Help please - Formal Demand Letter from CPM

nosferatu1001

Exactly that! You cannot ADMIT to something you dont know is true
So dont
State you were an OCCUPANT of the car.

Amaka123

Ok, so I've added a bit more around the Keeper Liability and added in actual height of signage (after going out with my tape measure). How does the Witness Statement look now? Do I need more examples of relevant cases?

When posting the Witness Statements/Evidence to the court and claimants (Gladstones) should I post them recorded delivery? I plan to post them so they will arrive a day or two before the 14 days deadline.

In the County Court at XXXXX
Claim No. XXXXXXXX
Between
UK Car Park Management (Claimant)
and
XXX XXX (Defendant)

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Witness Statement

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1. Sequence of Events
1.1 I am xxxx xxxxxx, being the Defendant in this case. I am an unrepresented consumer with no experience of Court procedure. Should I not present my case as professionally as the Claimant’s, I trust that the Court excuses my inexperience.
1.2 Although I am the Registered Keeper of the vehicle XXXX XXX I may or may not have been the driver at the time of the parking incident. Being almost 2 years ago I cannot remember for certain who was driving the car, both myself and my Husband were in the car at the time and either of us could have been driving. See Exhibit X which shows my Husband listed as a named driver on my insurance policy from 2017.
1.3 This claim refers to a parking incident on XXXX Road, Lichfield. For all intents and purposes the part of the road parked on appears to be part of the public highway. There are no signs upon entering the road to state that the road is ‘private’. In fact there are nearly always cars parked along this part of XXXXX Road whenever you go down it. See photographs in Exhibit X taken on numerous days over the last two years.
1.4 Upon receipt of the parking fine stating the road was a ‘private road’ I contacted Staffordshire County Council to ask for clarification. The email response received stated that XXXXX Road is in fact a ‘public highway’ up until the 1st junction on the left of XXXXX Road. My car was parked opposite this junction. There is not a single sign to state that the road is in fact ‘private’ after this junction (unless you drive much further up the street). The driver of the car did not see any signs with regards to the road being private or any parking restrictions and so did not see any reason why the car couldn’t be parked there.
1.5 The day of the parking incident was after heavy snowfall and very icy road conditions, as can be seen on the photographic evidence. Exhibit X shows the route that the driver took upon entering the road, pulling into a side street to reverse the car and then park alongside the road edge. At no point from entering XXXXX Road to parking up did the driver pass a single sign to indicate the Road was private or that there were parking conditions imposed. If they had of seen a sign then they simply would not have parked there.

2. Keeper Liability

2.1 The Particulars of Claim state that the Defendant was the registered keeper and/or the driver of the vehicle(s). These assertions indicate that the Claimant has failed to identify a Cause of Action, and is simply offering a menu of choices. As such, the Claim fails to comply with Civil Procedure Rule 16.4, or with Civil Practice Direction 16, paras. 7.3 to 7.5.
2.2 As the keeper of the vehicle I cannot be held liable as there are two potential drivers (myself or my husband) and none of the evidence submitted by the Claimant identifies who the driver actually was. As such as Registered Keeper of the vehicle I can only be held liable if the Claimant has fully complied with Schedule 4 of the Protection of Freedoms Act 2012 (POFA). Due to inadequate notice of the parking charge, the possibility that the land parked on is Council owned land under statutory control and a lack of any relevant contract with the driver, this Claimant has failed to invoke the law and therefore keeper liability cannot pass to the registered keeper. (See highlighted parts of Exhibit X – POFA 2012 Schedule 4).

2.3 In the POPLA Annual Report 2015, Henry M Gleenslade iterates quite clearly that the only person who can be deemed wholly responsible for a parking charge on private land is the driver of the vehicle in question at the time, and that this cannot be assumed to be the registered keeper. In addition, the details of the keeper can only be released under the POFA 2012 if there is ‘reasonable cause’ to do so, such as ‘tracing people responsible for driving off without paying for goods and services’. (See Exhibit X).

3. No Contract Exists

3.1 I understand from correspondence with the Claimant that the Claimant’s case relies upon the signage at the site (see Exhibit X) constituting a ‘contract’ between myself and the Claimant as per ParkingEye vs Beavis. The ‘breach of terms’ on the Particulars of Claim presumably refers to the supposed ‘contract’ formed by this signage.

