3 private parking tickets being pursued for all 3 and had a ccj claim made

[b789]

@Barbudaprince, we need to keep each claim separate, even if they are for basically the same reasons, otherwise it becomes very difficult for me to keep track of which case I am advising on. However, yes, the point about the location of the alleged contravention falling outside of the claimants boundary of operation is significant and should be used in the other case.

Back to this case... the order confirms what we expected.

The judge has recorded that there were no detailed Particulars of Claim on the court file, that you told the court you had not received them, and that your existing defence was therefore only pleaded in response to the original bare claim form.

The court has now regularised the position. UKCPM had to re-file and re-serve the detailed Particulars of Claim by 4pm on 6 May 2026. You must now file and serve a fully pleaded defence to those detailed Particulars of Claim by 4pm on 20 May 2026.

If UKCPM wants to reply to your defence, they may do so by 4pm on 3 June 2026.

Both sides may then file and serve updated witness evidence and supporting documents by 4pm on 24 June 2026.

The hearing has been adjourned and will be re-listed as an in-person small claims hearing with a 2.5 hour time estimate, on the first available date after 24 June 2026.

Costs are reserved, which means the judge has not decided who should pay any costs arising from the adjournment. That issue remains live and can be dealt with later.

The order also makes clear that any reference to “filing” means filing at Wandsworth County Court, not Brentford. The final hearing bundle must be agreed at least 7 working days before trial, and UKCPM must file that bundle with the court at least 3 working days before trial.

I have already drafted the defence, but I wanted to see the sealed order first so that we knew exactly what the court had directed. The key point now is that this is not just an optional amended defence. The court has expressly ordered you to file and serve a fully pleaded defence by 4pm on 20 May 2026, so that deadline must be treated as fixed.

You can submit the following as your defence:

IN THE COUNTY COURT AT WANDSWORTH

CLAIM NUMBER: [Claim number]

Between

UK CAR PARK MANAGEMENT LIMITED

Claimant

And

[DEFENDANT NAME]

Defendant

---

DEFENCE TO THE DETAILED PARTICULARS OF CLAIM

1. The Defendant denies the claim in its entirety. No debt is owed to the Claimant, whether as alleged or at all.

2. This Defence is filed pursuant to the order dated 29 April 2026, following the Claimant’s re-service of its detailed Particulars of Claim.

3. The detailed Particulars of Claim remain inadequately pleaded, contrary to CPR 16.4 and PD 16. Where a claim is based upon an agreement, PD 16 requires proper particulars of that agreement. In Liberty Homes (Kent) Ltd v Rajakanthan & Ors [2022] EWHC 2201 (TCC), Mrs Justice Jefford DBE held that it is implicit that the Particulars of Claim must set out whether the agreement relied upon is oral, written, by conduct, or some combination. The Claimant has failed to plead its alleged contractual basis with sufficient clarity.

4. The Claimant pleads three different alleged contraventions, namely “Permit Required”, “No Parking On Access Roads / Roadways”, and “Not Displaying A Valid Permit”. Those are materially different allegations. The Claimant has not properly particularised each alleged breach separately, the precise contractual term relied upon for each PCN, or how each alleged term was incorporated and breached.

5. The Defendant is the registered keeper. The driver has not been identified. The Claimant is put to strict proof of the driver’s identity and, alternatively, of full compliance with Schedule 4 of the Protection of Freedoms Act 2012 if it seeks keeper liability.

6. The Notices to Keeper fail to specify any proper period of parking. They do not identify a start time, end time, duration, or actual observation period. The Claimant is put to strict proof of any alleged period of parking and any basis for keeper liability.

7. The Claimant is put to strict proof that any driver was given the required consideration period before any parking contract could be formed. The Defendant denies that the Claimant has evidenced any continuous observation period or any fair opportunity for a driver to read the signs, consider the terms and leave.

8. The alleged location is inadequately and/or inaccurately identified. The Claimant is put to strict proof of the exact relevant land, the precise vehicle locations, the signs allegedly applicable at those locations, and the basis on which the pleaded location corresponds with the land on which the vehicle was allegedly parked.

9. The Defendant was a tenant/resident at the property at the material time. Parking was already governed by the residential/tenancy arrangements. The Claimant’s signage did not override those pre-existing rights or create liability to the Claimant unless the Claimant proves a separate enforceable contract, properly incorporated terms, and authority to impose charges on residents or their vehicles.

10. The Defendant understands that the Claimant’s own boundary/authority map does not cover the hard-standing area where the vehicle was located for at least two of the alleged PCNs. The Claimant is put to strict proof that it had contractual authority at the precise location of each alleged contravention.

11. The Claimant is put to strict proof that the signage was visible, prominent, applicable to the precise vehicle locations, and capable of forming a contract. Any prohibitory wording, including “No Parking On Access Roads / Roadways”, is denied to create any contractual licence or liability for a parking charge.

12. The Claimant is put to strict proof of landowner authority to operate at this residential site, impose parking charges, access keeper data, and bring proceedings in its own name.

