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I, [Defendant’s Full Name], am the Defendant in this claim and make this statement in support of my defence. The facts in this statement are true to the best of my knowledge and belief.

Multiple Procedural Defects in the Claimant’s Case

2. The Claimant’s Particulars of Claim (PoC) and Witness Statement (WS) are both procedurally defective and should be given no weight due to their failure to comply with the Civil Procedure Rules (CPR) and the improper execution of their statements of truth.

3. The PoC fail to comply with CPR 16.4 and Practice Direction 16, paragraph 7.5. The Claimant had an obligation to fully particularise the claim at the time of issuing proceedings but failed to:

a) Set out the exact wording of the clause(s) of the terms and conditions relied upon.
(b) Adequately explain how the terms of the alleged contract were incorporated or why I am said to be in breach.
(c) Distinguish whether the claim is brought against me as the driver or the keeper.
(d) Provide a breakdown of how the total sum claimed has been calculated, including interest and alleged additional charges.

4. Despite the Claimant’s failure to adequately plead its case, the allocation judge did not order the Claimant to amend or clarify its PoC. The Claimant has since sought to introduce additional details via its Witness Statement, but this does not cure the defective PoC. A Witness Statement cannot remedy an inadequate statement of case, and this attempt to rectify procedural failings at a later stage is an abuse of process.

5. The PoC are signed by Sarah Ensall, described as the "Claimant’s legal representative," but there is no evidence that she is a solicitor or that she has the formal authorisation required under CPR 22.1 and Practice Direction 22 to sign a statement of truth on behalf of the Claimant.

6. CPR 22.1(6) and PD 22, paragraph 3.9, require that:

(a) If signed by a legal representative, they must be a solicitor or a person formally authorised by the Claimant.
(b) The signatory must be responsible for the conduct of the case.

7. Sarah Ensall is not a solicitor, and the Claimant has not provided evidence that she has explicit authorisation to sign statements of truth on behalf of Euro Car Parks. The Claimant must demonstrate that she has the required formal standing to sign the PoC. If she does not, the statement of truth is defective, and the PoC are procedurally invalid.

8. The same procedural failure applies to the Witness Statement, which is also signed by Sarah Ensall. She is not a direct witness with knowledge of the facts and has no first-hand evidence regarding the alleged parking event, the contract, or the issuance of the charge. Instead, the WS is based on hearsay, without a supporting statement from a Euro Car Parks employee who has direct knowledge of the facts.

9. The Witness Statement attempts to introduce new arguments and details that were absent from the PoC, including references to specific payment records, signage, and contract terms. However, this does not remedy the defective PoC and is an attempt to circumvent proper procedure.

10. The Claimant is a serial litigant represented by bulk litigation solicitors and should be fully aware of its obligations under the CPR. Despite this, it failed to properly plead its case at the outset and now seeks to correct its failings by introducing details at a later stage. This approach is unfair, unreasonable, and an abuse of process.

11. In light of these procedural defects, I submit that:

(a) The PoC are inadequately pleaded, do not comply with CPR 16.4, and should be struck out under CPR 3.4(2)(a) as disclosing no reasonable grounds for bringing the claim.
(b) The statement of truth on both the PoC and WS is defective, as the Claimant has not demonstrated that Sarah Ensall was properly authorised to sign on their behalf.
(c) The Witness Statement should be given no weight, as it is based entirely on hearsay and does not correct the failings in the PoC.
(d) The court should consider whether the Claimant’s conduct in issuing vague claims and relying on late evidence constitutes unreasonable behaviour, warranting a costs order under CPR 27.14(2)(g).

Misuse of CPR 27.9 (Absentee Representation and Advocate's Role)

12. The Claimant’s Witness Statement concludes with an assertion that my Defence is "entirely without merit" and requests that it be struck out. This is a baseless and presumptive statement that disregards the multiple procedural failings, misrepresentations, and legal deficiencies in the Claimant’s case that I have demonstrated throughout this Witness Statement.

13. The Claimant’s witness, Sarah Jennifer Helena Ensall, states that she "may not be able to attend the hearing" and that an advocate will attend on her behalf under CPR 27.9. However, this is a misuse of CPR 27.9, which specifically governs hearings where neither the party nor their representative appears in person. CPR 27.9(1) states that if a party does not attend a hearing, they may rely on their written representations only if they have given notice to the court and to me no later than seven days before the hearing and have filed and served all documents on which they intend to rely.

