DCB Legal Claim defence

Just_Cruising · 13 May at 7:43PM

Also, I didn't get a lot of time before/after work, but I have looked for autism defences without much success. I've added the following:

14. I and my daughter are protected by the Equality Act 2010 and entitled to more parking time than the fixed period available to other users. It is illegal for a trader to impose an inflexible time limit on people with 'protected characteristics' and their carers. Term 5 in the Service Level Agreement between the retail park owner and Euro Car Parks Limited state clearly that "Disabled badge holders will not be exempt from the maximum stay of the site", ignoring their responsibilities to people with protected characteristics.

15. My daughter experiences sensory sensitivities, particularly to noise and bright lights. This can make it difficult to focus on tasks and can contribute to anxiety or overwhelm. She also has executive function difficulties and struggles with time management. This can include difficulties with handling tasks like shopping, and necessitates distracting her with play which makes the overall task take longer and keeping track of time difficult.

Just_Cruising · 13 May at 7:51PM

It actually looks like they've done more than template waffle in their WS:

The Contract

i. The Defendant denies that the Claimant is entitled to relief in the sum claimed. The signs at

“EXHIBIT 2” clearly outlined the Terms of parking and the Defendant was on notice of the

Terms upon entering the land. By parking on the Land, the Defendant accepted the Terms.

These Terms state that the maximum stay duration permitted is 2 hours, and that if the Terms

are breached, the Defendant agrees to pay a Parking Charge of £100.00. During this period, the

Defendant parked on the Land in direct breach of its Terms by remaining on the Land for 2

hours and 35 minutes, and 2 hours and 42 minutes respectively, and therefore, they agreed to

pay a Parking Charge. The Claimant submits they are not seeking more than the original core

debt, however they are now seeking further costs. The Claimant confirms their employees spent

time and resource attempting to recover the debt, as well as instructing external debt recovery

providers, all at a cost to the Claimant. The Claimant submits this is not their usual business

and, but for the Defendant’s refusal to pay, would not have been necessary.

ii. Further to the above, the Defendant alleges that the Claimant has no authority to bring the

Claim. The Claimant confirms that the Landowner instructed them to manage the parking on

the Land and issue Parking Charges to any Vehicle found to be in breach of the Terms of

parking. A copy of the agreement can be seen at “EXHIBIT 1”. It is respectfully submitted that the Claimant has the relevant authority to issue Parking Charges and bring Claims for such in

the event the charges remain outstanding. In any event, the Defendant is a third party to the

Landowner Agreement and privity of Contract applies.

Just_Cruising · 13 May at 7:52PM

The Defendant’s Allegations

vi. For the avoidance of doubt, the Claimant confirms the Defendant is pursued on the balance of

probabilities they were the Driver of the Vehicle on the material dates, as otherwise they would

have nominated a Driver. In any event, the Claimant has complied with the requirements of

POFA and therefore has the right to recover from the Defendant as the Registered Keeper of

the Vehicle in the alternative. Attention is respectfully drawn to “EXHIBIT 5” which clearly

demonstrates the Claimant’s compliance with the same.

vii. The Defendant outlines the Terms stipulate parking is permitted for “customers only”. Whilst

this is accepted, the Charges were issued as the Vehicle remained on the Land in excess of the

maximum stay duration of 2 hours. The Terms on the signs, exhibited at “EXHIBIT 2” were

adequate in respect of overall size, font size, plain English, location, and content. The Plan,

exhibited at “EXHIBIT 4”, demonstrates where the signs were located, and it is submitted they

are adequate to constitute notice of the Terms to the Driver. In the event that a Driver parks

their Vehicle on Land in which they do not own nor have prior authority to park, it is

incumbent upon the Driver to ascertain whether there is a remedy to prevent their unauthorised

parking. It is reasonable to suggest that the Defendant should have sought out the signage on

the Land in any case if they were unsure of the Terms of parking.

viii. The Defendant believes they are not indebted to the Claimant. The signs at “EXHIBIT 2”

clearly outlined the Terms of parking and the Defendant was on notice of the Terms upon

entering the land. By parking on the Land, the Defendant accepted the Terms. These Terms

state that the maximum stay duration permitted is 2 hours, and that if the Terms are breached,

the Defendant agrees to pay a Parking Charge of £100.00. During this period, the Defendant

parked on the Land in direct breach of its Terms and therefore they agreed to pay a Parking

