OK. This is what you must do now...
Once you have filled in any placeholders with the necessary details/dates, you send them as PDF files attached to an email addressed to the court and CC'd to the claimant and yourself. Make sure that every page is numbered (paginated).
This is the detail you must put in the email. It should be addressed to enquiries.watford.countycourt
@justice.gov.uk and CC'd to enquiries@gladstonessolicitors.co.uk and to yourself.
Subject: URGENT – Relief from Sanctions & Late WS – Claim no.: L1GF6N4R Private Parking Solutions (London) Ltd v Maira Munir – Hearing 25/09/2025
Dear Civil Listings Team,
I am the Defendant. I respectfully apply for relief from sanctions and permission to rely on my witness statement and exhibits served today.
• I was out of the country until 9 September 2025. While I was away, the Claimant’s WS bundle (cover letter dated 28 August 2025) was delivered. I first saw it on 9 September 2025.
• I did not receive the Notice of Allocation and therefore did not know the WS deadline. I obtained a copy from the court on 22 September 2025 and have acted promptly since then.
• I apologise for the late service.
Attached: (1) Defendant’s WS (paginated); (2) Relief-from-Sanctions statement (CPR 3.9; Denton); (3) Draft Order; (4) Proof bundle (travel evidence; court email dated 22 Sept).
I have served the Claimant’s solicitors by email at the same time.
Yours faithfully,
Maira Munir, Defendant
[Address] | [Email] | [Mobile]
You then create the following PDFs and include them in the bundle:
IN THE COUNTY COURT AT WATFORD
Claim No.: L1GF6N4R
Between: Private Parking Solutions (London) Ltd – Claimant
and
Maira Munir – Defendant
Relief from sanctions (CPR 3.9; Denton v TH White)
1. My witness statement is late against the small-claims timetable, but admitting it will not derail the hearing on 25 Sept 2025. The Claimant has my bundle at the same time as the Court.
2. I was abroad until 9 Sept 2025. The Claimant’s WS bundle (cover letter 28 Aug 2025) arrived during my absence. I did not receive the Notice of Allocation and only obtained a copy on 22 Sept 2025, after which I acted immediately.
3. I have acted promptly and in good faith. My evidence responds to matters first seen on 9 Sept. Granting relief best serves the overriding objective (CPR 1.1) by enabling the Court to deal with the real issues fairly and proportionately.
I apologise to the Court and the Claimant for the late service.
Also, the following draft order:
IN THE COUNTY COURT AT WATFORD
Claim No.: L1GF6N4R
Between: Private Parking Solutions (London) Ltd – Claimant
and
Maira Munir – Defendant
DRAFT ORDER
UPON the Defendant’s application for relief from sanctions and permission to rely on late evidence, and upon reading the Defendant’s statement dated [date]:
1. The Defendant is granted relief from sanctions pursuant to CPR 3.9.
2. The Defendant’s witness statement and exhibits served on [date sent] are admitted for the hearing listed on 25 September 2025.
3. Costs reserved/No order as to costs.
Signed: Maira Munir
Defendant
Date: 23 September 2025
Another PDF:
IN THE COUNTY COURT AT WATFORD
Claim No.: L1GF6N4R
Between: Private Parking Solutions (London) Ltd – Claimant
and
Maira Munir – Defendant
Certificate of Service
I, Maira Munir, certify that on 23 September 2025 I served the attached witness statement and exhibits, relief-from-sanctions statement, and draft order by email to:
• Court: enquiries.watford.countycourt@justice.gov.uk
• Claimant’s solicitors: enquiries@gladstonessolicitors.co.uk
Signed: Maira Munir
Date: 23 September 2025
And finally the WS:
IN THE COUNTY COURT AT WATFORD
Claim No.: L1GF6N4R
Between: Private Parking Solutions (London) Ltd – Claimant
and
Maira Munir – Defendant
1. I, Maira Munir, of [Address], am the Defendant. I make this witness statement from my own knowledge and belief except where I indicate otherwise, in which case the facts are true to the best of my information and belief and I identify the source.
2. Late service and apology. I apologise to the Court and to the Claimant for serving this statement close to the hearing. I was out of the country until 9 September 2025. While I was away, a package containing the Claimant’s witness statement bundle was delivered. I only became aware of it on my return on 9 September 2025. I did not receive the Notice of Allocation and therefore did not know the witness-statement deadline; I obtained a copy from the Court on 22 September 2025 and have acted promptly since then.
3. I received the Claimant’s witness statement and exhibits on 9 September 2025. This was the first time the Claimant set out factual assertions and documents.
4. My evidence is necessarily confined to responding to what has now been produced. I ask the Court to note that any lack of prior detail is due to the defective pleadings, not any failure on my part. If the Court is minded to admit the Claimant’s late material, I ask that the prejudice to me be taken into account when assessing case management and costs.
Relief from sanctions (CPR 3.9; Denton)
5. This statement is late against the small-claims timetable but admitting it will not derail the hearing. The Claimant has my bundle at the same time as the Court.