14. The key limitation of CPR 27.9 is that the party choosing not to attend is restricted to relying on their written statement and may not introduce new arguments or evidence via an advocate. If no representative of Euro Car Parks is physically present, I submit that their advocate must not be allowed to make submissions or introduce any further arguments beyond the contents of the Witness Statement. The advocate cannot cross-examine me or argue points beyond what is already written. If an advocate attempts to introduce new material, I will object on the basis that this breaches CPR 27.9.

15. Furthermore, there is no evidence that the witness has any direct knowledge of the alleged contravention, and the Witness Statement itself consists largely of hearsay. If the Claimant does not produce a genuinely informed representative who can be cross-examined, then I submit that the court should give little to no weight to the Claimants Witness Statement and dismiss the claim.

16. The Claimant also seeks to recover the advocate’s fee for attending the hearing, which is another procedural overreach. Given that this is a small claims track case, I submit that costs are strictly limited under CPR 27.14. The attendance of an advocate is not a recoverable cost, and this request should be dismissed.

17. In light of this, if no Euro Car Parks representative is physically present, their advocate must not be permitted to introduce new arguments beyond the Witness Statement, and any attempt by the advocate to cross-examine me or make oral submissions beyond the Witness Statement should be challenged as a breach of CPR 27.9. The advocate’s fee must not be awarded, as it is not a recoverable cost under CPR 27.14.

The Claimant’s Non-Compliance with the BPA Code of Practice

18. The Claimant’s Witness Statement at paragraph 5 asserts that they are an accredited member of the British Parking Association (BPA) and operate in accordance with the BPA Code of Practice (CoP). However, this statement is demonstrably false, as the Claimant’s own evidence proves multiple breaches of the BPA CoP (Version , which was in effect at the time of the alleged contravention.

19. The Claimant’s witness further states that the BPA has a Code of Practice that its members are expected to adhere to, or otherwise face potential sanctions. This assertion is inherently untrue. BPA membership does not automatically mean compliance, and the BPA rarely enforces meaningful sanctions against its members, even when serious breaches occur. In this case, the evidence provided by the Claimant itself proves non-compliance with multiple sections of the BPA CoP.

20. The lack of compliant signage is evident from the Claimant’s own exhibits. The Claimant’s witness, Sarah Ensall, falsely claims adherence to the British Parking Association (BPA) Code of Practice (CoP) while simultaneously submitting non-compliant signage as evidence.

21. The Claimant’s evidential photos of signage at the location, found in Exhibit 2 of their Witness Statement, predominantly depict signs that contain no contractual terms whatsoever. These signs are either instructional, directional, or otherwise irrelevant to the formation of a contract with motorists. The only sign that purportedly contains any contractual terms is found at pages 46, 48 and 50 of the Claimant’s Witness Statement. However, this sign is almost impossible to read due to its poor positioning and excessive use of small print. It is mounted high on a pole, making it difficult for any driver to meaningfully engage with, particularly in low-light conditions.

22. Furthermore, the core contractual term—the parking charge amount for a breach—is buried within a wall of tiny text, in direct contravention of the requirements set out in ParkingEye Ltd v Beavis [2015] UKSC 67, which emphasised the need for prominent, clear, and legible signage. In Beavis, the Supreme Court upheld the parking charge on the basis that the £85 charge was clearly and prominently displayed on a sign that was simple, highly visible, and capable of conveying the essential contractual terms at a glance. The Claimant’s signage in this case bears no resemblance to the signage in Beavis and fails to meet the same legal standard.

23. This is further evidence of non-compliance with the BPA Code of Practice, which at Section 19.3 states:

"Signs must be conspicuous and legible, and written in intelligible language, so that they are easy to see, read and understand."

24. The Claimant’s signage is neither conspicuous nor legible, and the terms and conditions are not easy to read or understand, making it impossible for a motorist to enter into a fair and informed contractual agreement. I submit a comparison between the Claimant’s signage and the signage in the Beavis case as Exhibit [XX-01], to demonstrate the clear inadequacy of their signage and their failure to meet both contract law principles, the mandatory BPA CoP requirements and the requirement in PoFA 2(2) which states: "The reference in the definition of “parking charge” to a sum in the nature of damages is to a sum of which adequate notice was given to drivers of vehicles (when the vehicle was parked on the relevant land)."

25 The Claimant’s own exhibits contradict their claim of compliance with the BPA CoP. This demonstrates that the witness lacks direct knowledge of the facts and that their statement is unreliable, misleading, and hearsay.

