Napier Parking company, small claims court defence

Roasted_Lemon

Hi,

If someone can read my defence letter against a parking company fine, which has been escalated to small claims court, specifically with 'Napier Parking' company. The claim is vague and states 'no valid payment made' however I have bank statement evidence to prove otherwise.

If there is any adjustments that is needed, please let me know. see below: This is just the relevant bits. the title etc has not been included. Just the defence itself and layout.

1. The Defendant denies that the Claimant is entitled to relief in the sum claimed, or at all. It is denied that any conduct by the driver was in breach of any term. Further, it is denied that this Claimant (understood to have a bare licence as agents) has standing to sue or form contracts in their own name. Liability is denied, whether or not the Claimant is claiming 'keeper liability', which is unclear from the boilerplate text in the Particulars of Claim ('the POC').

The facts known to the Defendant:

1. The facts in this defence come from the Defendant's own knowledge and honest belief. Conversely, the Claimant sets out a cut-and-paste incoherent and sparse statement of case. The POC is devoid of any detail and even lacks specific breach allegation(s), making it very difficult to respond. However, it is admitted that the Defendant was the registered keeper and the driver of the vehicle.
2. It is acknowledged that on July 14, 2025, the Defendant's motor vehicle entered the St Johns Rd Car Park located in Brimingham, B11 4RG. Upon arrival, the car park was at full capacity, forcing the Defendant to wait for an available parking space for a duration of 15 minutes. Once a viable parking space became vacant, the Defendant ultimately decided to park the vehicle in question. The duration of stay was electronically paid at the designated parking meter for the appropriate period. The Defendant holds a bank statement confirming payment to Napier Parking Limited. The claim is denied in full.
3. The International Parking Community (IPC) Code of Practice specifically delineates, in Schedule 1 under the title of "Signage," the following: “If parking enforcement takes place outside of daylight hours you should ensure that signs are illuminated or there is sufficient other lighting.”
4. Signage at this site is unlit and in minuscule text. The Claimant's case is likely to rely upon alleged "clear display" of the terms and conditions. This would be false and misleading. The situation at this location is made worse by poor placement of the sparse signs which are at an angle on approach, cannot be read from a car and do not meet the statutory requirements for prominence and 'adequate notice'. Any terms and conditions were not seen, let alone agreed. There was no fair opportunity to learn that the car park was subject to any restrictions.
5. Based on these previous points, it is clear that a contract could not have been formed between the Claimant and the Defendant because the necessary conditions for forming a contract were not met.
6. The Claimant will concede that no financial loss has arisen and that in order to impose an inflated parking charge, as well as proving a term was breached, there must be:

(i). a strong 'legitimate interest' extending beyond mere compensation for loss, and

(Ii). 'adequate notice' of the 'penalty clause' charge which, in the case of a car park,requires prominent signs and lines.

1. The Defendant denies (i) or (ii) have been met. The charge imposed, in all the circumstances is a penalty, not saved by Parkingeye Ltd v Beavis [2015] UKSC67('the Beavis case'), which is fully distinguished.

Exaggerated Claim and 'market failure' currently being addressed by UK

Government

1. The alleged 'core debt' from any parking charge cannot exceed £100 (the industry cap). It is denied that any 'Debt Fees' or damages were actually paid or incurred by this Claimant, who is put to strict proof of:

(i). the alleged breach, which is not pleaded in the POC and requires further and better particulars, and

(ii). a breakdown of how they arrived at the enhanced sum in the POC, including how interest was calculated, which looks to be improperly applied on the entire inflated sum, as if that was all overdue on the day of the alleged event.

1. The Defendant avers that this claim is unfair and inflated and it is denied that any sum is due, whether in debt or damages. This Claimant routinely pursues an unconscionable fixed sum added per PCN, despite knowing that the will of Parliament is to ban it.
2. This case is a classic example where adding exaggerated fees funds the 'numbers game' of bulk litigation of weak and/or archive parking cases. MoJ statistics of bulk litigators reveal that there are several hundred thousand parking claims per annum, with some 90% causing default CCJs totalling hundreds of millions of pounds. No checks and balances are likely to have been made to ensure facts, merit or a proper cause of action (given away by the woefully inadequate POC).
3. The Department for Levelling Up, Housing and Communities ('the DLUHC') published a statutory Parking Code of Practice in February 2022.