13. The added sums are denied as unrecoverable, unsupported and inadequately pleaded. If the Claimant relies on keeper liability, recovery from the keeper is in any event limited to the amount specified on the relevant Notice to Keeper.

14. The Claimant has already had the opportunity, pursuant to the order dated 29 April 2026, to re-file and re-serve detailed Particulars of Claim. If the detailed Particulars still fail to plead a proper cause of action, the Defendant submits that the Claimant should not be granted a further opportunity to repair its defective case. Having regard to the overriding objective under CPR 1.1, the modest sums claimed, the routine bulk nature of these proceedings, and the need to deal with cases justly and at proportionate cost, the Defendant invites the court to strike out the claim of its own initiative pursuant to CPR 3.4 and CPR 3.3.

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.

Signed:


Date:

It must be emailed to the court AND BW Legal as a PDF attachment in the same email. Also, CC yourself. Please confirm when that has been done.

[Barbudaprince]

All done thank you for your help

---

So just received this automated response. Surely this is not fair.


This email address is inactive and not monitored.

Your message has not been received, read, or reviewed, and no information has been provided to BW Legal. This email is being returned to you as undeliverable.

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[Barbudaprince]

Hello I have received this reply to the defence via email.

 Should we respond? Many thanks

https://drive.google.com/file/d/1DDDI9Kb...p=drivesdk

[b789]

This is useful, but it does not require any immediate reply unless the court specifically directs one. It is their permitted “Reply to Defence”. The next substantive step remains the updated witness evidence/documents deadline of 24 June 2026.

The reply is weak in several places.

First, they try to say the Defence has not addressed their pleaded facts and that matters are therefore admitted under CPR 16.5(5). That is overreach. The Defence clearly denies liability, challenges the contractual basis, signage, location, PoFA compliance, period of parking, authority, residential rights and added sums. They cannot manufacture admissions simply because the Defence does not plead a full witness statement-style rebuttal.

Second, their answer to the defective pleading point is poor. At paragraph 10 they effectively say they do not need to identify the specific contractual terms because this is a “known template argument”. That is not an answer to CPR 16.4, PD 16 or Liberty Homes. If the claim is based on a contract by conduct through signage, they still need to identify the material terms relied upon and explain how each of the three different alleged contraventions gives rise to liability.

Third, their keeper/driver point is muddled. At paragraph 11 they say the Defendant does not deny being the driver. That is not the same thing as proving the Defendant was the driver. The Defendant is entitled to put them to proof. They then say they can pursue the Defendant as registered keeper anyway, but that depends on full PoFA compliance, which remains disputed.

Fourth, their PoFA “period of parking” argument is poor. The Claimant’s reply confirms that the NtKs used the wording that the period of parking was “the period immediately preceding the incident time”. That is precisely the defective wording being challenged. It remains circular and undefined. Their assertion that “period of parking” is not defined in PoFA does not remove the statutory requirement for the NtK itself to specify the relevant period of parking. Separate evidential photographs, if not included with the NtK, do not cure that statutory defect. Later photographs may show that a vehicle was present at particular moments, but they cannot retrospectively repair a NtK which failed to specify the period of parking required by Schedule 4.

Fifth, their consideration period answer is weak. Saying that later photographs show nobody in the vehicle does not prove when the vehicle arrived, whether it was continuously observed, whether the driver was given the required opportunity to read the signs, or whether any contract had already been formed before enforcement. In any event, later evidence cannot be used to rewrite the NtK. The issue is not merely whether UKCPM can produce photographs showing presence; it is whether the notice and evidence prove a proper period of parking, a proper consideration period, and a properly formed contract before the PCN was issued.

Sixth, the residential point remains live. They rely on the AST wording, but that cuts both ways because it confirms that parking was already regulated by the tenancy/residential framework. UKCPM still has to prove that its signage created a separate enforceable contract, that the terms were incorporated, and that it had authority to charge a tenant/resident at the precise locations alleged.

Seventh, they have not properly answered the boundary-map point. If their contractual authority map does not cover the hard-standing area where the vehicle was located for at least two PCNs, then their authority at the precise location remains a major issue.

Eighth, the added-sum response is thin. Saying the signage mentions debt recovery costs does not answer the PoFA keeper-cap point, the mismatch in the figures, or whether the added sum is genuinely recoverable rather than a dressed-up double recovery.

The practical position is simple: this Reply does not cure the defects in their case. It gives useful material for your updated witness statement, particularly on their muddled driver/keeper position, their weak period-of-parking answer, their failure to engage properly with the boundary issue, and their reliance on the tenancy agreement while pretending residential rights are irrelevant.

@Barbudaprince, BW Legal have made a point in their Reply to Defence that the AST copy previously provided had the tenant names redacted, so they say they cannot ascertain who it relates to. Can you confirm whether the AST you sent with your original witness statement had your name redacted? If it did, why was it redacted? Was it simply for privacy/data protection reasons, or was it an accidental over-redaction?