26. While there are further failures of compliance with the BPA CoP, which will be addressed later in this Witness Statement, the above breaches alone are irrefutable proof that the Claimant does not adhere to the BPA CoP, rendering paragraph 5 of the Claimant’s Witness Statement wholly unreliable and untrue.

The Claimant’s Unlawful Access to DVLA Data

27. The Claimant’s Witness Statement at paragraph 6 asserts that compliance with the BPA Code of Practice is essential for the Claimant to obtain Registered Keeper details from the DVLA under Regulation 27 of the Road Vehicles (Registration and Licensing) Regulations 2002. The witness further claims that the Claimant "complies in all regards" with the BPA Code, thereby satisfying the requirements for accessing DVLA data.

28. This statement is demonstrably false. As already established in this Witness Statement, the Claimant does not comply with the BPA Code of Practice, as evidenced by their own signage. Since full, strict compliance with the BPA Code of Practice is a fundamental condition of the Keeper At Date Of Event (KADOE) contract between private parking operators and the DVLA, the Claimant’s access to DVLA data is unlawful.

29. The KADOE contract explicitly states that an operator must adhere to the BPA Code of Practice in its entirety as a condition of being granted access to Registered Keeper data. Any failure to meet the requirements of the Code, including but not limited to inadequate signage, misleading contractual terms, or procedural breaches, invalidates an operator’s lawful basis for requesting and processing keeper details from the DVLA.

30. The evidence provided by the Claimant itself proves that its signage does not meet the requirements of the BPA Code. As such, the Claimant has unlawfully accessed my data in contravention of the KADOE contract, which constitutes a breach of the Data Protection Act 2018 and UK GDPR, as it obtained and processed my personal data without a lawful basis.

31. The claim that the Claimant "complies in all regards" with the BPA Code is therefore untrue, and the Claimant’s entitlement to obtain, retain, and use my data is in serious doubt.

32. Further breaches of the BPA Code of Practice will be detailed later in this Witness Statement, reinforcing the fact that the Claimant has no lawful right to process or use my personal data for the purposes of issuing or pursuing this claim.

The Claimant Falsely States Issue Dates

33. The Claimant’s Witness Statement at paragraph 7 falsely states that the Parking Charge Notice (PCN) was "issued" on 18/12/2021. However, the Claimant’s own evidence, shown in their Exhibit 6, proves that the Notice to Keeper (NtK)—which constitutes the formal issuance of the parking charge—was in fact issued on 23/12/2021.

34. This is a deliberate misrepresentation of the facts, as the NtK is the formal notice that initiates enforcement action against the Registered Keeper. The Claimant’s assertion that the charge was "issued" on 18/12/2021 is demonstrably false, and it is unclear whether this is due to gross negligence or an intentional attempt to mislead the court.

35. This mendacious statement was also included in the Particulars of Claim, meaning that the Claimant has knowingly submitted incorrect information at multiple stages of these proceedings. This is a blatant breach of CPR 16.4, which requires the Claimant to provide a concise and accurate statement of the facts upon which they rely.

36. Given that the Claimant’s own documentary evidence contradicts their Witness Statement and Particulars of Claim, it is clear that the statements made by their witness are unreliable and untrustworthy. This further supports the contention that the Claimant’s case is based on procedural defects, misrepresentations, and abuse of process.

The Claimant’s Failure to Prove Landowner Authority

37. The Claimant’s Witness Statement at paragraph 8 asserts that they have a valid contract with the landowner authorising them to issue Parking Charge Notices (PCNs). However, the contract provided in their Exhibit 1 is so heavily redacted that it is meaningless and constitutes a clear abuse of process.

38. The document is so extensively redacted that it fails to confirm the identity of the contracting parties, the date of the agreement, the scope of authority granted, or even the names, positions, and authority of the signatories. Without this key information, the Claimant has provided no admissible evidence that they have landowner authority, which is a fundamental requirement for bringing this claim.

39. This excessive redaction contravenes CPR 31.6, which requires disclosure of documents relied upon in proceedings. The absence of an unredacted contract means there is no verifiable evidence that the Claimant has the locus standi to pursue this claim.

40. A parking operator must have clear landowner authority to issue and enforce parking charges. This was confirmed in ParkingEye Ltd v Somerfield Stores Ltd [2012] EWCA Civ 1338, where the Court of Appeal emphasised that authority must be demonstrated through an unambiguous contract. The Claimant’s contract is so heavily redacted that it is impossible to verify whether they have such authority.

