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Messages - NBSCMN

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1
Private parking tickets / Re: NCP Epsom Parking Charge
« on: February 03, 2026, 09:15:08 am »
thanks all. PCN cancelled

on points 1 and 2 .

2
Private parking tickets / Re: NCP Epsom Parking Charge
« on: January 27, 2026, 09:50:38 pm »
1. Failure to Specify the "Relevant Land" The Notice to Keeper (NTK) identifies the location of the alleged contravention as "Epsom High Street." However, the car park in question is not located on High Street; both the entrance and exit are situated on Station Approach. Under Schedule 4 of the Protection of Freedoms Act 2012 (PoFA), a notice must accurately specify the "relevant land" on which the vehicle was parked. By providing an incorrect location, NCP has failed to meet the strict requirements of PoFA 2012, and therefore cannot transfer liability for this charge to me, the registered keeper.

2. Non-Compliance with PoFA 2012 (Delivery Date) Furthermore, I challenge the validity of this notice regarding the timeline of service. For a notice to be PoFA-compliant where no ticket was fixed to the vehicle, it must be delivered to the keeper within 14 days of the incident. Given the date of the incident (03/01/2026) and the date of sending (14/01/2026), the notice did not arrive within the statutory 14-day window. This constitutes a further failure to meet the requirements necessary to invoke keeper liability.

3. Consideration Period and Lack of Contract The evidence provided shows a total stay of only 14 minutes. According to the BPA Code of Practice, operators must allow a sufficient "consideration period" for a driver to enter a car park, find a parking space, and read the terms and conditions on the signage to decide whether to stay. A 14-minute window is entirely consistent with a driver entering the site, finding the terms unacceptable or the site unsuitable, and subsequently exiting. No contract was ever entered into, and no parking "breach" occurred.

As NCP has failed to comply with the requirements of PoFA 2012 and the BPA Code of Practice, I request that this charge be cancelled immediately.

should i remove point 2 ?

3
Private parking tickets / NCP Epsom Parking Charge
« on: January 25, 2026, 11:09:47 am »
Hi,


What can I appeal for this?

https://imgbox.com/Q7QjYPvN
https://imgbox.com/L8J4lgjz

i think this was delivered around mon 19th but i think the notice is within the 14 day period as well if im not mistaken

date of incident 3/1
date of sending 14/1

can i appeal as:

strict proof of the date of actual sending based on the requirements of section 8.1.2(e) Note 2 of the PPSCoP which states:

Quote
The parking operator must ensure that a notice informs the recipient: that if the recipient appeals within 28 days of receiving the parking charge, the right to pay at the rate applicable when the appeal was made must stand for a further 14 days from the date (subject to 8.1.2d) they receive notification that their appeal has been rejected;

NOTE 1: Where the 14 days to pay was at the reduced rate a further 14 days should be offered to make payment at the full rate.
NOTE 2: A notice sent by post is to be presumed, unless the contrary is proved, to have been delivered on the second working day after the day on which it is posted; and for this purpose, “working day” means any day other than a Saturday, Sunday or a public holiday in England and Wales. Therefore, parking operators must retain a record of the date of posting of a notice, not simply of that notice having been generated (e.g. the date that any third-party Mail Consolidator actually put it in the postal system.)

4
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?


5
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?


6
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

7
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

8
❌ 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.

:(

9
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.

10
I can only see Ibrar Ahmad on that form. no one else

11
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

12
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


13
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.

14
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.



15
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.

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