06-07-2026, 04:30 PM
@Barbudaprince, yes, the L&Q/freeholder communication may help, but it needs to be used carefully.
It does not automatically prove what the position was on the dates of the PCNs because it is later correspondence from June 2026. However, it does show that L&Q recognises the existence of “designated external overflow areas outside the car park gates” and that residents may be directed to use those areas when required. If that is the same hard-standing or informal parking area where the PCNs were issued, it supports the point that the location was not simply some random forbidden area, access road, or place where parking could never be contemplated. It was an area connected with the wider residential parking arrangements.
That is useful if UKCPM try to argue that the vehicle was parked somewhere wholly unauthorised or outside any residential parking arrangement. L&Q’s own communication appears to undermine that. It assists the factual narrative that parking at the site is governed by the residential/estate management arrangements, not simply by UKCPM’s generic signs.
Do not overstate it. The letter also says the arrangement was temporary, first-come-first-served, did not guarantee parking, did not permit obstruction of access routes, and did not amount to general parking permission. So, in the witness statement, you should rely on it only as evidence of the character and use of the area, unless the wording clearly proves that the same permission existed on the actual PCN dates.
On the AST point, simply explain that the tenant names were redacted for privacy reasons. For the updated witness statement, exhibit a minimally redacted copy showing your name, the property address, the tenancy dates, the relevant parking/residential clauses and the execution/signature page. Do not redact anything needed to prove that the AST relates to you and to Wheatstone House.
As for case law, yes, you can still refer to it, but the witness statement should not become a legal essay. The WS should mainly be your factual evidence: that you were a resident, what the AST says, where the vehicle was positioned, what the signs were like, what UKCPM’s own boundary map does or does not cover, what the NtKs did or did not specify, and why their evidence does not prove liability. The legal points can be kept short and tied to those facts. The detailed legal argument can be expanded orally at the hearing or in a short skeleton if needed.
It does not automatically prove what the position was on the dates of the PCNs because it is later correspondence from June 2026. However, it does show that L&Q recognises the existence of “designated external overflow areas outside the car park gates” and that residents may be directed to use those areas when required. If that is the same hard-standing or informal parking area where the PCNs were issued, it supports the point that the location was not simply some random forbidden area, access road, or place where parking could never be contemplated. It was an area connected with the wider residential parking arrangements.
That is useful if UKCPM try to argue that the vehicle was parked somewhere wholly unauthorised or outside any residential parking arrangement. L&Q’s own communication appears to undermine that. It assists the factual narrative that parking at the site is governed by the residential/estate management arrangements, not simply by UKCPM’s generic signs.
Do not overstate it. The letter also says the arrangement was temporary, first-come-first-served, did not guarantee parking, did not permit obstruction of access routes, and did not amount to general parking permission. So, in the witness statement, you should rely on it only as evidence of the character and use of the area, unless the wording clearly proves that the same permission existed on the actual PCN dates.
On the AST point, simply explain that the tenant names were redacted for privacy reasons. For the updated witness statement, exhibit a minimally redacted copy showing your name, the property address, the tenancy dates, the relevant parking/residential clauses and the execution/signature page. Do not redact anything needed to prove that the AST relates to you and to Wheatstone House.
As for case law, yes, you can still refer to it, but the witness statement should not become a legal essay. The WS should mainly be your factual evidence: that you were a resident, what the AST says, where the vehicle was positioned, what the signs were like, what UKCPM’s own boundary map does or does not cover, what the NtKs did or did not specify, and why their evidence does not prove liability. The legal points can be kept short and tied to those facts. The detailed legal argument can be expanded orally at the hearing or in a short skeleton if needed.
Never argue with stupid people. They will drag you down to their level and then beat you with experience. - Mark Twain