3.2 In ‘ParkingEye vs Beavis’, on which the Claimant relies to justify this charge, it was found that a contract could exist because there was a meaningful ‘offer’ made to the Defendant (that of a licence allowing free parking for a set period of time) and that the Defendant’s agreeing not to overstay this period could constitute a ‘consideration’ in respect of this. The ‘ParkingEye vs Beavis’ judgement is littered with references to the disputed charge being justifiable only in the context of the ‘contractual licence to park’ being given to the Defendant, e.g. ‘They must regard the risk of having to pay £85 for overstaying as an acceptable price for the convenience of parking there’.

3.3 There is no such ‘offer’ made by the signage in this case, no ‘contractual licence’, no ‘benefit of free parking‘ and no conceivable way the driver could have benefitted from this alleged ‘contract’ without breaching its terms.

3.4 In J Spurling Ltd v Bradshaw in the Court of Appeal, Lord Denning states that ‘the more unreasonable a clause is, the greater the notice which must be given of it’. This is commonly referred to the ‘Red Hand Rule’. As the terms of this ‘contract’ (specifically the clause relating to a £100 parking charge) are designed to discourage motorists from accepting them it follows that they must be ‘unreasonable’ and that therefore Lord Denning’s rule should apply.

3.5 The Claimant has not applied Lord Denning’s ‘Red Hand Rule’ to the terms and conditions in this case. The sentence that refers to a ‘parking charge’ is in an extremely small font (one of the smallest on the sign) which, given that this sign is supposed to be read from a vehicle, is woefully inadequate - particularly when compared to the signage in the ‘ParkingEye vs Beavis’ case (see Exhibit X).

3.6 The very act of entering into this alleged ‘contract’ (parking) constitutes a breach of its terms, therefore making it impossible to perform.

3.7 Both the PCN and Notice to Keeper issued by the Claimant state the reason for the disputed charge as being ‘Unauthorised Parking’. I cannot be seen to have entered into a contract for something I was not ‘authorised’ to do.

3.8 The signage and its wording at this site is very similar to the signage in the case of ‘Parking Control Management v Bull’ (Exhibit X) in which the Judge found that it was ‘impossible to construct out of this in any way, either actually or contingently or conditionally, any permission for anyone to park on the roadway.’ and that therefore any charges made on the basis of said signage would be damages for trespass and must constitute reparations for actual loss.

4. Inadequate Signage

4.1 A key factor in ‘ParkingEye vs Beavis’ was that the relevant signs were ‘large, prominent and legible, so that any reasonable user of the car park would be aware of their existence and nature’ and ‘the charge is prominently displayed in large letters at the entrance to the car park and at frequent intervals within it’. That is not the case here. The parking charge of £100 is actually one of the smallest fonts on the sign measuring just 1cm in height. (See Exhibit X).

4.2 In ‘Vine v London Borough of Waltham Forest’ the Court of Appeal ruled that a person cannot be presumed bound by terms and conditions on signage that they haven’t seen. In this case, which was found in favour of the motorist, the signage was deemed insufficient because there was no sign directly adjacent to the Appellant’s parking bay and the only signage that was displayed could not have been seen from within the vehicle whilst parking. In this case there was no sign adjacent to my vehicle, the driver had not passed any signs to park, and no signs in the vicinity could possibly be read from inside the vehicle.

4.3 A key factor in ‘ParkingEye vs Beavis’ was that ParkingEye were found to have operated in line with the relevant parking operator’s code of practice. In this case the signage and operating practice of the Claimant fails, on numerous counts, to adhere to the standards laid out by the relevant accredited parking operator - The International Parking Community (IPC).

4.3.1 The IPC guidelines state that signage at the entrance to the site should ‘Make it clear that the motorist is entering onto private land’. There is no signage at the entrance to the road in question and one can see from the photographs that the driver would not have passed any signage indicating they were entering a private road.

4.3.2 The IPC guidelines state that text on signage ‘should be of such a size and in a font that can be easily read by a motorist having regard to the likely position of the motorist in relation to the sign.’ The text on the signage, particularly that which refers to ‘contractual terms’ and a ‘parking charge’ is very small. In fact is measures just 1cm in height. This, coupled with the fact that the signs are mounted at least 6.5ft off the ground, makes it very hard to read and impossible to read from a vehicle.

