Claim Form defence - Wells next to sea (CEL)

Gravis

Coupon-mad said:

A lot of that is very old.  The one I linked for you from April is better although it doesn't mention Excel v Wilkinson like the current advised template defence does.

Remove #16.19, 23 and 24 - out of date stuff - and put this right (you have a rogue apostrophe in 'costs' and 'signs' - eek!! these are plurals and don't take any apostrophe):

15.  Even if the Claimant had shown the global sum claimed in the largest font on clear and prominent sign's -which is denied-they are attempting double recovery of cost's. The sum exceeds the maximum amount which can be recovered from a registered keeper , as prescribed in schedule 4 (5) of the protection of freedom act 2012 Protection of Freedoms Act 2012   ('the POFA').

ok awesome, will revise! thank you!!

Gravis

ok here is the revised version and i will submit as is unless there are any other recommendations?

1. The Defendant is the registered keeper of the vehicle stated in the Particulars of Claim ('POC'). The Defendant denies that the claimant is entitled to relief in the sum claimed or at all. It is denied that the driver of the vehicle entered into any contractual agreement, whether express , implied or by conduct , to pay a 'parking charge' to the claimant.

2. Whilst it is admitted that the defendant was the keeper, the mandatory requirements to establish 'keeper liability' have not been met and the defendant is not liable in law.

3.The defendants vehicle had stopped at wells quay car park on 17/07/2020 at approximately 9:30pm in an emergency due to vehicle breakdown. At no point was the defendants vehicle left unoccupied as the 21 minute stay was spent on the telephone to a vehicle specialist whilst still inside the vehicle. The alternative to this would have been to stop and cause a dangerous obstruction on "The Quay" (B1105).The Claimant’s POC is not specific, in that it only alleges a breach of terms and conditions thus no details are provided in the PCN, only ‘payment not made in accordance with terms displayed on signage.

4. It is denied that the Claimant's signage was capable of creating a legally binding contract. It is denied that there was any contravention of a prominently displayed 'relevant obligation' or that there was any agreement by the driver to pay the Claimant a punitive £100 parking charge over and above the advertised tariff paid. The Claimant is put to strict proof of their compliance with their Trade Body's strict rules set for 'mandatory' signage and for new/changed restrictions in the BPA CoP. This is a code which the Supreme Court held was not just guidance but effectively 'regulatory' and that access to DVLA registered keeper data depends upon full compliance.

5. The Claimant's sign states that their role is to 'enforce', 'monitor' and 'patrol' and it is clear that their limited function is to facilitate the terms offered by the principal, including 'contact the DVLA' and 'issue PCNs'. This limited function is confirmed in the Claimant's own Linked In page, where they proclaim 'Civil Enforcement Ltd process and administer Parking Charge Notices (PCN's) on the behalf of UK Small Businesses and Major UK Brands.'

6. Unlike in the Supreme Court case of ParkingEye Ltd v Beavis [2015] UKSC 67, there is no sentence in the signage that offers or attempts to create a contract between this Claimant and a driver. A parking management firm could use wording to make themselves personally liable on the contract and they could make a contractual offer themselves by saying 'by parking at this site you, the driver, are entering into a contract with us' (or words to that effect) but there is no such contract on the signs. In fact, at no point is a driver told that they are entering into any contractual relationship.

7. The term and the licence to park is made by the principal, Wells Harbour Commissioners. In one image, the Claimant's sign has covered up a larger one that also says 'Order of The Wells Harbour Commissioners' but the words are still just about visible when taken in the context of other images and at the entrance, it is clear that the licence is offered by, and the site maintained by, the Port of Wells Harbour Commissioners, who are the disclosed principal.

8. Therefore, unlike in ParkingEye v Beavis, this Claimant has placed their service, and themselves, in the position of an agent/broker/middle-man, making the bargain for another party and collecting monies (the parking fees from the machine) for that party. The Defendant avers that this Claimant does not retain nor pay VAT on the tariffs and they have no possessory title in this land. Fatally to their claim, the Claimant made no offer of a contract to the driver, at all. The Claimant is put to strict proof if their position is to the contrary of that stated by this Defendant, who takes the point that the principles established by the authority of Fairlie v Fenton (1870) LR 5 Exch 169 apply and there is no contractual relationship between this Claimant and the Defendant.