Charge. It is the Defendant’s responsibility to ensure that the Terms of parking are complied

with at all times. If the Defendant was unable to comply with the Terms, they ought to have

sought alternative parking. Had the Defendant adhered to the Terms or simply made payment

upon receipt of the Charge, the Claimant would not have needed to pursue the matter. The

Claimant confirms they have issued legal proceedings only as a last resort to recover the debt.

ix. The Defendant suggests the Particulars of Claim provide “wrong” details in respect of the “date

of PCN”. This is wholly denied. Attention is respectfully drawn to the Claim Form at

“EXHIBIT 6” which clearly states “The PCN(s) were issued on 20/06/2021, 14/01/2023”. As

seen at “EXHIBIT 3”, the Vehicle was present on the Land in breach of the Terms on these

material dates.

x. The Defendant states the Land is “notoriously hard to find parking spaces in”. With respect,

the Defendant was put on notice of the Terms upon entrance to the Land, which clearly outline

the maximum stay duration permitted is 2 hours. It is ultimately the responsibility of the

motorist to ensure they familiarise themselves with the Terms and decide whether to park on

the Land, or exit the Land and seek alternative parking if they are unable to comply with the

same. The Defendant was under no obligation to park on the Land.

Just_Cruising · 13 May at 10:35PM

My latest witness statement:

Name of Witness: XXXXX

Witness Statement No.: One

IN THE COUNTY COURT AT KINGSTON – UPON – THAMES

Claim No.: XXXXX

Between

EURO CAR PARKS LIMITED (Claimant)

V

MR XXXXX (Defendant)

________

WITNESS STATEMENT OF XXXXX

I, Mr XXXXX, of XXXXX will say as follows:

INTRODUCTION

I make this Witness Statement (hereinafter referred to as WS) in readiness for the hearing listed on the first available date after 25th June 2025 at Kingston-upon-thames County Court and in support of my Defence against the Claimant’s claim.

FACTS AND SEQUENCE OF EVENTS.

1. I have in the past used the parking facility at Priory Retail Park – Colliers Wood to attend the retail outlets there. There is a large home furnishings store, a large Currys store, other shops and places to eat. This is a popular retail outlet and car parking places can often take some time to find.

2. Date and Time of the Incident: It is admitted that on the material dates, I was the registered keeper of the vehicle.

3. On the dates in question (several years ago), the claimant’s records show my vehicle entering and exiting the car park in under 3 hours.

4. My experience of shopping with my partner and our autistic daughter (who is now 7 years old but was 3 and 5 years old respectively at the time of the incidents) is that this is not an unreasonable time to spend in these establishments, particularly with a new home to furnish.

5. We used to live in Wimbledon before moving to Purley and then Epsom where we now reside. We have made many visits to the Priory Retail Park in the past with no issues. When we were furnishing our new home, which we bought in 2019, we made several trips back to Wimbledon to purchase goods.

6. I will now make reference to Exhibits 1 and 2. Which are images of the retail park entrance, where there were no mention of parking limitations or charges.

7. The claimant’s Particulars of Claim states that we breached the terms on the signs.

8. Exhibit 3 shows images of the car park in July 2022 from Google Streetview.

9. Exhibit 4 shows an image of the parking signs that show the retail park is for customers only, which we were.

10. Exhibit 5 shows a contrasting image from a case (ParkingEye Ltd v Beavis [2015] UKSC67 ['the Beavis case'] found in favour of the parking owner. The duration and charges are very clear.

11. I contend that I did not breach the terms of the agreement, being unaware that I had entered into a contract as I was a customer of the facilities as I had been many times before.

12. I say that fees were not paid out or incurred by this Claimant, who is to put strict proof of:

(i) The alleged breach, and

(ii) A breakdown of how they arrived at the enhanced amount claimed, including how interest has been calculated, which appears to have been applied improperly on the entire inflated sum, as if that figure was immediately overdue on the day of an alleged parking event.

13. In support of my contention that the sum sought is unconscionably exaggerated and thus unrecoverable, attention is drawn to paras 98, 193, 198 of ParkingEye Ltd v Beavis [2015] UKSC67 ('the Beavis case') in Exhibit 5. Also, ParkingEye Ltd v Somerfield Stores Ltd ChD [2011] EWHC 4023(QB), where the parking charge was £75, discounted to £37.50 for prompt payment. Whilst £75 was reasonable, HHJ Hegarty (decision later ratified by the CoA) held in paras 419-428 that unspecified 'admin costs' inflating a parking charge to £135 was not a true reflection of the cost of a template letter and 'would appear to be penal.