The Ministerial Foreword is damning:"Private firms issue roughly 22,000 parking tickets every day, often adopting a labyrinthine system of misleading and confusing signage, opaque appeals services, aggressive debt collection and unreasonable fees designed to extort money from motorists."

1. Despite legal challenges delaying the Code - marked as temporarily withdrawn - it is thankfully 'live' after a draft Impact Assessment (IA) was published on 30th July

2023. The Government's analysis exposes what they say are industry-gleaned facts about supposed 'fees'. Paragraphs 4.31 and 5.19 state that the parking industry has shown the DLUHC that the true minor cost of what the former calls debt recovery or 'enforcement' (= preaction) stage totals a mere £8.42 per case (not per PCN). With that in mind, it is clear that the extant claim has been enhanced by an extreme sum, believed to be routinely retained by the litigating legal team, not the Claimant. In this Claim it is additional to the intended 'legal representatives fees' cap set within small claims track rules. This conduct has been examined and found - including in a detailed judgment by Her Honour Judge Jackson, now a specialist Civil High Court Judge on the Leeds/Bradford circuit - to constitute 'double recovery'. The Defendant takes that position. The draft IA shows that the intimidating letter-chains actually cost 'eight times less' than the seemingly 'price-fixed' +£70 per PCN. This causes consumer harm in the form of almost half a million wrongly-enhanced CCJs each year, that District Judges are powerless to prevent. This false fee was enabled by the self-serving Codes of Practice of the rival parking Trade Bodies who suddenly aligned in 2021 re allowing +£70, each led by a Board of the very parking operators and debt firms who stood to gain from it. It is denied that the purported damages/fee sought was incurred or is recoverable. Attention is drawn to paras 98, 100, 193, 198 of Beavis. 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 ratified by the CoA) held in paras 419-428 that 'admin costs' inflating a parking charge to £135 was not a true reflection of the cost of template letters and 'would appear to be penal'. This Claimant has not incurred costs. A parking charge model already includes what the Supreme Court called an 'automated letter-chain' and it is a model that generates a healthy profit. In Beavis, there were 4 pre-action letters/reminders and the

£85 'PCN' was held to more than cover the minor costs of the operation. The DLUHC's IA confirms that the parking charge more than covers the minor costs of the letters (NB: the debt collectors do not charge anything in failed collection cases). Whilst the new Code is not retrospective, all non-monetary clauses went unchallenged by the parking industry. The 2022 DLUHC Code will replace the selfserving BPA & IPC Codes, which are not regulation and carry limited weight. In a clear steer for the Courts and for the avoidance of doubt: the DLUHC say they are addressing 'market failure'. In addition, pursuant to Schedule 4 paragraph 4(5) of the Protection of Freedoms Act 2012 ('the POFA') the sum claimed exceeds the maximum potentially recoverable from a registered keeper. Further, the Claimant is put to strict proof of POFA compliance. The Defendant avers that the DLUHC's analysis now overrides plainly wrong assumptions made by Circuit Judges steered by Counsel in astonishingly weak appeal cases that the parking industry engineered their way: Britannia v Semark-Jullien, One Parking Solution v Wilshaw, Vehicle Control Services v Ward and Vehicle Control Services v Percy. Far from being persuasive, regrettably these one-sided appeals cherry-picked litigant-in-person consumers without the wherewithal to appeal. Incorrect presumptions were made in every case; and there were major evidence discrepancies (e.g., in Wilshaw, where the Judge was also oblivious to the DVLA KADOE requirement for landowner authority). One Judge inexplicably sought out for himself and quoted from the wrong Code of Practice (Percy). In Ward, a few seconds' emergency stop out of the control of the driver was wrongly aligned with the agreed contract in Beavis. The Defendant avers that there was no agreement to pay a parking charge or added 'damages' which were not even incurred, let alone quantified in bold, prominent text. This Claimant failed to erect well-placed, large and readable signs on a par with the yellow & black warnings seen in Beavis, and unlike the signage requirements set out in the DLUHC Code which reflects the already statutory requirement for 'prominence' (Consumer Rights Act 2015 - the 'CRA').