9.The car park in question is owned by the wells harbour commissioners and is governed entirely under statutory control by byelaws, regulations and subordinate rules stated clearly by the car park signs which display the authority of such with the wording "BY ORDER OF THE WELLS HARBOUR COMMISSIONERS"

10. The Claimant is put to strict proof that it has sufficient proprietary interest in the land, or that it has the necessary and lawful authorisation from the landowner to issue parking charge notices at this Harbour location, and specifically, that Civil Enforcement LTD is lawfully authorised in it,s own name to pursue payment from a registered keeper via a small claim. This point is vital for the Claimant to evidence, and it will not be enough merely to produce a contract from the Wells Harbour Commissioners because the legal position is that registered keepers cannot be held liable for parking charges at this Port. Liability cannot pass from driver to keeper , because this is not 'relevant land' under Schedule 4 of the Protection of Freedoms Act 2012 ('the POFA') which says at paragraph 3(1)(c):

''In this Schedule ''relevant land'' means any land (including land above or below ground level) other than [...] any land [...] on which the parking of a vehicle is subject to statutory control. 3(3) For the purposes of sub-paragraph (1)(c) the parking of a vehicle on land is ''subject to statutory control'' if any statutory provision imposes a liability (whether criminal or civil, and whether in the form of a fee or charge or a penalty of any kind) in respect of the parking on that land of vehicles generally or of vehicles of a description that includes the vehicle in question. [...] ''statutory provision'' means any provision (apart from this Schedule) contained in - (a) any Act (including a local or private Act), whenever passed; or (b) any subordinate legislation, whenever made, and for this purpose ''subordinate legislation'' means an Order in Council or any order, regulations, byelaws or other legislative instrument.''

11. There is legislation in place at [wells harbour car park ] thus this location is not ''relevant land" under the POFA definition, and therefore parking matters incurring a charge or 'penalty fine' can only be pursued by the Harbour Master through the magistrates court. This is outside of the jurisdiction of any private parking company using the small claims track. This view is further supported by the Department for Transport's 2012 Guidance about this section of the POFA.

12. The (DFT) clarify the question at schedule 4: ''On what type of land does Schedule 4 apply? 4.1 The provisions in Schedule 4 are intended to apply only on private land in England and Wales. Public highways are excluded as well as any parking places on public land which are either provided or controlled by a local authority (or other government body). Any land which already has statutory controls in relation to the parking of vehicles (such as byelaws applying to airports, ports and some railway station car parks) is also excluded.''

13. At the Bradford County Court, District Judge Claire Jackson (now HHJ Jackson, a Specialist Civil Circuit Judge) decided to hear a 'test case' a few months ago, where £60 had been added to a parking charge despite Judges up and down the country repeatedly disallowing that sum and warning parking firms not to waste court time with such spurious claims. That case was Excel v Wilkinson: G4QZ465V, heard in July 2020 and leave to appeal was refused and that route was not pursued. The Judge concluded that such claims are proceedings with 'an improper collateral purpose'. This Judge - and others who have since copied her words and struck dozens of cases out in late 2020 and into 2021 - went into significant detail and concluded that parking operators (such as this Claimant) are seeking to circumvent CPR 27.14 as well as breaching the Consumer Rights Act 2015. DJ Hickinbottom has recently struck more cases out in that court area, stating: ''I find that striking out this claim is the only appropriate manner in which the disapproval of the court can be shown''.

14. In relation to parking on private land , it is settled law from the Supreme court, that a parking charge must be set at a level which includes recovery of the cost's of operating a scheme .However this claimant is claiming a global sum of £195.88. This figure is a penalty, far exceeding the £85 parking charge in the Parking eye LTD v Beavis case .The global sum claimed is unconscionable and it was not shown in large lettering on any consumer signs, and it is averred that the charge offends against schedule 2 of the consumer rights act 2015 ( 'the CRA') , where s71 (2) creates a duty on the court to consider the fairness of a consumer contract .The Court's attention is drawn ( but not limited to) parts 6,10, 14 and 18 of the list of terms that are likely to be unfair.