14. The claimant has failed to provide clear evidence that a contract was formed, nor has it shown that the parking charge notices were validly issued. The lack of adequate signage and the unlawful nature of the additional charges further invalidate the claimant’s claim. The claimant’s attempt to impose liability for these inflated charges is unsupported by both statutory law and leading case precedents. I ask the court to dismiss the claim and award appropriate costs for the time and effort expended in defending against these unjust claims.

15. I ask the judge to read the persuasive Judgment from His Honour Judge Murch (August 2023) in the Civil Enforcement v Chan case, and deliver the same outcome given that this Claimant has submitted a similarly vague PoC. It is worth noting that in the Civil Enforcement v Chan case, the PoC, while still ambiguous, did contain a subtle indication of the alleged contravention, specifically regarding the duration of the parking on the premises. In contrast, the PoC in this case lacks even a minimal effort to hint at the nature of the alleged violation. In the Civil Enforcement v Chan case, full costs were awarded to the motorist, and the claim was struck out.

16. I and my daughter are protected by the Equality Act 2010 and entitled to more parking time than the fixed period available to other users. It is illegal for a trader to impose an inflexible time limit on people with 'protected characteristics' and their carers. Term 5 in the Service Level Agreement between the retail park owner and Euro Car Parks Limited state clearly that "Disabled badge holders will not be exempt from the maximum stay of the site", ignoring their responsibilities to people with protected characteristics.

17. My daughter is autistic, with speech and language delay, she experiences sensory sensitivities, particularly to noise and bright lights. She gets very easily dysregulated and it’s difficult to manage her emotions. She struggles with busy environments and this can contribute to heightened anxiety or overwhelm. That can make shopping very stressful and challenging for our family. We need to give her regular breaks to prevent meltdowns and to help her regulate. This makes the overall task take longer and keeping track of time difficult. Any shopping for our family takes much longer than a neurotypical family.

18. Exhibit 6 is my daughter’s Autism Diagnosis which points to further cognitive difficulties on page 24. We have many further assessments.

COSTS ASSESSMENT

Given the significant time and effort required to defend this unjust claim, I respectfully request that the court consider awarding costs under CPR 27.14(2)(g). I have spent considerable time researching, preparing this statement, and attending the hearing. My estimated costs for this are as follows:

• Research and preparation of witness statement (10 Hours): £122

• Travel expenses (Taxi to and from court): £50

• Time off work (half day): £95

Totalling: £267

I request that the court consider these costs in its judgment, given the claimant's unreasonable behaviour in pursuing this claim without merit.

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: ________________

Name: Kevin McNally

Dated: 13th May 2025

Coupon-mad · 14 May at 12:00AM

The stuff you quoted is their template waffle!

I don't know why you searched for "autism defence"? Far too niche and you won't find anything really.

Search for:

Equality Act Witness Statement

or

EHRC tours defence

or

EHRC reasonable adjustment parking

etc.

Just_Cruising · 14 May at 11:30AM

Thanks @Coupon-mad that is helpful.

INTRODUCTION

I make this Witness Statement (hereinafter referred to as WS) in readiness for the hearing listed on the first available date after 25th June 2025 at Kingston-upon-thames County Court and in support of my Defence against the Claimant’s claim.

FACTS AND SEQUENCE OF EVENTS.

1. I have in the past used the parking facility at Priory Retail Park – Colliers Wood to attend the retail outlets there. There is a large home furnishings store, a large Currys store, other shops and places to eat. This is a popular retail outlet and car parking places can often take some time to find.

2. Date and Time of the Incident: It is admitted that on the material dates, I was the registered keeper of the vehicle.

3. On the dates in question (several years ago), the claimant’s records show my vehicle entering and exiting the car park in under 3 hours.

4. My experience of shopping with my partner and our autistic daughter (who is now 7 years old but was 3 and 5 years old respectively at the time of the incidents) is that this is not an unreasonable time to spend in these establishments, particularly with a new home to furnish.

5. We used to live in Wimbledon before moving to Purley and then Epsom where we now reside. We have made many visits to the Priory Retail Park in the past with no issues. When we were furnishing our new home, which we bought in 2019, we made several trips back to Wimbledon to purchase goods.

6. I will now make reference to Exhibits 1 and 2. Which are images of the retail park entrance, where there were no mention of parking limitations or charges.