CRA breaches Section 71 CRA creates a statutory duty upon Courts to consider the test of fairness whether a party raises it or not. Claiming costs on an indemnity basis is unfair, per the Unfair Contract Terms Guidance (CMA37, para 5.14.3): The CRA introduced new requirements for 'prominence' of both terms and 'consumer notices'. In a parking context, this includes a test of fairness and clarity of 'signs & lines' and all communications intended to be read by consumers. Signage must be prominent (lit in hours of darkness/dusk) and all terms must be unambiguous and contractual obligations clear. The Defendant avers that the CRA has been breached due to unfair/unclear terms and notices, pursuant to s62 and paying regard to examples 6, 10, 14 & 18 of Schedule 2 and the duties of fair/open dealing and good faith (NB: this does not necessarily mean there has to be a finding of bad faith). ParkingEye v Beavis is distinguished Unlike in Beavis, the penalty rule remains engaged, not least due to the unconscionable added 'Fee'. The CRA covers disproportionate sums, which are not exempt from being assessed for fairness because a 'fee' is not the core price term and neither was it prominently proclaimed on the signs. The Supreme Court held that deterrence is likely to be penal if there is a lack of a 'legitimate interest' in performance extending beyond the prospect of compensation flowing directly from alleged breach. The intention cannot be to punish a driver, nor to present them with hidden terms or cumbersome obligations ('concealed pitfalls or traps'). In the present case, the Claimant has failed those tests, with small signs, hidden terms and minuscule small print that is incapable of binding a driver. Court of Appeal authorities about a lack of ‘adequate notice’ of a parking charge include:

1. Spurling v Bradshaw [1956] 1 WLR 461 (Lord Denning's ‘red hand rule’) and
2. Thornton v Shoe Lane Parking Ltd [1970] EWCA Civ2,

both leading authorities that a clause cannot be incorporated after a contract has been concluded; and

1. Vine v London Borough of Waltham Forest: CA 5 Apr 2000, where Ms Vine won because it was held that she had not seen the terms by which she would later be bound, due to "the absence of any notice on the wall opposite the parking space''.
2. Fairness and clarity of terms and notices are paramount in the DLUHC Code and these clauses are supported by the BPA & IPC. In Parking Review, solicitor Will Hurley, CEO of the IPC, observed: "Any regulation or instruction either has clarity or it doesn’t. If it’s clear to one person but not another, there is no clarity. The same is true for fairness. Something that is fair, by definition, has to be all-inclusive of all parties involved – it’s either fair or it isn’t."

Lack of standing or landowner authority, and lack of ADR

1. DVLA data is only supplied if there is an agreement flowing from the landholder (ref: KADOE rules). It is not accepted that this Claimant (an agent of a principal) has authority to form contracts at this site in their name. The Claimant is put to strict proof of their standing to litigate.
2. The Claimant failed to offer a genuinely independent Alternative Dispute Resolution (ADR). The DLUHC Code shows that genuine disputes such as this should see PCNs cancelled, had a fair ADR existed. The rival Trade Bodies' time-limited and opaque 'appeals' services fail to properly consider facts or rules of law and reject most disputes: e.g. the IAS upheld appeals in a woeful 4% of decided cases (2020 Annual Report). This consumer blame culture and reliance upon their own 'appeals service' (described by MPs as a kangaroo court and about to be replaced by the Government) should lead Judges to know that a fair appeal was never on offer.

Conclusion There is now evidence to support the view - long held by many District Judges that these are knowingly exaggerated claims that are causing consumer harm. The July 2023 DLUHC IA analysis shows that the usual letter-chain costs eight times less than the sum claimed for it. The claim is entirely without merit and the POC embarrassing. The Defendant believes that it is in the public interest that claims like this should be struck out. In the matter of costs, the Defendant seeks: standard witness costs for attendance at Court, pursuant to CPR 27.14, and a finding of unreasonable conduct by this Claimant, and further costs pursuant to CPR 46.5. 33. Attention is drawn to the (often-seen) distinct possibility of an unreasonably late Notice of Discontinuance. Whilst CPR r.38.6 states that the Claimant is liable for the Defendant's costs after discontinuance (r.38.6(1)) this does not 'normally' apply to claims allocated to the small claims track (r.38.6(3)). However, the White Bookstates (annotation 38.6.1): "Note that the normal rule as to costs does not apply if a claimant in a case allocated to the small claims track serves a notice of discontinuance although it might be contended that costs should be awarded if a party has behaved unreasonably (r.27.14(2)(dg))." Statement of Truth I believe that the facts stated in this defence 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. Signature: Date:

Coupon-mad

That's not the current Template Defence.