15.Even if the Claimant had shown the global sum claimed in the largest font on clear and prominent signs -which is denied-they are attempting double recovery of costs. The sum exceeds the maximum amount which can be recovered from a registered keeper , as prescribed in schedule 4 (5) of the Protection of Freedom Act 2012 ('the POFA')

16. CPR 44.3 (2) states: ''Where the amount of costs is to be assessed on the standard basis, the court will – (a) only allow costs which are proportionate to the matters in issue. Costs which are disproportionate in amount may be disallowed or reduced even if they were reasonably or necessarily incurred; and (b) resolve any doubt which it may have as to whether costs were reasonably and proportionately incurred or were reasonable and proportionate in amount in favour of the paying party.''

17. Whilst quantified costs can be considered on a standard basis, this Claimant's costs are wholly disproportionate and do not stand up to scrutiny. In fact it is averred that the Claimant has not paid or incurred any added costs and cannot plead a case in damages at all. Any debt collection letters were either sent by a third party which offers a 'no collection, no fee' service, or were a standard feature of a low cost business model. The Beavis case is the authority for recovery of the parking charge itself and no more, since that sum is, by definition, already hugely inflated for profit, not loss, and the Judges held that a parking firm not in possession cannot plead their case in damages, as none exist.

18. Should this claim continue, the Claimant will no doubt try to mislead the court by pointing to their Trade Association ‘ATA’ Code of Practice (‘CoP’) that now includes a hastily-added clause 'allowing' added costs/damages. The Defendant points out that the CoP is a self-serving document, written in the parking firms’ interests. Further, the ‘admin fee’ model was reportedly invented by a member of the British Parking Association Board, Gary Osner, whose previous firm, Roxburghe (UK) Limited, folded after being declared ‘unfit’ by the Office of Fair Trading who refused to renew their consumer credit licence due to ‘unfair and misleading’ business practices. Mr Osner states in an article that has been in the public domain since 2018: ''I created the model of ‘admin fees’ for debt recovery because ticket value was so low that nobody would make any money. Parking is business and business is about money, after all.''

19. The two competing ‘race to the bottom’ ATAs have engineered a veil of legitimacy to protect this industry for too long. They are not regulators and have failed consumers so badly, that Parliament is currently working on replacing them with a new CoP overseen by the Secretary of State, following the enactment of the Parking (Code of Practice) Act 2019. Many courts have now recognised that a predatory parking firm Claimant using unfair and predatory business practices and inflating their claims with false ‘admin fees’, is not the ‘innocent party’ in a dispute. In stark contrast to the BPA Board member’s mindset, the will of Parliament as set out in the new 2019 Act is very much consumer-focussed, aiming for: ''good practice...in the operation or management of private parking facilities as appears to the Secretary of State to be desirable having regard to the interests of persons using such facilities.''

20. In the alternative, the defence is prejudiced and the court is invited to note that, contrary to the Pre-Action Protocol for Debt Claims, the Letter Before Claim omitted evidence of any breach and failed to append the wording of the sign or consumer notice. Further, the Particulars of Claim are embarrassing and incoherent, lacking specificity re the location of the event and status of the contracting parties and failing to detail any conduct or liability that could give rise to a cause of action. There is insufficient detail to ascertain the nature, basis and facts of the case but the sum claimed includes unrecoverable costs/damages and is clearly an abuse of process.

21. In summary , the Claimant cannot reasonably recover an additional three figure sum in damages or costs to pursue an alleged £100 debt. The POFA states that the maximum sum that may be recovered from a registered keeper is the charge stated on a compliant NTK, and only if all requirements of Schedule 4 are met. This is not the case in this claim, in any respect, and there was no breach of any 'relevant obligation' or 'relevant contract' at all.

22. The Defendant denies the claim in its entirety voiding any liability to the claimant for all amounts claimed due to the aforementioned reasons. The Court is invited to dismiss the Claim, and to allow such Defendant's costs as are permissible under Civil Procedure Rule 27.14.

Coupon-mad

Capital initials needed for every word in place names and other proper nouns, of course:

wells quay 

wells harbour commissioners 

wells harbour

And move your point #13 about the DJ Jackson decision down to replace your #16, which isn't needed as the Judge knows what the CPRs say, pretty much.   Then renumber of course as you will have one point less.

And I'd explain here how you know what the signs say:

5. Through research and after visiting the location at the time of writing this defence, the Defendant's position is that the Claimant's sign states... (blah blah, same as you have this point).

1505grandad

Just checking  -  Para 14  -  ".However this claimant is claiming a global sum of £195.88."

If you are going to quote the actual sum is it correct? -  for instance in a previous draft you quoted:-

"However this claimant is claiming a global sum of £280.88."