7. The claimant’s Particulars of Claim states that we breached the terms on the signs.

8. Exhibit 3 shows images of the car park from Google Streetview.

9. Exhibit 4 shows a close-up Google Streetview image of the parking signs that show the retail park is for customers only, which we were.

10. Exhibit 5 shows a contrasting image from a case (ParkingEye Ltd v Beavis [2015] UKSC67 ['the Beavis case'] found in favour of the parking owner. The duration and charges are very clear.

11. I contend that I did not breach the terms of the agreement, being unaware that I had entered into a contract as I was a customer of the facilities as I had been many times before.

12. I say that fees were not paid out or incurred by this Claimant, who is to put strict proof of:

(i) The alleged breach, and

(ii) A breakdown of how they arrived at the enhanced amount claimed, including how interest has been calculated, which appears to have been applied improperly on the entire inflated sum, as if that figure was immediately overdue on the day of an alleged parking event.

13. In support of my contention that the sum sought is unconscionably exaggerated and thus unrecoverable, attention is drawn to paras 98, 193, 198 of ParkingEye Ltd v Beavis [2015] UKSC67 ('the Beavis case') in Exhibit 5. Also, ParkingEye Ltd v Somerfield Stores Ltd ChD [2011] EWHC 4023(QB), where the parking charge was £75, discounted to £37.50 for prompt payment. Whilst £75 was reasonable, HHJ Hegarty (decision later ratified by the CoA) held in paras 419-428 that unspecified 'admin costs' inflating a parking charge to £135 was not a true reflection of the cost of a template letter and 'would appear to be penal.

14. The claimant has failed to provide clear evidence that a contract was formed, nor has it shown that the parking charge notices were validly issued. The lack of adequate signage and the unlawful nature of the additional charges further invalidate the claimant’s claim. The claimant’s attempt to impose liability for these inflated charges is unsupported by both statutory law and leading case precedents. I ask the court to dismiss the claim and award appropriate costs for the time and effort expended in defending against these unjust claims.

15. I ask the judge to read the persuasive Judgment from His Honour Judge Murch (August 2023) in the Civil Enforcement v Chan case, and deliver the same outcome given that this Claimant has submitted a similarly vague PoC. It is worth noting that in the Civil Enforcement v Chan case, the PoC, while still ambiguous, did contain a subtle indication of the alleged contravention, specifically regarding the duration of the parking on the premises. In contrast, the PoC in this case lacks even a minimal effort to hint at the nature of the alleged violation. In the Civil Enforcement v Chan case, full costs were awarded to the motorist, and the claim was struck out.

16. I and my daughter are protected by the Equality Act 2010 and entitled to more parking time than the fixed period available to other users. It is illegal for a trader to impose an inflexible time limit on people with 'protected characteristics' and their carers. Term 5 in the Service Level Agreement between the retail park owner and Euro Car Parks Limited state clearly that "Disabled badge holders will not be exempt from the maximum stay of the site", ignoring their responsibilities to people with protected characteristics.

17. My daughter is autistic, with speech and language delay, she experiences sensory sensitivities, particularly to noise and bright lights. She gets very easily dysregulated and it’s difficult to manage her emotions. She struggles with busy environments and this can contribute to heightened anxiety or overwhelm. That can make shopping very stressful and challenging for our family. We need to give her regular breaks to prevent meltdowns and to help her regulate. This makes the overall task take longer and keeping track of time difficult. Any shopping for our family takes much longer than a neurotypical family.

18. Exhibit 6 is my daughter’s Autism Diagnosis which points to further cognitive difficulties on page 24. We have many further assessments.

19. I feel a short 20-30% overstay given the circumstance is discriminatory against my daughter’s disability and in breach of the Equality Act 2010 in particular section 20: Duty to make adjustments.

20(3):The first requirement is a requirement, where a provision, criterion or practice of A's puts a disabled person at a substantial disadvantage in relation to a relevant matter in comparison with persons who are not disabled, to take such steps as it is reasonable to have to take to avoid the disadvantage.

20. In addition, this in breach of the EHRC Equality Act Code of Practice for Service Providers

Sec 119(14.58) - Indirect discrimination will be intentional where the defendant (or defender) knew that certain consequences would follow from their actions and they wanted those consequences to follow. A motive, for example, of promoting business efficiency, does not mean that the act of indirect discrimination is unintentional.

s.19(2)(d)

(5.34) - In a case involving disability if the service provider has not complied with its duty to make relevant reasonable adjustments, it will be difficult for the service provider to show that the treatment was proportionate.