4.3.3 The IPC guidelines state that signage that is intended to form a contract should ‘Be clearly legible and placed in such a position that a driver of a vehicle is able to see them clearly upon entering the site or parking a vehicle within the site’. It is more-or-less impossible to read this signage whilst driving as it is mounted on a pole at least 6.5ft high.
4.3.4 The first parking conditions sign situated in XXXX road and the one that would have been closest to the parked vehicle is actually only 2.2ft from the ground and when a vehicle is parked in front of it (as witnessed on many occasions – see photographs in Exhibit X) the sign is completely out of sight to anyone passing in a vehicle.

5. Landowner Authority

5.1 Despite being asked, the Claimant has not provided any indication that they are authorised by the landowner to issue parking charges and carry out court proceedings on their behalf. The Claimant is put to strict proof that they have the authority to do this, and that the terms and conditions of parking they impose at the site are in line with what they have been authorised to do. I have reasonable belief that the Claimant does not have the authority to issue charges on this land in their own name, and that they have no right to bring any action regarding this claim.

6. Additional Costs

6.1 The Particulars of Claim include £50 for ‘contractual costs’. The Claimant is put to strict proof that these additional charges are justified. I have the reasonable belief that the Claimant has not incurred £50 costs to pursue an alleged £100 debt. Any debt collection letters were a standard feature of a low cost business model and are already counted within the parking charge itself. In reference to Exhibit X, The Protection of Freedoms Act 2012, Schedule 4, Para 4(5) states that the maximum sum that may be recovered from the keeper is the charge stated on the Notice to Keeper, in this case £100.
6.2 According to Ladak v DRC Locums UKEAT/0488/13/LA a Claimant can only recover the direct and provable costs of the time spent preparing the claim in a legal capacity, not any administration costs allegedly incurred by already remunerated administrative staff.


I invite the Court to dismiss this claim in its entirety, and to award my costs of attendance at the hearing, such as are allowable pursuant to CPR 27.14.

I believe that the facts stated in this Witness Statement are true.

XXXX
XX/10/2019

SCHEDULE OF COSTS


In the County Court at XXXX
Claim No. XXXX
Between
UK Car Park Management Limited (Claimant)
and
XXXX (Defendant)

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Defendant's Schedule of Costs

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Ordinary Costs

Loss of earnings/leave, incurred through attendance at Court 19/11/2019: £90.00

Return mileage from home address to Court: £9.00 (20 miles x £0.45)

Sub-total £99.00 ======

Further costs for Claimant's unreasonable behaviour, pursuant to Civil Procedure Rule 27.14(2)(g)

Research, preparation and drafting of documents (4 hours at Litigant in Person rate of £19 per hour) £76.00

Stationery, printing, photocopying and postage: £15.00

Sub-total £91.00 ======
£190.00 TOTAL COSTS CLAIMED

1505grandad

Just a few observations:-

Heading - the claimant is .Ltd I think you will find on Court docs.

Para 1.4 - parking "charge" - not "fine"


Para 3.2 - no "e" in judgment


Para 4.3.3 - same as 4.3.2


The Abuse of Process paras to include very latest Court cases should be added at the end.

Amaka123

I have made a few amends to my WS as per 1505grandad's suggestions. I've added bits in section 4 and section 6 if anyone is able to have a look over them for me?

Does it look like this WS is ready to go? Any other advice as I feel a bit out of my depth.
Thanks

Witness Statement

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1. Sequence of Events
1.1 I am xxxx xxxxxx, being the Defendant in this case. I am an unrepresented consumer with no experience of Court procedure. Should I not present my case as professionally as the Claimant’s, I trust that the Court excuses my inexperience.
1.2 Although I am the Registered Keeper of the vehicle XXXX XXX I may or may not have been the driver at the time of the parking incident. Being almost 2 years ago I cannot remember for certain who was driving the car, both myself and my Husband were in the car at the time and either of us could have been driving. See Exhibit 1 which shows my Husband listed as a named driver on my insurance policy from 2017.
1.3 This claim refers to a parking incident on XXXX Road, Lichfield. For all intents and purposes the part of the road parked on appears to be part of the public highway. There are no signs upon entering the road to state that the road is ‘private’ (See photograph in Exhibit 2). In fact there are nearly always cars parked along this part of XXXXX Road whenever you go down it. See photographs in Exhibit 3 taken on numerous days over the last two years.
1.4 Upon receipt of the parking charge stating the road was a ‘private road’ I contacted Staffordshire County Council to ask for clarification. The email response received stated that XXXXX Road is in fact a ‘public highway’ up until the 1st junction on the left of XXXXX Road. My car was parked opposite this junction (see map in Exhibit 4). There is not a single sign to state that the road is in fact ‘private’ after this junction (unless you drive much further up the street). The driver of the car did not see any signs with regards to the road being private or any parking restrictions and so did not see any reason why the car couldn’t be parked there.
1.5 The day of the parking incident was after heavy snowfall and very icy road conditions, as can be seen on the photographic evidence. Exhibit 5 shows the route that the driver took upon entering the road, pulling into a side street to reverse the car and then park alongside the road edge. At no point from entering XXXXX Road to parking up did the driver pass a single sign to indicate the Road was private or that there were parking conditions imposed. If they had of seen a sign then they simply would not have parked there.