41. The redacted contract does not allow the Defendant or the court to verify that the Claimant has the right to operate at the site, issue charges, or pursue legal action in its own name. The Claimant’s failure to provide an unredacted contract means there is no proof that they were authorised to act at the time of the alleged contravention.

42. The level of redaction in their Exhibit 1 is wholly unreasonable. Even security services disclose less heavily redacted documents under the Official Secrets Act. It is improper for the Claimant to expect the court to accept such an incomplete and unverifiable document as proof of their legal standing.

43. Given that the Claimant has failed to comply with CPR 31.6, Practice Direction 16, paragraph 7.5, and established case law, I submit that this claim should be dismissed due to the Claimant’s failure to provide fundamental evidence of their authority.

44. If the Claimant has submitted an unredacted version of the contract to the court while withholding it from me, this would constitute a clear breach of fairness and transparency in legal proceedings, violating CPR 31.14, which entitles a party to inspect a document mentioned in a statement of case.

45. The Claimant’s refusal to disclose an unredacted contract suggests either (a) the contract does not contain the necessary authority for them to issue PCNs and pursue legal action, or (b) they are attempting to restrict my ability to scrutinise the agreement, gaining an unfair procedural advantage. Either scenario is an abuse of process that should not be tolerated by the court.

46. In light of the above, I submit that the Claimant has failed to establish that it has landowner authority, has engaged in procedural misconduct, and that this claim should be dismissed in its entirety.

The Claimant’s Misuse of Case Law on Landowner Authority

47. The Claimant’s Witness Statement at paragraph 9 states, "I am advised by the Claimant, that the Landowner Agreement has been extended by mutual consent of the parties." This statement is purely hearsay and provides no actual evidence that a valid contract was in force at the time of the alleged contravention.

48. The Claimant’s reliance on One Parking Solution Ltd v Wilshaw [2021] is misplaced. That case does not establish a general rule that landowner authority is irrelevant, nor does it override the requirement for a Claimant to prove its legal standing when challenged.

49. In Wilshaw, the operator’s landowner authority was not disputed. By contrast, in this case, the Claimant’s own redacted and undated contract raises serious doubts as to whether they had authority to issue PCNs at the time of the alleged contravention. The absence of an unambiguous contract distinguishes this case from Wilshaw, making the Claimant’s reliance on it inappropriate. The Claimant cannot rely on Wilshaw to bypass the need to prove its standing where it has been actively challenged

50. The Claimant cannot cite Wilshaw to bypass the fundamental requirement to prove its standing, especially when this issue has been actively challenged. Without clear, unredacted evidence of landowner authority, the claim cannot succeed.

51. As the Claimant has failed to provide admissible proof that it had the authority to operate at the site on the relevant date, no valid contract could have existed between the Claimant and the Defendant. Consequently, the claim must fail.

52. The Claimant has failed to provide clear, unredacted evidence that it had authority to operate at the site on the relevant date. Without such proof, no valid contract with the Defendant could have existed, and the claim must fail.

No Contract Was Formed Due to Signage and Machine Failures

53. I deny the Claimant’s assertions in paragraphs 11 to 16 of their Witness Statement regarding the alleged contract. I did not knowingly agree to any contract with the Claimant, nor did I breach any stated terms.

54. I attempted to pay for parking at the site but was unable to increase the duration of stay due to what I believe was a fault with the payment machine. The machines were also positioned in a poorly lit area, and at 9 PM in December, visibility was extremely poor. I could barely see what I was pressing, which made it difficult to ensure that the correct payment had been made.

55. The fundamental basis of a contract is mutual agreement, which requires a clear offer and unambiguous acceptance. Given that the signage was already incapable of forming a contract, as previously discussed, and that the payment process was hindered by external factors beyond my control, no legally binding agreement could have been formed.

56. The Claimant has provided no evidence that the payment machine was functioning correctly at the time or that it was sufficiently illuminated for drivers to reasonably interact with it. Without proof that a valid contract was entered into, the claim cannot succeed.

The Claimant’s Misrepresentation of Liability Under PoFA

57. The Claimant’s Witness Statement, under the section titled "Defendant’s Liability", covering paragraphs 17 to 20, contains further breaches of both the BPA Code of Practice (CoP) and the Protection of Freedoms Act (PoFA) 2012.

58. In paragraph 17, the Claimant’s witness falsely states that "Pursuant to the Contract; the Driver was liable to pay the Parking Charge within 28 days of issue." This is incorrect and contradicts both the BPA CoP and PoFA.