21. A service provider which refuses to make a 'reasonable adjustment' without lawful justification is therefore in breach of their mandatory duties under the statutory Code and their contract is unenforceable with another passage from the EHRC Equality Act Code of Practice for Service Providers:

Unenforceable terms

142(3.14)

A term of a contract that promotes or provides for treatment that is prohibited by the Act is unenforceable. However, this will not prevent a person who is or would be disadvantaged by an unenforceable term from relying on it to get any benefit to which they are entitled.

22. In this case, I feel that the Claimant has not taken our circumstances during these occasions into account and are indirectly discriminating against my daughter and our experience during the day because of a 20 – 30% overstay.

Coupon-mad · 14 May at 11:47AM

Just_Cruising said:

Thanks @Coupon-mad that is helpful.
INTRODUCTION

I make this Witness Statement (hereinafter referred to as WS) in readiness for the hearing listed on the first available date after 25th June 2025 at Kingston-upon-thames County Court and in support of my Defence against the Claimant’s claim.

FACTS AND SEQUENCE OF EVENTS.

1.     I have in the past used the parking facility at Priory Retail Park – Colliers Wood to attend the retail outlets there. There is a large home furnishings store, a large Currys store, other shops and places to eat. This is a popular retail outlet and car parking places can often take some time to find.

2.     Date and Time of the Incident: It is admitted that on the material dates, I was the registered keeper of the vehicle.

3.     On the dates in question (several years ago), the claimant’s records show my vehicle entering and exiting the car park in under 3 hours.

4.     My experience of shopping with my partner and our autistic daughter (who is now 7 years old but was 3 and 5 years old respectively at the time of the incidents) is that this is not an unreasonable time to spend in these establishments, particularly with a new home to furnish.

5.     We used to live in Wimbledon before moving to Purley and then Epsom where we now reside. We have made many visits to the Priory Retail Park in the past with no issues. When we were furnishing our new home, which we bought in 2019, we made several trips back to Wimbledon to purchase goods.

6.     I will now make reference to Exhibits 1 and 2. Which are images of the retail park entrance, where there were no mention of parking limitations or charges.

7.     The claimant’s Particulars of Claim states that we breached the terms on the signs.

8.     Exhibit 3 shows images of the car park from Google Streetview.

9.     Exhibit 4 shows a close-up Google Streetview image of the parking signs that show the retail park is for customers only, which we were.

10. Exhibit 5 shows a contrasting image from a case (ParkingEye Ltd v Beavis [2015] UKSC67 ['the Beavis case'] found in favour of the parking owner. The duration and charges are very clear.

11. I contend that I did not breach the terms of the agreement, being unaware that I had entered into a contract as I was a customer of the facilities as I had been many times before.

12. I say that fees were not paid out or incurred by this Claimant, who is to put strict proof of:

(i) The alleged breach, and

(ii) A breakdown of how they arrived at the enhanced amount claimed, including how interest has been calculated, which appears to have been applied improperly on the entire inflated sum, as if that figure was immediately overdue on the day of an alleged parking event.

13. In support of my contention that the sum sought is unconscionably exaggerated and thus unrecoverable, attention is drawn to paras 98, 193, 198 of ParkingEye Ltd v Beavis [2015] UKSC67 ('the Beavis case') in Exhibit 5. Also, ParkingEye Ltd v Somerfield Stores Ltd ChD [2011] EWHC 4023(QB), where the parking charge was £75, discounted to £37.50 for prompt payment. Whilst £75 was reasonable, HHJ Hegarty (decision later ratified by the CoA) held in paras 419-428 that unspecified 'admin costs' inflating a parking charge to £135 was not a true reflection of the cost of a template letter and 'would appear to be penal.

14. The claimant has failed to provide clear evidence that a contract was formed, nor has it shown that the parking charge notices were validly issued. The lack of adequate signage and the unlawful nature of the additional charges further invalidate the claimant’s claim. The claimant’s attempt to impose liability for these inflated charges is unsupported by both statutory law and leading case precedents. I ask the court to dismiss the claim and award appropriate costs for the time and effort expended in defending against these unjust claims.