6. I was abroad until 9 September 2025 and did not receive the Notice of Allocation. I obtained a copy on 22 September 2025 and acted immediately.
7. I have acted promptly and in good faith. Admitting my evidence best serves the overriding objective so the real issues can be dealt with fairly and proportionately.
8. I am unable to provide a factual narrative of the alleged contravention because the Claimant’s Particulars of Claim (PoC) do not comply with CPR 16.4(1)(a) and PD 16. They do not plead the material facts, the contractual terms said to be breached, any period of parking, or a clear legal basis (driver or keeper). I first learned any detail of the allegation when I received the Claimant’s witness-statement material.
Pleadings and case management
9. A witness statement is not a substitute for compliant pleadings. If the Claimant required more space than the MCOL form allows, they could have served separate particulars within 14 days of service of the claim form or applied to amend (CPR 7.4(1); PD 7C §6.1). They did not do so. I ask the Court to treat the PoC as defective and to consider appropriate case-management relief (including CPR 3.4(2)(a)).
10. Insofar as the Claimant relies on CPR 16.5 to criticise my Defence, that rule presupposes compliant particulars. It is not possible to “admit/deny” allegations that were never pleaded with particulars.
Claimant’s witness and nature of their evidence
11. The Claimant’s witness describes herself as a Legal Assistant and states that she “has conduct of this action”. The conduct of litigation is a reserved legal activity under the Legal Services Act 2007 (s.12 and Sch.2). Carrying on a reserved legal activity when not entitled is an offence under s.14. I do not ask the Court to make any criminal finding, but I record that the witness’s own wording appears to engage s.14 and, at minimum, renders the Claimant’s approach procedurally irregular. I rely on this irregularity when the Court considers case management and costs.
12. Recent High Court authority in Mazur & Stuart v Charles Russell Speechlys LLP [2025] EWHC 2341 (KB) confirms that unqualified staff may assist but may not themselves conduct litigation—even under supervision. I therefore invite the Court, consistently with Mazur, to attach limited weight to assertions made by an unqualified person purporting to “have conduct” and to reflect that irregular conduct in any costs order. Where the statement proceeds on information and belief, I also note that PD 32 §18.2 requires identification of sources; absent that, the Court should assess low weight under the Civil Evidence Act 1995 s.4.
13. Much of the statement appears to be based on information from the Claimant rather than first-hand knowledge. Where information and belief are relied upon, PD 32 §18.2 requires the source to be identified. In the absence of sources and primary documents, I invite the Court to attach limited weight under the Civil Evidence Act 1995 s.4.
14. The Claimant’s own material shows the vehicle present for approximately one minute only (their exhibit numbering refers). There is no evidence of any period of parking. The following points (paras 15–17) address why, on those facts alone, no contract could have been formed and why keeper liability does not arise.
15. Under the BPA Code of Practice in force at the time (section 13.1), a driver must be given a reasonable consideration period, with a minimum of five minutes, to read the terms and decide whether to stay. If a driver decides not to park, they must be allowed to leave during that period without incurring a charge. On the Claimant’s evidence of about one minute, no contract could have been formed.
16. The signage relied upon states “NO PARKING ON YELLOW LINES”. That is a forbidding notice and does not make any offer capable of acceptance. In those circumstances there is no contractual basis for a charge. If anything, only the landowner could pursue trespass and then only for nominal loss, which has not been pleaded.
17. The Claimant seeks to rely on keeper liability. Schedule 4 of the Protection of Freedoms Act 2012 requires identification of a period of parking; instantaneous images or a momentary observation are insufficient. The persuasive appellate decision in Brennan v Premier Parking Solutions Ltd (2023) [H6DP632H] confirms that a period of parking must be specified; a single instant does not prove parking. The driver has not been identified and PoFA has not been met, so keeper liability does not arise.
18. The Claimants "witness" at paragraph 29 in their statement about my defence has made a speculative and unsupported allegation. The Civil Procedure Rules do not require a litigant to be the sole author of their defence; what matters is that the party adopts it and verifies it with a Statement of Truth (CPR 22 and PD 22). Litigants routinely take advice and assistance in drafting statements of case. The Claimant’s witness identifies no source for the assertion that the Defendant ‘is not the original author’, nor explains why authorship would affect validity once verified. The allegation is therefore irrelevant, prejudicial, and should be disregarded.
Standing and Claimants Exhibit GS1
19. The contract evidenced is heavily redacted. It does not disclose the site address, the parties in full, the dates in force, the scope of any authority (including a right to litigate in the Claimant’s own name), or the identity and authority of the signatories. While commercially sensitive figures can be redacted, the core terms establishing standing cannot be.
20. In its present form, the Claimants exhibit GS1, their purported landowner agreement, does not prove standing and should attract little or no weight.
21. If the land is managed via an agent, I also require proof of the chain of authority back to the landowner. If an unredacted version has been provided only to the Court and not to me, I would regard that as procedurally improper; evidence should be served on both parties.