Le_Kirk

https://forums.moneysavingexpert.com/discussion/comment/81918064#Comment_81918064

……… nor is it going to fit in MCOL.

Roasted_Lemon

can you guide me in what is the current template?

Le_Kirk

From here, click back once and you will be on the front page of the forum; there you will see the announcements, one of them is the template defence.

Roasted_Lemon

I have had a look at the template used.

I have drafted a response below.

Would this be acceptable? or Should I remove or add anything? Any help is much appreciated.

1. The Defendant denies that the Claimant is entitled to relief in the sum claimed, or at all. It is denied that any conduct by the driver was in breach of any term. Further, it is denied that this Claimant (understood to have a bare licence as agents) has standing to sue or form contracts in their own name. Liability is denied, whether or not the Claimant is claiming 'keeper liability', which is unclear from the boilerplate text in the Particulars of Claim ('the POC').

2. The facts in this defence come from the Defendant's own knowledge and honest belief. Conversely, the Claimant sets out a cut-and-paste incoherent and sparse statement of case. The POC is devoid of any detail and even lacks specific breach allegation(s), making it very difficult to respond. However, it is admitted that the Defendant was the registered keeper and the driver of the vehicle.

3. It is acknowledged that on July 14, 2025, the Defendant's motor vehicle entered the St Johns Rd Car Park located in Brimingham, B11 4RG. Upon arrival, the car park was at full capacity, forcing the Defendant to wait for an available parking space for a duration of 15 minutes. Once a viable parking space became vacant, the Defendant ultimately decided to park the vehicle in question. The duration of stay was electronically paid at the designated parking meter for the appropriate period. The Defendant holds a bank statement confirming payment to Napier Parking Limited. The claim is denied in full.

4. The allegation(s) and heads of cost are vague and liability is denied for the sum claimed, or at all. At the very least, interest should be disallowed; the delay in bringing proceedings lies with the Claimant. This also makes retrieving material documents/evidence difficult, which is highly prejudicial. The Defendant seeks fixed costs (CPR 27.14) and a finding of unreasonable conduct and further costs (CPR 46.5). The Defendant has little recollection of events, save as set out below and to admit that they were the driver.

5. It is neither admitted nor denied that a term was breached but to form a contract, there must be an offer, acceptance, and valuable consideration (absent in this case). The Consumer Rights Act 2015 (s71) mandates a 'test of fairness' duty on Courts and sets a high bar for prominence of terms and 'consumer notices'. Paying regard to Sch2 (examples 6, 10, 14 & 18), also s62 and the duties of fair, open dealing/good faith, the Defendant notes that this Claimant reportedly uses unclear (unfair) terms/notices. On the limited information given, this case looks no different. The Claimant is put to strict proof with contemporaneous photographs.

6. DVLA keeper data is only supplied on the basis of prior written landowner authority. The Claimant (an agent) is put to strict proof of their standing to sue and the terms, scope and dates of the landowner agreement, including the contract, updates, schedules and a map of the site boundary set by the landowner (not an unverified Google Maps aerial view).

7. To impose a PC, as well as a breach, there must be: (i) a strong 'legitimate interest' extending beyond compensation for loss, and (ii) 'adequate notice' (prominence) of the PC and any relevant obligation(s). None of which have been demonstrated. This PC is a penalty arising as a result of a 'concealed pitfall or trap', poor signs and covert surveillance, thus it is fully distinguished from ParkingEye v Beavis [2015] UKSC67.

8. Attention is drawn to (i) paras 98, 100, 193, 198 of  Beavis (an £85 PC comfortably covered all letter chain costs and generated a profit shared with the landowner) and also to (ii) the binding judgment in ParkingEye v Somerfield Stores ChD [2011] EWHC 4023(QB) which remains unaffected by Beavis and stands as the only parking case law that deals with costs abuse. HHJ Hegarty held in paras 419-428 (High Court, later ratified by the CoA) that 'admin costs' inflating a £75 PC (already increased from £37.50) to £135 were disproportionate to the minor cost of an automated letter-chain and 'would appear to be penal'.

