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 informationYou 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.
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 complaintThe 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.
