Gladstones Letter Before Claim - NPM PCN - No e-Permit - Woodgrange Road E7

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@armz247, @Brenda_R2 is right. You have already done exactly what was advised: you sent the short tactical response, Gladstones replied, and you have now updated the thread so their latest position is recorded. There is no need to send them anything further. I would now leave the utter incompetents at Gladstones alone and wait for the claim.

Their latest response has actually given you several useful points to preserve for the defence and, later, the witness statement.

First, their position on the landowner agreement is pathetically ridiculous. They have confirmed that the document exists, but refuse to provide even a redacted copy because it is supposedly "commercially sensitive", saying it will only be disclosed at the direction of the court, usually 14 days before the hearing.

Commercial sensitivity is not the same as the document being unavailable, nor does it give them some automatic entitlement to conceal the provisions which establish whether NPM actually had authority/standing to operate on this land, issue parking charges, enter into contracts with motorists and litigate in its own name. Irrelevant commercial information can obviously be redacted.

More importantly, 14 days before a small-claims hearing is ordinarily the standard deadline for serving the documents relied upon. It is not some special disclosure privilege enjoyed by the idiots at Gladstones. If the court orders the usual simultaneous exchange of evidence 14 days before the hearing, how is a Defendant supposed to receive the alleged landowner authority for the first time on the same day their own evidence is due, scrutinise it for defects and then address those defects in their witness statement? That issue can be dealt with after the claim is issued, including, if necessary, asking the court for a specific direction requiring earlier disclosure. For now, keep their written refusal.

Their supposed signage evidence is also useful for entirely the wrong reasons. The site photographs they have supplied are dated 13 January 2023. The alleged event was 23 December 2025. So their photographs are nearly three years old and were taken in daylight, whereas the alleged contravention occurred at about 21:08 on a dark December night. Those photographs do not establish what signs were actually present on the material date, still less that they were illuminated and readable in darkness.

The clean image of the sign at the end of their pack is simply a specimen/artwork image. It proves what NPM says its sign looks like; it does not prove that that sign was actually installed, in that form, at the relevant location on 23 December 2025.

There is then a more fundamental problem with the wording of the sign itself. The prominent operative term says:

"Parking is permitted for pre-authorised vehicles (NPM E-Permit)".

So what contractual offer is being made to a vehicle which is NOT pre-authorised?

The sign does not say that an unauthorised motorist may park for £100. It says that parking is permitted for pre-authorised vehicles. The £100 wording lower down says that by parking or remaining the driver accepts liability for failing to comply with the terms, but that does not automatically resolve the basic contractual problem. NPM must still identify an offer made to this particular driver, consideration provided by NPM and conduct amounting to acceptance. If permission to park is expressly confined to pre-authorised vehicles, there is an exceptionally strong argument that a non-permit holder was never offered parking at all. At most, that potentially leaves a question of trespass, which makes NPM's withheld landowner agreement and the precise extent of its authority even more important.

There is also still no proper evidence of a compliant entrance sign at the material date and time. Their site map marks alleged sign locations and one of their old 2023 daytime photographs appears to show a sign near the entrance, but the wording is unreadable. A diagram with green stars does not prove that a particular sign was physically present, positioned correctly and readable to a driver entering the road almost three years later at 21:08 in darkness.

The issue is not simply whether there was "a sign somewhere". Before NPM can rely upon detailed terms further inside the site, it needs to establish that a driver was adequately alerted that they were entering controlled private land and directed to the contractual terms. Their evidence does not establish that. Nor does it establish that the detailed signs themselves were illuminated or otherwise readable at night.

That matters particularly because their own evidence shows the vehicle there for only about 2 minutes 43 seconds. The driver exited shortly after stopping, returned and left. On those facts there is a very obvious issue as to whether the driver was doing no more than stopping long enough to identify the restrictions, consider them and leave, rather than accepting any supposed contractual offer.

So there is no benefit in educating the dimwits at Gladstones any further. They have said they will accept no further submissions anyway, and, as you have already confirmed in reply to @Brenda_R2, you are now simply waiting for the claim unless there is some genuinely new development.

Preserve everything they have sent, including:

• the refusal to disclose the landowner agreement;
  
• the nearly three-year-old daytime signage photographs;
  
• the specimen sign artwork;
  
• the absence of contemporaneous evidence of illuminated/readable entrance signage;
  
• the wording restricting permission to pre-authorised vehicles; and
  
• the absence of the full unedited video which was specifically requested.
  

Let them issue the inevitable claim. We can then deal with whatever defective template Particulars of Claim (PoC) they produce and plead these points properly in the Defence. The detailed evidential demolition comes later. I can guarantee that the PoC in any claim issued by Gladstones is defective.