The global sum - if quoted - was usually pounds only (I believe).

Coupon-mad

Yes, you are not meant to include the interest or the court fees shown on the right of the claim form.

Gravis

1505grandad said:

Just checking  -  Para 14  -  ".However this claimant is claiming a global sum of £195.88."

If you are going to quote the actual sum is it correct? -  for instance in a previous draft you quoted:-

"However this claimant is claiming a global sum of £280.88."

The global sum - if quoted - was usually pounds only (I believe).

Ok yes I was a little confused, I’ve attached a picture of what’s on the claim form. Which is the correct global amount please?

Gravis

Coupon-mad said:

Yes, you are not meant to include the interest or the court fees shown on the right of the claim form.

ah ok that explains it thanks

Gravis

Coupon-mad said:

Capital initials needed for every word in place names and other proper nouns, of course:

wells quay 

wells harbour commissioners 

wells harbour

And move your point #13 about the DJ Jackson decision down to replace your #16, which isn't needed as the Judge knows what the CPRs say, pretty much.   Then renumber of course as you will have one point less.

And I'd explain here how you know what the signs say:

5. Through research and after visiting the location at the time of writing this defence, the Defendant's position is that the Claimant's sign states... (blah blah, same as you have this point).

ok thank you I have amended.

Gravis

1. The Defendant is the registered keeper of the vehicle stated in the Particulars of Claim ('POC'). The Defendant denies that the claimant is entitled to relief in the sum claimed or at all. It is denied that the driver of the vehicle entered into any contractual agreement, whether express , implied or by conduct , to pay a 'parking charge' to the claimant.

2. Whilst it is admitted that the defendant was the keeper, the mandatory requirements to establish 'keeper liability' have not been met and the defendant is not liable in law.

3.The defendants vehicle had stopped at Port of Wells car park on 17/07/2020 at approximately 9:30pm in an emergency due to vehicle breakdown. At no point was the defendants vehicle left unoccupied as the 21 minute stay was spent on the telephone to a vehicle specialist whilst still inside the vehicle. The alternative to this would have been to stop and cause a dangerous obstruction on "The Quay" (B1105).The Claimant’s POC is not specific, in that it only alleges a breach of terms and conditions thus no details are provided in the PCN, only ‘payment not made in accordance with terms displayed on signage.

4. It is denied that the Claimant's signage was capable of creating a legally binding contract. It is denied that there was any contravention of a prominently displayed 'relevant obligation' or that there was any agreement by the driver to pay the Claimant a punitive £100 parking charge over and above the advertised tariff paid. The Claimant is put to strict proof of their compliance with their Trade Body's strict rules set for 'mandatory' signage and for new/changed restrictions in the BPA CoP. This is a code which the Supreme Court held was not just guidance but effectively 'regulatory' and that access to DVLA registered keeper data depends upon full compliance.

5. Through research and after visiting the location at the time of writing this defence, the Defendant's position is that the Claimant's sign states that their role is to 'enforce', 'monitor' and 'patrol' and it is clear that their limited function is to facilitate the terms offered by the principal, including 'contact the DVLA' and 'issue PCNs'. This limited function is confirmed in the Claimant's own Linked In page, where they proclaim 'Civil Enforcement Ltd process and administer Parking Charge Notices (PCN's) on the behalf of UK Small Businesses and Major UK Brands.'

6. Unlike in the Supreme Court case of ParkingEye Ltd v Beavis [2015] UKSC 67, there is no sentence in the signage that offers or attempts to create a contract between this Claimant and a driver. A parking management firm could use wording to make themselves personally liable on the contract and they could make a contractual offer themselves by saying 'by parking at this site you, the driver, are entering into a contract with us' (or words to that effect) but there is no such contract on the signs. In fact, at no point is a driver told that they are entering into any contractual relationship.

7. The term and the licence to park is made by the principal, Wells Harbour Commissioners. In one image, the Claimant's sign has covered up a larger one that also says 'Order of The Wells Harbour Commissioners' but the words are still just about visible when taken in the context of other images and at the entrance, it is clear that the licence is offered by, and the site maintained by, the Port of Wells Harbour Commissioners, who are the disclosed principal.

