concluding Remarks

  • Reiterate your position: "The Claimant has failed to provide the necessary details for a valid claim. Their case is an abuse of process and has no reasonable prospect of success."
  • State your request: "I respectfully request that the court strike out the claim pursuant to CPR 3.4(2)(a) and (b)."



I am worried that if the judge asks me 'why' for any of these statements then I have no idea how to explain the points.

Also, is it likely they could bring up the previous PCNs that I have received from them as per their WS? They have been cancelled now, but do I need a good defence for this?


Thanks

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