9. The Parking (Code of Practice) Act will curb rogue conduct by operators and their debt recovery agents (DRAs). The Government recently launched a Public Consultation considered likely to bring in a ban on DRA fees, which a 2022 Minister called ‘extorting money from motorists’. They have identified in July 2025: 'profit being made by DRAs is significantly higher than ... by parking operators' and 'the high profits may be indicative of these firms having too much control over the market, thereby indicating that there is a market failure'.

10. Pursuant to Sch4 of the Protection of Freedoms Act 2012 ('POFA') the claim exceeds the maximum sum and is unrecoverable: see Explanatory Note 221: 'The creditor may not make a claim against the keeper ... for more than the amount of the unpaid parking related charges as they stood when the notice to the driver was issued (para 4(5))'. Late fees (unknown to drivers, not specified on signs) are not 'unpaid parking related charges'. They are the invention of 'no win no fee' DRAs. Even in the (unlikely) event that the Claimant complied with the POFA and CoP, there is no keeper liability law for DRA fees.

11. This claim is an utter waste of court resources and it is an indication of systemic abuse that parking cases now make up a third of all small claims. False fees fuel bulk litigation that has overburdened HMCTS. The most common outcome of defended cases is late discontinuance, making Claimants liable for costs (r.38.6(1)). Whilst this does not 'normally' apply to the small claims track (r.38.6(3)) the White Book has this annotation: 'Note that the normal rule as to costs does not apply if a claimant in a case allocated to the small claims track serves a notice of discontinuance although it might be contended that costs should be awarded if a party has behaved unreasonably (r.27.14(2)(dg))'.

TicketFighter99

for PCN defence letters… https://fightmypcn.com/

Coupon-mad

That is not the current Template Defence in the thread at the top of the forum.

My signature tells everyone where to click. You have two links to page one right here on this page.

Roasted_Lemon

I have sifted through numerous threads and posts and newbie guides.

I have put together the defence based on what is available and seen throughout the threads and information.

My questions is because it is MCOL so limited lines. Do I put the following in as well or strictly just the defence?

Claim No.: xxxxxxxxx

Between

Napier Parking Ltd

(Reference number: xxxxxxx)

(Claimant)

- and -

xxxxx xxxxxxx

(Defendant)

My defence with the obvious edited para 3. everything else is the same.

1. The Claimant’s sparse case lacks specificity and does not 
   comply with CPR 16.4, 16PD3 or 16PD7, failing to 'state all facts 
   necessary for the purpose of formulating a complete cause of 
   action'. Further, the Claimant has improperly added a false 'fee' 
   or damages to the original Parking Charge (PC). This sum is not 
   legally recoverable and constitutes an attempt at double recovery, 
   which is unreasonable conduct under CPR 27.14(2)(g). The binding 
   Supreme Court judgment in ParkingEye Ltd v Beavis [2015] UKSC 67 
   held that an £85 parking charge more than covered all the 'costs 
   of enforcement' which HHJ Moloney had listed as the pre-action 
   work of a DVLA look-up and a simple automated letter chain, 
   including a LBC. The same heads of cost cannot lawfully be counted 
   twice and interest should also be disallowed. Exaggerated claims 
   for impermissible sums are good reason for judges to intervene and 
   the court is invited to strike out the claim using its powers 
   under CPR 3.4.
2. The allegation(s) are vague and liability is denied for the sum 
   claimed, or at all. The delay in bringing proceedings lies with 
   the Claimant, making retrieving material evidence difficult, which 
   is highly prejudicial. The Defendant has little knowledge of 
   events, save as set out below and to admit that they were the 
   registered keeper AND Driver.
3. It is acknowledged that on July xxx, xxxx, the Defendant's motor 
   vehicle entered the St Johns Rd Car Park located in Brimingham, 
   B11 4RG. Upon arrival, the car park was at full capacity, forcing 
   the Defendant to wait for an available parking space for a 
   duration of 15 minutes. Once a viable parking space became vacant, 
   the Defendant ultimately decided to park the vehicle in question. 
   The duration of stay was electronically paid at the designated 
   parking meter for the appropriate period. The Defendant holds a 
   bank statement confirming payment to Napier Parking Limited. The 
   claim is denied in full.
4. It is neither admitted nor denied that a term was breached but 
   to form a contract, there must be an offer, acceptance, and 
   valuable consideration (absent in this case). The Consumer Rights 
   Act 2015 (s71) mandates a 'test of fairness' duty on Courts and 
   sets a high bar for prominence of terms and 'consumer notices'. 
   Paying regard to Sch2 (examples 6, 10, 14 & 18), also s62 and the 
   duties of fair, open dealing/good faith, the Defendant notes that 
   this Claimant reportedly uses unclear (unfair) terms/notices. On 
   the limited information given, this case looks no different. The 
   Claimant is put to strict proof with contemporaneous photographs.
5. DVLA keeper data is only supplied on the basis of prior written 
   landowner authority. The Claimant (an agent) is put to strict 
   proof of their standing to sue and the terms, scope and dates of 
   the landowner agreement, including the contract, updates, 
   schedules and a map of the site boundary set by the landowner (not 
   an unverified Google Maps aerial view).
6. To impose a PC, as well as a breach, there must be: (i) a 
   strong 'legitimate interest' extending beyond compensation for 
   loss, and (ii) 'adequate notice' (prominence) of the PC and any 
   relevant obligation(s). None of which have been demonstrated. This 
   PC is a penalty arising as a result of a 'concealed pitfall or 
   trap', poor signs and covert surveillance, thus it is fully 
   distinguished from Beavis.
7. Attention is drawn to:

