06-24-2026, 01:23 PM
@Barbudaprince, the claimant's latest witness statement arguably creates more problems than it solves. The key issue is not the location markers. The key issue is that the claimant appears to have changed the enforcement boundary itself.
You had already identified the alleged vehicle locations on the claimant's original site map. On that original map, two of the alleged contraventions were outside the claimant's red-line enforcement area. Rather than explain that discrepancy or produce contemporaneous evidence showing the original map was wrong, the claimant has now produced a different, lower-quality satellite image and drawn a thicker, altered boundary which conveniently brings those same locations within the alleged enforcement area.
That raises an obvious question: which map is correct?
If the original map was correct, the claimant had no authority over those locations. If the new map is correct, why was the original map wrong, and where is the contemporaneous evidence proving the true boundary at the material time?
The claimant cannot simply redraw the boundary during litigation to overcome a defence point. What matters is the actual enforcement area authorised by the landowner at the time of the alleged contraventions. The claimant should therefore be put to strict proof by production of the contemporaneous contract and site plan in force at the material time, not a litigation-generated map produced after the issue was identified.
Preserve both versions of the map immediately. Put them side by side. The court needs to see that the claimant’s boundary evidence has changed after the defect was pointed out.
The claimant's witness is a BW Legal paralegal with no first-hand knowledge. She cannot personally verify where the vehicles were located, who identified those locations, who altered the boundary, or why the latest map differs from the earlier one. The witness statement is therefore largely commentary upon documents rather than evidence of fact.
The claimant also continues to ignore the residential nature of the case. You were not a visitor entering a business park and deciding whether to accept a contractual licence from signage. You were a resident whose tenancy already contained parking provisions. The claimant still has not explained how its alleged signage contract interacts with, supplements, or overrides those existing residential rights.
Likewise, the claimant relies on the non-binding County Court appeal decision in VCS v Crutchley, yet fails to engage with Liberty Homes, which is a binding High Court authority. Liberty Homes goes directly to the issue in this case: a claimant must properly plead the contractual basis of its claim. Even after being forced to provide further particulars, the claimant still has not properly explained the contractual terms allegedly breached, how those terms were incorporated into your existing residential arrangements, or how UKCPM acquired authority to impose contractual charges on a resident.
In short, the claimant's latest evidence does not resolve the boundary issue. It arguably demonstrates it. The more they alter their maps, the more they undermine confidence in the accuracy of their own evidence. The court should be invited to prefer the contemporaneous documents and require strict proof of the true enforcement boundary at the material time.
You had already identified the alleged vehicle locations on the claimant's original site map. On that original map, two of the alleged contraventions were outside the claimant's red-line enforcement area. Rather than explain that discrepancy or produce contemporaneous evidence showing the original map was wrong, the claimant has now produced a different, lower-quality satellite image and drawn a thicker, altered boundary which conveniently brings those same locations within the alleged enforcement area.
That raises an obvious question: which map is correct?
If the original map was correct, the claimant had no authority over those locations. If the new map is correct, why was the original map wrong, and where is the contemporaneous evidence proving the true boundary at the material time?
The claimant cannot simply redraw the boundary during litigation to overcome a defence point. What matters is the actual enforcement area authorised by the landowner at the time of the alleged contraventions. The claimant should therefore be put to strict proof by production of the contemporaneous contract and site plan in force at the material time, not a litigation-generated map produced after the issue was identified.
Preserve both versions of the map immediately. Put them side by side. The court needs to see that the claimant’s boundary evidence has changed after the defect was pointed out.
The claimant's witness is a BW Legal paralegal with no first-hand knowledge. She cannot personally verify where the vehicles were located, who identified those locations, who altered the boundary, or why the latest map differs from the earlier one. The witness statement is therefore largely commentary upon documents rather than evidence of fact.
The claimant also continues to ignore the residential nature of the case. You were not a visitor entering a business park and deciding whether to accept a contractual licence from signage. You were a resident whose tenancy already contained parking provisions. The claimant still has not explained how its alleged signage contract interacts with, supplements, or overrides those existing residential rights.
Likewise, the claimant relies on the non-binding County Court appeal decision in VCS v Crutchley, yet fails to engage with Liberty Homes, which is a binding High Court authority. Liberty Homes goes directly to the issue in this case: a claimant must properly plead the contractual basis of its claim. Even after being forced to provide further particulars, the claimant still has not properly explained the contractual terms allegedly breached, how those terms were incorporated into your existing residential arrangements, or how UKCPM acquired authority to impose contractual charges on a resident.
In short, the claimant's latest evidence does not resolve the boundary issue. It arguably demonstrates it. The more they alter their maps, the more they undermine confidence in the accuracy of their own evidence. The court should be invited to prefer the contemporaneous documents and require strict proof of the true enforcement boundary at the material time.
Never argue with stupid people. They will drag you down to their level and then beat you with experience. - Mark Twain