15. I ask the judge to read the persuasive Judgment from His Honour Judge Murch (August 2023) in the Civil Enforcement v Chan case, and deliver the same outcome given that this Claimant has submitted a similarly vague PoC. It is worth noting that in the Civil Enforcement v Chan case, the PoC, while still ambiguous, did contain a subtle indication of the alleged contravention, specifically regarding the duration of the parking on the premises. In contrast, the PoC in this case lacks even a minimal effort to hint at the nature of the alleged violation. In the Civil Enforcement v Chan case, full costs were awarded to the motorist, and the claim was struck out.

16. I and my daughter are protected by the Equality Act 2010 and entitled to more parking time than the fixed period available to other users. It is illegal for a trader to impose an inflexible time limit on people with 'protected characteristics' and their carers. Term 5 in the Service Level Agreement between the retail park owner and Euro Car Parks Limited state clearly that "Disabled badge holders will not be exempt from the maximum stay of the site", ignoring their responsibilities to people with protected characteristics.

17. My daughter is autistic, with speech and language delay, she experiences sensory sensitivities, particularly to noise and bright lights. She gets very easily dysregulated and it’s difficult to manage her emotions. She struggles with busy environments and this can contribute to heightened anxiety or overwhelm. That can make shopping very stressful and challenging for our family. We need to give her regular breaks to prevent meltdowns and to help her regulate. This makes the overall task take longer and keeping track of time difficult. Any shopping for our family takes much longer than a neurotypical family.
18. Exhibit 6 is my daughter’s Autism Diagnosis which points to further cognitive difficulties on page 24. We have many further assessments.

19. I feel a short 20-30% overstay given the circumstance is discriminatory against my daughter’s disability and in breach of the Equality Act 2010 in particular section 20: Duty to make adjustments.

20(3):The first requirement is a requirement, where a provision, criterion or practice of A's puts a disabled person at a substantial disadvantage in relation to a relevant matter in comparison with persons who are not disabled, to take such steps as it is reasonable to have to take to avoid the disadvantage.

20. In addition, this in breach of the EHRC Equality Act Code of Practice for Service Providers
Sec 119(14.58) - Indirect discrimination will be intentional where the defendant (or defender) knew that certain consequences would follow from their actions and they wanted those consequences to follow. A motive, for example, of promoting business efficiency, does not mean that the act of indirect discrimination is unintentional.

s.19(2)(d)
(5.34) - In a case involving disability if the service provider has not complied with its duty to make relevant reasonable adjustments, it will be difficult for the service provider to show that the treatment was proportionate.

21. A service provider which refuses to make a 'reasonable adjustment' without lawful justification is therefore in breach of their mandatory duties under the statutory Code and their contract is unenforceable with another passage from the EHRC Equality Act Code of Practice for Service Providers:

Unenforceable terms

142(3.14)

A term of a contract that promotes or provides for treatment that is prohibited by the Act is unenforceable. However, this will not prevent a person who is or would be disadvantaged by an unenforceable term from relying on it to get any benefit to which they are entitled.
22. In this case, I feel that the Claimant has not taken our circumstances during these occasions into account and are indirectly discriminating against my daughter and our experience during the day because of a 20 – 30% overstay.

Remove that last paragraph because you should never be admitting to 'overstay' and they can't have taken your circumstances into account if they didn't know.

What you are describing there is DIRECT discrimination where a trader knows an individual is disabled. Nope. Your point is about INDIRECT discrimination of the shoppers 'at large' a good percentage of whom might have protected characteristics and need more time. Traders have an anticipatory duty to consider the needs of disabled people at large - and that's not just bunging in some wider bays!

With this bit, you can't expect the judge to read Chan if you aren't providing it as an exhibit. And if you are going to use Chan you must also use Akande (search the forum or just grab the words and link to the 2 case transcripts already provided in the first post if thr Template Defence thread...):

"15. I ask the judge to read the persuasive Judgment from His Honour Judge Murch (August 2023)"

I'm disappointed you didn't find the EHRC tours example in the EHRC statutory Code of Practice. I gave you some search words (did you wonder why I included the word tours?).

There are so many cases already written that cite that EHRC Code with much more powerful quotes and using the tours example that is a case study in that code.

Just_Cruising · 14 May at 12:00PM

Apologies, just running out of time and trying to do this at work.

Just_Cruising · 14 May at 12:16PM

Trying again - went direct to the CoP

INTRODUCTION

I make this Witness Statement (hereinafter referred to as WS) in readiness for the hearing listed on the first available date after 25th June 2025 at Kingston-upon-thames County Court and in support of my Defence against the Claimant’s claim.

FACTS AND SEQUENCE OF EVENTS.