(i) paras 98, 100, 193, 198 of Beavis (an £85 PC covered all costs 
and generated a huge profit shared with the landowner); the court 
should also read paragraph 3.4 of the original judgment by HHJ 
Moloney in Beavis, confirming what that authority means by 'costs 
of the operation', and

(ii) the binding judgment in ParkingEye v Somerfield Stores ChD 
[2011] EWHC 4023(QB) which remains unaffected by Beavis and stands 
as the only parking case law that references costs abuse. HHJ 
Hegarty held in paras 419-428 (his judgment later ratified by the 
CoA) that 'costs' inflating a £75 PC (already increased from 
£37.50) to £135 were disproportionate to the very minor cost of a 
letter-chain and 'would appear to be penal'. The court should note 
that HHJ Moloney referenced this case in Beavis.

1. The Parking (Code of Practice) Act will curb rogue conduct by 
   operators and debt recovery agents (DRAs). The Government launched 
   a Public Consultation likely to herald a ban on double recovery 
   'fees', which the relevant 2022 Minister called ‘extorting money 
   from motorists’. Both the previous and present Governments found 
   that the high profits may be indicative of firms having too much 
   control 'indicating that there is a market failure'.
2. Pursuant to Sch4 of the Protection of Freedoms Act 2012 
   ('POFA') the claim exceeds the maximum sum and is unrecoverable: 
   see Explanatory Note 221: 'The creditor may not make a claim 
   against the keeper ... for more than the amount of the unpaid 
   parking related charges as they stood when the notice to the 
   driver was issued (para 4(5))'. There is no keeper liability for 
   added false fees and the POFA specifically states that 'double 
   recovery' is not allowed if a creditor uses any other remedy.
3. The Defendant seeks fixed costs (CPR 27.14) and a finding of 
   unreasonable conduct and further costs (CPR 46.5). Parking cases 
   now make up a third of all small claims which has overburdened 
   HMCTS, causing the most CCJs of all sectors yet almost invariably 
   discontinuing defended cases before hearings, which indicates a 
   deliberate business model of systemic abuse and makes Claimants 
   liable for costs (r.38.6(1)). Whilst this does not 'normally' 
   apply to the small claims track (r.38.6(3)) the White Book has 
   this annotation: 'Note that the normal rule as to costs does not 
   apply if a claimant in a case allocated to the small claims track 
   serves a notice of discontinuance although it might be contended 
   that costs should be awarded if a party has behaved unreasonably 
   (r.27.14(2)(dg))'.

IF THIS ISNT CORRECT, WHY IS IT NOT CORRECT? IS THE WORDINGS INCORRECT? WILL SOMETHING BE JUST DISMISSED BY THE JUDGE IF STATED?

Thanks for having a look appreciate it.

Coupon-mad

Looks fine. That is the Template Defence we signposted you to and your para 3 is fine.