2. Keeper Liability

2.1 The Particulars of Claim state that the Defendant was the registered keeper and/or the driver of the vehicle(s). These assertions indicate that the Claimant has failed to identify a Cause of Action, and is simply offering a menu of choices. As such, the Claim fails to comply with Civil Procedure Rule 16.4, or with Civil Practice Direction 16, paras. 7.3 to 7.5.
2.2 As the keeper of the vehicle I cannot be held liable as there are two potential drivers (myself or my Husband) and none of the evidence submitted by the Claimant identifies who the driver actually was. As such as registered keeper of the vehicle I can only be held liable if the Claimant has fully complied with Schedule 4 of the Protection of Freedoms Act 2012 (POFA). Due to inadequate notice of the parking charge, the possibility that the land parked on is Council owned land under statutory control and a lack of any relevant contract with the driver, this Claimant has failed to invoke the law and therefore keeper liability cannot pass to the registered keeper. (See highlighted parts of Exhibit 6 – POFA 2012 Schedule 4).

2.3 In the POPLA Annual Report 2015, Henry M Gleenslade iterates quite clearly that the only person who can be deemed wholly responsible for a parking charge on private land is the driver of the vehicle in question at the time, and that this cannot be assumed to be the registered keeper. In addition, the details of the keeper can only be released under the POFA 2012 if there is ‘reasonable cause’ to do so, such as ‘tracing people responsible for driving off without paying for goods and services’. (See Exhibit 7).

3. No Contract Exists

3.1 I understand from correspondence with the Claimant that the Claimant’s case relies upon the signage at the site (see Exhibit 8) constituting a ‘contract’ between myself and the Claimant as per ParkingEye v Beavis. The ‘breach of terms’ on the Particulars of Claim presumably refers to the supposed ‘contract’ formed by this signage.

3.2 In ‘ParkingEye vs Beavis’, on which the Claimant relies to justify this charge, it was found that a contract could exist because there was a meaningful ‘offer’ made to the Defendant (that of a licence allowing free parking for a set period of time) and that the Defendant’s agreeing not to overstay this period could constitute a ‘consideration’ in respect of this. The ‘ParkingEye v Beavis’ judgment is littered with references to the disputed charge being justifiable only in the context of the ‘contractual licence to park’ being given to the Defendant, e.g. ‘They must regard the risk of having to pay £85 for overstaying as an acceptable price for the convenience of parking there’.

3.3 There is no such ‘offer’ made by the signage in this case, no ‘contractual licence’, no ‘benefit of free parking‘ and no conceivable way the driver could have benefitted from this alleged ‘contract’ without breaching its terms.

3.4 In J Spurling Ltd v Bradshaw in the Court of Appeal, Lord Denning states that ‘the more unreasonable a clause is, the greater the notice which must be given of it’. This is commonly referred to the ‘Red Hand Rule’. As the terms of this ‘contract’ (specifically the clause relating to a £100 parking charge) are designed to discourage motorists from accepting them it follows that they must be ‘unreasonable’ and that therefore Lord Denning’s rule should apply.

3.5 The Claimant has not applied Lord Denning’s ‘Red Hand Rule’ to the terms and conditions in this case. The sentence that refers to a ‘parking charge’ is in an extremely small font (one of the smallest on the sign) which, given that this sign is supposed to be read from a vehicle, is woefully inadequate - particularly when compared to the signage in the ‘ParkingEye v Beavis’ case (see Exhibit 9).