59. The BPA CoP, section 21.11, explicitly states that the Notice to Keeper (NtK) does not impose immediate liability on the keeper but serves three purposes:

• It invites the keeper to pay the unpaid parking charge.
• It invites the keeper to identify the driver if they were not the driver.
• It starts the 28-day period after which the keeper may become liable, but only if the operator fully complies with PoFA.

60. The BPA CoP, section 21.12, further confirms that an effective Notice to Keeper must meet the requirements of PoFA Schedule 4. The Claimant’s witness has completely misstated the legal position, as PoFA does not make the driver or keeper liable within 28 days of "issue", but instead follows the specific statutory timelines set out in Schedule 4.

61. PoFA Schedule 4, Paragraph 9(2)(f) states that the 28-day period begins from the day after that on which the notice is "given", not from the date of "issue".

62. PoFA Schedule 4, Paragraph 9(6) then defines when a notice is "given." A notice sent by post is presumed to have been delivered on the second working day after it was posted, unless the contrary is proved. For these purposes, a "working day" excludes Saturdays, Sundays, and public holidays in England and Wales.

63. This position was later reinforced in the latest BPA/IPC Private Parking Single Code of Practice, section 8.1.2(e), which states that the recipient has 28 days to appeal from the date of "receipt", not from the date of "issue".

64. The Claimant’s witness, who has already demonstrated a lack of direct knowledge of the facts, is once again making false statements that contradict the statutory framework of PoFA and the BPA CoP. These errors, whether due to negligence or an intentional attempt to misrepresent the facts, render the Claimant’s Witness Statement unreliable and untrustworthy.

65. Given that the Claimant’s witness has now provided multiple contradictory and misleading statements, their entire testimony should be treated with significant doubt, and the claim itself must be called into question.

The Claimant’s Attempt to Rectify Defective Pleadings via the Witness Statement

66. The Claimant’s Witness Statement, under the sections titled "Defence" and "Amount Claimed" (paragraphs 21 to 32), attempts to retrospectively introduce new details and justifications that were absent from the original PoC. However, as already established in paragraphs 2-11 above, a Witness Statement cannot remedy defective pleadings.

67. The Claimant asserts that I was afforded a 28-day appeal period but failed to engage with it. However, my decision not to participate in a voluntary and non-statutory appeals process has no bearing on my liability. The appeals process run by unregulated private parking operators does not override legal rights, and a motorist cannot be penalised for choosing to defend themselves in court rather than engaging with an unregulated system.

68. The Claimant further argues that I had the opportunity to challenge the charge after receiving debt collection letters and a Letter of Claim. This is irrelevant. Debt collection letters are not legal determinations of liability, and ignoring them does not equate to acceptance of the claim. Furthermore, the Parking On Private Land Appeals service (POPLA), associated with BPA operators, has been widely criticised for its lack of impartiality, rendering the Claimant’s argument baseless.

69. The Claimant asserts that I breached the contract by overstaying the paid parking period. However, I have already provided evidence that my ability to comply with the alleged terms was hindered by a faulty payment machine and inadequate lighting at the time of payment. The Claimant’s WS does not address these issues or provide any evidence that the payment system was fully operational at the time.

70. The Claimant relies on their Exhibit 2 to prove contractual agreement. However, their signage fails to meet the required standards to form a legally binding contract. The charge for breach was buried in a block of small, unreadable text, failing the principle of "prominent and transparent" terms established in ParkingEye Ltd v Beavis [2015] UKSC 67. Additionally, the Claimant has not provided evidence of a compliant entrance sign, contrary to the BPA Code of Practice (v8) Section 19.2, which mandates clear entrance signage.

71. The Claimant attempts to justify the inadequacy of their PoC by referring to Practice Direction 7C, Section 5.2(1) and 5.2A. However, while these rules permit brief particulars of claim in money claims, they do not absolve the Claimant of the obligation to provide sufficient detail under CPR 16.4. The Claimant had the opportunity to submit Further and Better Particulars but chose not to do so. A defective PoC cannot be retrospectively rectified through a Witness Statement.

The £100 Charge and Additional £70 Are Unenforceable

72. The Claimant asserts that the £100 parking charge is justified under ParkingEye Ltd v Beavis [2015] UKSC 67. However, Beavis concerned a free stay car park, where the charge was upheld as a necessary deterrent to ensure turnover of spaces for retail customers. This rationale does not apply to a pay-and-display car park, where an operator is expected to charge in proportion to actual loss or operational costs. The Claimant has failed to provide any breakdown of its costs to justify this amount in a pay-and-display setting.

