Free Traffic Legal Advice

Before you do anything, I just noticed a typo in the cover letter to the court:

The Defendant was therefore denied a fair opportunity to respond to a properly poorly pleaded case.

There is no fee if you send as is and the court accepts that you have a valid argument. There is a possibility, that a judge may require you to submit a formal application (N244) and that would require a fee of £313 which you would get back if your costs request is successful.

You do not have to continue if you think the risk is too great if they require an N244 application. So, at least send in the costs request and let's see what the court comes back with.

We had a very similar case recently where the court simply ordered a costs hearing (no N244 required) and, in this case DCB Legal, kept trying to offer small sums to settle the matter out of court. We advised the defendant not to accept anything except the modest cost claimed (around £130 if I remember) and if they insisted on coming back with more and more offers that did not match the costs claimed, they would increase the costs claim because of the extra work in responding to the low offers being made. Of course, they eventually paid up in full before the hearing because they knew they would receive a spanking.

So, send the costs request as advised (correcting the typo I highlighted) and let's see where it goes from there. You are dealing with a firm of utterly incompetent wannabe legals and they should understand that their unreasonable behaviour has consequences.

Who sent the notice of discontinuance? The court or moorside legal.  Did they actually discontinue or just tell you they were so you didn’t turn up today to argue your case?

Who sent the notice of discontinuance? The court or moorside legal.  Did they actually discontinue or just tell you they were so you didn’t turn up today to argue your case?

Notice of Discontinuance Was sent to me by email 24hours and 15 minutes before the court hearing.

The NoD is sent by the claimant or their legal representative. An N279 is not issued by the court.

On a separate note, there has been a very recent High Court appeal decision, which will be binding, that could affect every single one of these bulk litigators, especially Moorside Legal who are one of the most incompetent of them all.

Mazur & Stuart v Charles Russell Speechlys LLP [2025] EWHC 2341 (KB), Sheldon J (16 Sept 2025) is a high-authority clarification that paralegals/non-admitted staff cannot conduct litigation merely because their firm is authorised; they may only support an authorised litigator.

In these types of cases, you can target any paralegal-signed formal steps (claim issue, SoTs, WS purporting to take responsibility) and seek regularisation plus costs. In this particular case, the N1SDT is signed by an Ibrar Ahmad. Whilst Mr Ahmad is listed as an SRA regulated solicitor, it shows him as employed by Osbourne Pinner Ltd, not Moorside Legal. The only SRA regulated employees of Moorside Legal are Adam Edward Peacock  who is not an SRA-regulated lawyer, working as Compliance officer for finance and administration (COFA), Rebecca Horton-Grainger who is an SRA-regulated solicitor and is Compliance officer for legal practice (COLP) and a Thomas Oliver Clough who is an SRA-regulated solicitor.

Given that Moorside Legal’s SRA entry lists only Rebecca Horton-Grainger (COLP) and Thomas Oliver Clough as its solicitors, if the N1SDT claim is signed “for Moorside Legal” by Ibrar Ahmad whose SRA record shows he “works at Osbourne Pinner Ltd”, there’s a clear authority mismatch.

A statement of case/SoT may be signed by the party or their legal representative (CPR 22; PD22). The legal representative must be the lawyer acting for the claimant through the firm on the record. A practising solicitor (like Mr Ahmad) is personally authorised to conduct litigation, but if he signs on behalf of Moorside Legal, he must have a proper practising relationship/authority with Moorside (employee/partner/consultant/secondment).

Unless Moorside can evidence that Mr Ahmad was acting through/for Moorside when he signed, this is a solid authority defect and will affect their liability for costs.

I suggest you send the following email to Rebecca Horton-Grainger at Moorside Legal:

Subject: Claim [Claim No.] – Confirmation of Mr Ibrar Ahmad’s authority (March 2025)

Dear Ms Horton-Grainger,

Re: UKCPS Ltd v [Defendant’s name] — Claim No. [____]; issued 13 March 2025]

For the purpose of a pending costs application following the Claimant’s late discontinuance, please confirm the following in relation to the above claim:

1. Whether Mr Ibrar Ahmad was employed by, seconded to, or acting as a consultant for Moorside Legal as at 13 March 2025; and
2. Whether Mr Ahmad was authorised by Moorside Legal to sign N1SDT claim forms and/or statements of truth on that date.

A brief yes/no to each point (or a short confirmation on letterhead) will suffice.

This request is made to clarify authority at the material time, in light of the recent High Court guidance on conduct of litigation by authorised persons.

I would be grateful for your reply within 7 days from today. If no response is received by that date, the Court may be invited to note the absence of confirmation when considering costs.

Yours faithfully,

[Full name]
Defendant
[Email] | [Telephone]
[Postal address]

Your original aim was to avoid paying UKCPS any money. You have succeeded in that aim. I'd count that as a win.

I don’t feel in the position to spend funds fighting for the fees.

Entirely sensible.