3.6 The very act of entering into this alleged ‘contract’ (parking) constitutes a breach of its terms, therefore making it impossible to perform.

3.7 Both the PCN and Notice to Keeper issued by the Claimant state the reason for the disputed charge as being ‘Unauthorised Parking’. I cannot be seen to have entered into a contract for something I was not ‘authorised’ to do.

3.8 The signage and its wording at this site is very similar to the signage in the case of Parking Control Management v Bull (see Exhibit 10) in which the Judge found that it was ‘impossible to construct out of this in any way, either actually or contingently or conditionally, any permission for anyone to park on the roadway.’ and that therefore any charges made on the basis of said signage would be damages for trespass and must constitute reparations for actual loss.

4. Inadequate Signage

4.1 A key factor in ‘ParkingEye v Beavis’ was that the relevant signs were ‘large, prominent and legible, so that any reasonable user of the car park would be aware of their existence and nature’ and ‘the charge is prominently displayed in large letters at the entrance to the car park and at frequent intervals within it’. That is not the case here. The parking charge of £100 is actually one of the smallest fonts on the sign measuring just 1cm in height. (See Exhibit 8).

4.2 In Vine v London Borough of Waltham Forest the Court of Appeal ruled that a person cannot be presumed bound by terms and conditions on signage that they haven’t seen. In this case, which was found in favour of the motorist, the signage was deemed insufficient because there was no sign directly adjacent to the Appellant’s parking bay and the only signage that was displayed could not have been seen from within the vehicle whilst parking.

4.3 In this case there was no sign adjacent to my vehicle, the driver had not passed any signs to park, and no signs in the vicinity could possibly be read from inside the vehicle. The only signage on the roadside by the parked vehicle were two signs on poles stating ‘Private Car Park for the Use of Ventura House Only’ which referred to the allocated car park spaces on the right hand side (see Exhibit X). The car was not parked in any of these spaces.

4.4 A key factor in ‘ParkingEye v Beavis’ was that ParkingEye were found to have operated in line with the relevant parking operator’s code of practice. In this case the signage and operating practice of the Claimant fails, on numerous counts, to adhere to the standards laid out by the relevant accredited parking operator - The International Parking Community (IPC).

4.4.1 The IPC guidelines state that signage at the entrance to the site should ‘Make it clear that the motorist is entering onto private land’. There is no signage at the entrance to the road in question and one can see from the photographs In Exhibit X that the driver would not have passed any signage indicating they were entering a private road.

4.4.2 The IPC guidelines state that text on signage ‘should be of such a size and in a font that can be easily read by a motorist having regard to the likely position of the motorist in relation to the sign.’ It also states that ‘they should be clearly seen upon entering the site’. The text on the signage in this case, particularly that which refers to ‘contractual terms’ and a ‘parking charge’ is very small. In fact is measures just 1cm in height. This, coupled with the fact that the signs are mounted at least 6.5ft off the ground, makes it very hard to read and impossible to read from a vehicle.
4.4.3 The first parking conditions sign situated in XXXX road and the one that would have been closest to the parked vehicle is actually only 2.2ft from the ground and when a vehicle is parked in front of it (as witnessed on many occasions – see photographs in Exhibit 12) the sign is completely out of sight to anyone passing in a vehicle.

4.4.4 A map sent to myself by the claimant supposedly indicates with a yellow dot where the parking conditions signage is located. I believe that there is no sign at all where one of the yellow dots has been placed (closest to the parked vehicle). Exhibit X contains photographs showing that there is no signage where the Claimant has indicated and it is in fact much further up the road – around 25 meters further away from the parked car and on part of the road which the vehicle did not pass. The Claimant is put to strict proof that the map provided is accurate and that this sign exists.

5. Landowner Authority

5.1 Despite being asked, the Claimant has not provided any indication that they are authorised by the landowner to issue parking charges and carry out court proceedings on their behalf. The Claimant is put to strict proof that they have the authority to do this, and that the terms and conditions of parking they impose at the site are in line with what they have been authorised to do. I have reasonable belief that the Claimant does not have the authority to issue charges on this land in their own name, and that they have no right to bring any action regarding this claim.