8. Therefore, unlike in ParkingEye v Beavis, this Claimant has placed their service, and themselves, in the position of an agent/broker/middle-man, making the bargain for another party and collecting monies (the parking fees from the machine) for that party. The Defendant avers that this Claimant does not retain nor pay VAT on the tariffs and they have no possessory title in this land. Fatally to their claim, the Claimant made no offer of a contract to the driver, at all. The Claimant is put to strict proof if their position is to the contrary of that stated by this Defendant, who takes the point that the principles established by the authority of Fairlie v Fenton (1870) LR 5 Exch 169 apply and there is no contractual relationship between this Claimant and the Defendant.

9.The car park in question is owned by the Wells Harbour Commissioners and is governed entirely under statutory control by byelaws, regulations and subordinate rules stated clearly by the car park signs which display the authority of such with the wording "BY ORDER OF THE WELLS HARBOUR COMMISSIONERS"

10. The Claimant is put to strict proof that it has sufficient proprietary interest in the land, or that it has the necessary and lawful authorisation from the landowner to issue parking charge notices at this Harbour location, and specifically, that Civil Enforcement LTD is lawfully authorised in it,s own name to pursue payment from a registered keeper via a small claim. This point is vital for the Claimant to evidence, and it will not be enough merely to produce a contract from the Wells Harbour Commissioners because the legal position is that registered keepers cannot be held liable for parking charges at this Port. Liability cannot pass from driver to keeper , because this is not 'relevant land' under Schedule 4 of the Protection of Freedoms Act 2012 ('the POFA') which says at paragraph 3(1)(c):

''In this Schedule ''relevant land'' means any land (including land above or below ground level) other than [...] any land [...] on which the parking of a vehicle is subject to statutory control. 3(3) For the purposes of sub-paragraph (1)(c) the parking of a vehicle on land is ''subject to statutory control'' if any statutory provision imposes a liability (whether criminal or civil, and whether in the form of a fee or charge or a penalty of any kind) in respect of the parking on that land of vehicles generally or of vehicles of a description that includes the vehicle in question. [...] ''statutory provision'' means any provision (apart from this Schedule) contained in - (a) any Act (including a local or private Act), whenever passed; or (b) any subordinate legislation, whenever made, and for this purpose ''subordinate legislation'' means an Order in Council or any order, regulations, byelaws or other legislative instrument.''

11. There is legislation in place at [Port of Wells car park ] thus this location is not ''relevant land" under the POFA definition, and therefore parking matters incurring a charge or 'penalty fine' can only be pursued by the Harbour Master through the magistrates court. This is outside of the jurisdiction of any private parking company using the small claims track. This view is further supported by the Department for Transport's 2012 Guidance about this section of the POFA.

12. The (DFT) clarify the question at schedule 4: ''On what type of land does Schedule 4 apply? 4.1 The provisions in Schedule 4 are intended to apply only on private land in England and Wales. Public highways are excluded as well as any parking places on public land which are either provided or controlled by a local authority (or other government body). Any land which already has statutory controls in relation to the parking of vehicles (such as byelaws applying to airports, ports and some railway station car parks) is also excluded.''

13. In relation to parking on private land , it is settled law from the Supreme court, that a parking charge must be set at a level which includes recovery of the cost's of operating a scheme .However this claimant is claiming a global sum of £182. This figure is a penalty, far exceeding the £85 parking charge in the Parking eye LTD v Beavis case .The global sum claimed is unconscionable and it was not shown in large lettering on any consumer signs, and it is averred that the charge offends against schedule 2 of the consumer rights act 2015 ( 'the CRA') , where s71 (2) creates a duty on the court to consider the fairness of a consumer contract .The Court's attention is drawn ( but not limited to) parts 6,10, 14 and 18 of the list of terms that are likely to be unfair.

14.Even if the Claimant had shown the global sum claimed in the largest font on clear and prominent signs -which is denied-they are attempting double recovery of costs. The sum exceeds the maximum amount which can be recovered from a registered keeper , as prescribed in schedule 4 (5) of the Protection of Freedom Act 2012 ('the POFA')

15. At the Bradford County Court, District Judge Claire Jackson (now HHJ Jackson, a Specialist Civil Circuit Judge) decided to hear a 'test case' a few months ago, where £60 had been added to a parking charge despite Judges up and down the country repeatedly disallowing that sum and warning parking firms not to waste court time with such spurious claims. That case was Excel v Wilkinson: G4QZ465V, heard in July 2020 and leave to appeal was refused and that route was not pursued. The Judge concluded that such claims are proceedings with 'an improper collateral purpose'. This Judge - and others who have since copied her words and struck dozens of cases out in late 2020 and into 2021 - went into significant detail and concluded that parking operators (such as this Claimant) are seeking to circumvent CPR 27.14 as well as breaching the Consumer Rights Act 2015. DJ Hickinbottom has recently struck more cases out in that court area, stating: ''I find that striking out this claim is the only appropriate manner in which the disapproval of the court can be shown''.