Trade-association “appeals”
22. The Claimant’s statement suggests that recipients benefit from independent ADR through the trade association. The Claimant is an IPC member. The second-stage “IAS” and the IPC are trading names within the same corporate group. In those circumstances I invite the Court to attach limited weight to the suggestion that this constitutes independent ADR in this case.
Relief sought
23. For the reasons above—defective PoC and resulting prejudice, the attempt to introduce new matter by witness statement, the limited probative value of the Claimant’s hearsay material, and the failure to prove standing with an intelligible contract—I ask the Court to strike out the claim under CPR 3.4(2)(a). In the alternative, I seek an unless order requiring properly particularised PoC and disclosure of a complete contract (parties, site, term, scope, and signatory authority), with strike-out for non-compliance, and my costs arising from the Claimant’s conduct.
Statement of truth
I believe that the facts stated in this witness statement are true. I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth.
Signed: Maira Munir
Date: 23 September 2025
You should also send the following, separate, email to Gladstones:
Subject: Urgent COLP enquiry – unauthorised conduct of litigation admitted – [Claim No. L1GF6N4R] [Private Parking Solutions (London) Ltd] v [Maira Munir]
For the attention of the COLP, Mr John Llewellyn Davies,
Dear Mr Davies,
In this matter, your firm’s “Legal Assistant”, Leah Allcock, expressly states in her witness statement that they “have conduct of this action”. That is an admission of conduct of litigation by a person who (on the face of it) is not an authorised litigator. As you will be well aware:
• Conduct of litigation is a reserved legal activity under the Legal Services Act 2007 (s.12 & Sch.2).
• Carrying on a reserved activity when not entitled is an offence under s.14 LSA 2007.
• The High Court in Mazur & Stuart v Charles Russell Speechlys LLP [2025] EWHC 2341 (KB) confirms that unqualified staff may assist but may not conduct litigation, even if supervised.
Given the explicit wording used in this case, please provide your firm’s position on the following:
1. Authorisation: Is the individual who claims to “have conduct of this action” an authorised person for the purposes of the LSA (e.g. solicitor/barrister/CILEX litigator with current practising rights)? If so, state their regulator and authorisation number.
2. Scope: Has any reserved activity (issuing/serving pleadings, conducting correspondence with the court, settlement conduct, etc.) been performed by this individual?
3. Supervision is not a defence: If the person is not authorised, explain why they are represented as conducting the litigation notwithstanding Mazur and the LSA.
Remedial action: What immediate steps will Gladstones take to rectify the position (including any corrections/clarifications placed before the Court) and to ensure future compliance?
Your response will inform (a) the Defendant’s costs position in reliance on Mazur, and (b) whether this matter is reported to the SRA as a potential breach of the LSA 2007 and the SRA Standards and Regulations.
Please treat this as urgent.
Yours faithfully,
[Full Name]
Finally, I hope you have not damaged your chances too badly by delaying this. Good luck for the hearing and please report back on how it went. As much detail as possible.
Here is short video which explains what is likely to happen on the day:
https://youtu.be/n93eoaxhzpU?feature=sharedHere’s a courtroom-ready opening you can read verbatim. Keep it calm and neutral.
Preliminary matters (before anything else):
1. Relief from sanctions / late WS (yours):
“Judge, preliminarily I apply for relief from sanctions under CPR 3.9. I was out of the country until 9 September and I did not receive the Notice of Allocation. I obtained a copy on 22 September and served my witness statement immediately. I apologise to the Court and to the Claimant. Admitting my statement will not derail the hearing and will help the Court deal with the real issues fairly.”
2. Reading time (only if the judge hasn’t pre-read):
“If the Court has not had the opportunity to read my statement and exhibits, I would be grateful for brief reading time.”
If relief is granted (very brief roadmap of the issues):
3. Defective pleadings / ambush:
“The Particulars of Claim do not comply with CPR 16.4. A witness statement is not a substitute for proper particulars. I invite the Court to treat the claim on that footing.”
4. Unauthorised conduct of litigation (weight/costs):
“The Claimant’s deponent, a Legal Assistant, states they ‘have conduct of this action’. Conduct of litigation is a reserved activity. Even if supervised, it may not be carried out by an unauthorised person. I rely on Mazur & Stuart v CRS LLP for weight and costs.”
5. Merits—contract/PoFA in brief:
• “Their exhibits show the vehicle for about one minute only; no period of parking is evidenced.”
• “The sign relied upon is forbidding—‘NO PARKING ON YELLOW LINES’—so no contractual offer.”
• “The BPA Code required a minimum five-minute consideration period; on their own evidence that was not afforded.”
• “They have not identified the driver and PoFA requires a period of parking to engage keeper liability. That is not proved.”
6. Relief sought:
“Accordingly, I invite strike-out under CPR 3.4(2)(a). In the alternative, an unless order for proper particulars and core documents (including an unredacted contract showing standing), with strike-out for non-compliance. I also ask the Court to reflect the Claimant’s conduct in costs.”
If the judge asks you to prioritise, lead with (1) relief, then (5) the no period of parking / forbidding sign / no PoFA points, and only then the (4) unauthorised conduct for costs.