6. Additional Costs

6.1 The Particulars of Claim include £50 for ‘contractual costs’. The Claimant is put to strict proof that these additional charges are justified. I have the reasonable belief that the Claimant has not incurred £50 costs to pursue an alleged £100 debt. Any debt collection letters were a standard feature of a low cost business model and are already counted within the parking charge itself. In reference to Exhibit 6, The Protection of Freedoms Act 2012, Schedule 4, Para 4(5) states that the maximum sum that may be recovered from the keeper is the charge stated on the Notice to Keeper, in this case £100.
6.2 According to Ladak v DRC Locums (case number UKEAT/0488/13/LA) a Claimant can only recover the direct and provable costs of the time spent preparing the claim in a legal capacity, not any administration costs allegedly incurred by already remunerated administrative staff.
6.3 Judges have disallowed all added parking firm 'costs' in County courts up and down the Country. In Claim number F0DP201T on 10th June 2019, District Judge Taylor sitting at the County Court at Southampton, echoed earlier General Judgment or Orders of DJ Grand, who (when sitting at the Newport (IOW) County Court in 2018 and 2019) has struck out several parking firm claims. These include a BPA member serial Claimant (Britannia, using BW Legal's robo-claim model) and an IPC member serial Claimant (UKCPM, using Gladstones' robo-claim model) yet the Orders have been identical in striking out both claims without a hearing, with the Judge stating:
''It is ordered that The claim is struck out as an abuse of process. The claim contains a substantial charge additional to the parking charge which it is alleged the Defendant contracted to pay. This additional charge is not recoverable under the Protection of Freedoms Act 2012, Schedule 4 nor with reference to the judgment in ParkingEye v Beavis. It is an abuse of process from the Claimant to issue a knowingly inflated claim for an additional sum which it is not entitled to recover. This order has been made by the court of its own initiative without a hearing pursuant to CPR Rule 3.3(4) of the Civil Procedure Rules 1998...''

6.4 That is not an isolated judgment striking a parking claim out for repeatedly adding sums they are not entitled to recover. In the Caernarfon Court in Vehicle Control Services Ltd v Davies (Case number FTQZ4W28) on 4th September 2019, District Judge Jones-Evans stated:

''Upon it being recorded that District Judge Jones-Evans has over a very significant period of time warned advocates [...] in many cases of this nature before this court that their claim for £60 is unenforceable in law and is an abuse of process and is nothing more than a poor attempt to go behind the decision of the Supreme Court v Beavis which inter alia decided that a figure of £160 as a global sum claimed in this case would be a penalty and not a genuine pre-estimate of loss and therefore unenforceable in law and if the practice continued he would treat all cases as a claim for £160 and therefore a penalty and unenforceable in law it is hereby declared [...] the claim is struck out and declared to be wholly without merit and an abuse of process.''

I invite the Court to dismiss this claim in its entirety, and to award my costs of attendance at the hearing, such as are allowable pursuant to CPR 27.14.

I believe that the facts stated in this Witness Statement are true.

Amaka123

Any help on the above please? Thanks

Amaka123

Is anyone able to look over this final draft of my witness statement (see above post)? Thanks in advance.

Le_Kirk

Sometimes you have to take it that if no one answers, it's OK. 1505grandad checked it for you for typos. Although I find it a bit wordy because you seem to be including bits of legal stuff in there, it should do the job ....... and of course you have the important abuse of process part.

Umkomaas

2.3 In the POPLA Annual Report 2015, Henry M Gleenslade iterates quite clearly that the only person who can be deemed wholly responsible for a parking charge on private land is the driver of the vehicle in question at the time, and that this cannot be assumed to be the registered keeper. In addition, the details of the keeper can only be released under the POFA 2012 if there is ‘reasonable cause’ to do so, such as ‘tracing people responsible for driving off without paying for goods and services’. (See Exhibit 7).

Do you know who he is and what his credentials are? Or are you assuming the Judge will know?

Le_Kirk

Well spotted Umkomaas, he is in fact Henry M Greenslade, Lead Adjudicator of POPLA.

Umkomaas

Le_Kirk wrote: »

Well spotted Umkomaas, he is in fact Henry M Greenslade, Lead Adjudicator of POPLA.

........ and there's more .....

parking law expert, barrister, and previous PATAS and POPLA Lead Adjudicator.

All needs to be added.

The truncated rather meaningless version 'Henry said'(!) is now slipping into Defences and WS's in copy and dump posts where little proofreading or logical questioning has been applied by posters, of what they're signing as a Statement of Truth. Just the same as all the legal case references being splashed around. Have posters even read the legal cases?