73. The Claimant further relies on signage to establish that a contract was formed, yet the signage evidence provided does not meet the required legal standards. The terms are buried in a block of small, unreadable text, and there is no evidence that an entrance sign was in place or clearly visible at the material time. The Supreme Court in Beavis made clear that contractual terms must be "prominent and transparent", yet the key terms relied upon by the Claimant fail to meet this standard.

74. In a pay-and-display setting, a motorist must be given a fair opportunity to read and understand the contractual terms before being bound by them. The burden is on the Claimant to prove that this was the case. Given the deficiencies in the signage and the lack of clarity regarding how the charge arises, I submit that no valid contract was formed.

75. Furthermore, the Claimant has not provided evidence that the payment system was fully operational at the time. I have already presented evidence that my ability to comply with the alleged terms was hindered by a faulty payment machine and inadequate lighting. A contract cannot be enforced where compliance was made impossible due to the Claimant’s own failures.

76. In light of the above, I submit that no enforceable parking contract was formed, and the claim should be dismissed on this basis alone.

77. The Supreme Court in ParkingEye Ltd v Beavis [2015] UKSC 67 made it clear that the parking charge itself must cover all operational costs, including enforcement. At paragraph 98, Lord Neuberger and Lord Sumption stated:

"One [purpose of the charge] was to manage the efficient use of parking space in the interests of the retail outlets, and of the users of those outlets who wish to find spaces in which to park their cars… The other purpose was to provide an income stream to enable ParkingEye to meet the costs of operating the scheme and make a profit from its services, without which those services would not be available."

78. Similarly, at paragraph 193, Lord Hodge confirmed:

"The scheme gave BAPF through ParkingEye’s weekly payments some income to cover the costs of providing and maintaining the car park. Judging by ParkingEye’s accounts, and unless the Chelmsford car park was out of the ordinary, the scheme also covered ParkingEye’s costs of operation and gave their shareholders a healthy annual profit."

79. These statements establish that all necessary operational costs—including those associated with enforcement and recovering unpaid charges—are already incorporated within the parking charge itself. The Claimant’s attempt to impose an additional £70 fee is therefore an abuse of process, as it constitutes an attempt at double recovery. This improper practice has been repeatedly struck down in multiple County Court judgments, including Excel Parking v Wilkinson [2023] and Britannia Parking v Semark-Jullien [2020].

80. The Claimant attempts to justify the additional £70 charge by citing Chaplair Ltd v Kumari [2015] EWCA Civ 798, claiming it allows contractual indemnity costs. However, this is a misrepresentation of the case. Chaplair concerned a tenancy agreement with an explicit indemnity clause, which has no relevance to a private parking contract where no such clause exists.

81. The Claimant further attempts to reserve the right to claim additional costs under CPR 27.14(2)(g), suggesting that I have acted unreasonably. However, it is the Claimant who has acted unreasonably by:

• Failing to provide adequate Particulars of Claim in breach of CPR 16.4.
• Failing to provide an unredacted contract to prove landowner authority.
• Misrepresenting PoFA compliance regarding keeper liability.
• Attempting to recover an additional £70 despite clear Supreme Court and County Court rulings to the contrary.

82. If any party has acted unreasonably, it is the Claimant in bringing a claim riddled with procedural defects, misrepresentations, and excessive charges. The attempt to inflate the claim with an unlawful £70 sum alone constitutes an abuse of process and should not be allowed.

83. Given that courts have consistently ruled against the addition of arbitrary sums such as £70, I submit that the court should strike out the added charge as an unrecoverable sum. In light of the above, I request that:

(a) The additional £70 charge be struck out as an abuse of process.
(b) The Claimant’s reliance on Chaplair v Kumari be dismissed as irrelevant.
(c) The claim, being procedurally and substantively flawed, be dismissed in its entirety.

Conclusion: The Claim Should Be Dismissed

84. The Claimant has made numerous procedural defects, failed to establish landowner authority, has submitted vague and defective Particulars of Claim, has attempted to circumvent proper procedure by relying on a Witness Statement to introduce new arguments, and has sought to recover sums that courts have consistently ruled to be an abuse of process.

85. Given the serious procedural defects, misrepresentations, and abuse of process in this case, I respectfully request that the claim be dismissed in its entirety.