16. Whilst quantified costs can be considered on a standard basis, this Claimant's costs are wholly disproportionate and do not stand up to scrutiny. In fact it is averred that the Claimant has not paid or incurred any added costs and cannot plead a case in damages at all. Any debt collection letters were either sent by a third party which offers a 'no collection, no fee' service, or were a standard feature of a low cost business model. The Beavis case is the authority for recovery of the parking charge itself and no more, since that sum is, by definition, already hugely inflated for profit, not loss, and the Judges held that a parking firm not in possession cannot plead their case in damages, as none exist.

17. Should this claim continue, the Claimant will no doubt try to mislead the court by pointing to their Trade Association ‘ATA’ Code of Practice (‘CoP’) that now includes a hastily-added clause 'allowing' added costs/damages. The Defendant points out that the CoP is a self-serving document, written in the parking firms’ interests. Further, the ‘admin fee’ model was reportedly invented by a member of the British Parking Association Board, Gary Osner, whose previous firm, Roxburghe (UK) Limited, folded after being declared ‘unfit’ by the Office of Fair Trading who refused to renew their consumer credit licence due to ‘unfair and misleading’ business practices. Mr Osner states in an article that has been in the public domain since 2018: ''I created the model of ‘admin fees’ for debt recovery because ticket value was so low that nobody would make any money. Parking is business and business is about money, after all.''

18. The two competing ‘race to the bottom’ ATAs have engineered a veil of legitimacy to protect this industry for too long. They are not regulators and have failed consumers so badly, that Parliament is currently working on replacing them with a new CoP overseen by the Secretary of State, following the enactment of the Parking (Code of Practice) Act 2019. Many courts have now recognised that a predatory parking firm Claimant using unfair and predatory business practices and inflating their claims with false ‘admin fees’, is not the ‘innocent party’ in a dispute. In stark contrast to the BPA Board member’s mindset, the will of Parliament as set out in the new 2019 Act is very much consumer-focussed, aiming for: ''good practice...in the operation or management of private parking facilities as appears to the Secretary of State to be desirable having regard to the interests of persons using such facilities.''

19. In the alternative, the defence is prejudiced and the court is invited to note that, contrary to the Pre-Action Protocol for Debt Claims, the Letter Before Claim omitted evidence of any breach and failed to append the wording of the sign or consumer notice. Further, the Particulars of Claim are embarrassing and incoherent, lacking specificity re the location of the event and status of the contracting parties and failing to detail any conduct or liability that could give rise to a cause of action. There is insufficient detail to ascertain the nature, basis and facts of the case but the sum claimed includes unrecoverable costs/damages and is clearly an abuse of process.

20. In summary , the Claimant cannot reasonably recover an additional three figure sum in damages or costs to pursue an alleged £100 debt. The POFA states that the maximum sum that may be recovered from a registered keeper is the charge stated on a compliant NTK, and only if all requirements of Schedule 4 are met. This is not the case in this claim, in any respect, and there was no breach of any 'relevant obligation' or 'relevant contract' at all.

21. The Defendant denies the claim in its entirety voiding any liability to the claimant for all amounts claimed due to the aforementioned reasons. The Court is invited to dismiss the Claim, and to allow such Defendant's costs as are permissible under Civil Procedure Rule 27.14.

Coupon-mad

I'd add a line here to make it clear your case is not just based upon the POFA alone:

Whilst it is admitted that the defendant was the keeper, the mandatory requirements to establish 'keeper liability' have not been met and the defendant is not liable in law.  The Defendant also takes the points that there are no contractual terms or offer from this Claimant on the signs, which disclose a principal; the signs are inadequate and the Claimant has enhanced their claim by a sum of £82 that are not true costs at all.  That sum was not expended but even if it was, it was not on the signs and in any case, cannot be added on top of an already almost doubled 'parking charge'.