This needs to be dealt with in the updated witness statement. If you are relying on the AST to prove that you were a tenant/resident at Wheatstone House, the court and the Claimant need to be able to see that the tenancy relates to you and to the relevant property. Otherwise BW Legal will try to say the AST proves nothing.

The best approach is not to send anything separately now unless the court directes a reply. Instead, include with the updated witness statement an unredacted or minimally redacted copy of the AST. Your own name, the property address, the tenancy date, the relevant parking/residential clauses and the signature/execution pages should be visible. Irrelevant personal or financial information can still be redacted if necessary, but not anything needed to prove that the AST is yours and applies to Wheatstone House.

In the updated WS, this can be dealt with simply:

The Claimant has suggested that the AST previously exhibited could not be linked to me because the tenant names were redacted. The redactions were applied for privacy reasons and not because the tenancy was unrelated. To avoid any possible ambiguity, I now exhibit a copy of the AST with my name, the property address, the relevant terms and the execution page visible.

That neutralises the point. It also avoids unnecessary correspondence with BW Legal, who are not going to deal with this fairly or helpfully.

The witness statement now needs to be prepared as the main evidential document, not another argument-only defence.

The deadline is 4pm on 24 June 2026. It must be filed at Wandsworth County Court and served on BW Legal/UKCPM by that deadline. The sensible approach is to have the WS, exhibits and index finished by 23 June, with only final checking on 24 June.

The WS should focus on these points:

1. The defendant’s residential status and the tenancy/AST parking provisions.
   
2. The fact that parking was already governed by the residential arrangements, not simply by UKCPM’s later signage.
   
3. The exact locations of the vehicle for each PCN, especially the hard-standing area.
   
4. The claimant’s own boundary/authority map not covering the hard-standing location for at least two PCNs.
   
5. The defective NtKs, especially the failure to specify the statutory period of parking.
   
6. The fact that later evidential photos cannot cure a defective NtK. PoFA requires the notice itself to specify the period of parking. Separate photos served later may show a vehicle at certain moments, but they do not retrospectively repair the notice.
   
7. The lack of evidence of any consideration period before enforcement.
   
8. The inadequacy, visibility and applicability of signage at the precise vehicle locations.
   
9. The claimant’s muddled driver/keeper position.
   
10. The added sums and the attempt to recover more than the NtK amount from a keeper.
    

For the WS, you will need the key exhibits in this order:

• The three NtKs/PCNs.
  
• The detailed Particulars of Claim.
  
• The Defence as filed.
  
• BW Legal’s Reply to Defence.
  
• The tenancy agreement or at least the relevant parking clauses.
  
• The claimant’s boundary/authority map.
  
• Photos showing where the vehicle was parked for each PCN.
  
• Any claimant evidence photos.
  
• Any signage photos.
  
• The order dated 29 April 2026.
  

The WS should be drafted as a clear first-person factual statement, with argument kept controlled and tied to the exhibits. The legal submissions can be short and embedded where necessary, but the priority is to make the judge understand: "I was a resident; UKCPM’s authority and signage do not cover what they claim; the notices are defective; and they have not proved liability."

@Barbudaprince, I suggest you now start putting together your updated witness statement based on the points above.

Remember, the witness statement is your narrative to the court. It is not another defence and it is not meant to be legal argument only. It should explain, in your own words, what happened, your connection to the property, what the tenancy says about parking, where the vehicle was positioned, what the claimant’s evidence does or does not show, and why you say UKCPM has not proved its case.

Do not worry too much at this stage about the formal heading, exhibit numbering or Statement of Truth. The important thing for now is that you produce a clear draft showing that you understand the issues and what evidence you are relying on.

In particular, make sure you deal with the AST point. If the copy previously provided had your name redacted, explain why. If you are relying on the AST to prove your residential status, the updated witness statement should exhibit a copy where your name, the property address, the relevant parking clause, the dates and execution/signature page are visible. Irrelevant personal information can still be redacted if necessary.

Also make sure you include the point that later evidential photographs cannot cure a defective Notice to Keeper. PoFA requires the NtK itself to specify the period of parking. Later photographs may show the vehicle at particular moments, but they cannot retrospectively fix a notice that failed to specify the statutory period of parking.

The deadline for updated witness evidence and documents is 4pm on 24 June 2026. Please do not leave this until the last minute. Put together your draft and show me what you have as soon as possible, ideally allowing at least a couple of days before the deadline so I can make any necessary corrections or adjustments. I can draft a polished version for you if yours needs restructuring, but I need your factual narrative and exhibits first.

[Barbudaprince]

Thanks,

For privacy reasons I redacted that information. 

I'm going to draft the updated witness statement. I have a lot of the existing prose from the original witness statement which I will just reformat. So am I no longer going to be referring to those case laws?

Quite interestingly and timely I have received this attached communication from the freeholder. The overflow car parking arrangements they speak off are basically where these contraventions had occurred. Does this lend anything to my case in that suddenly residents are being encouraged to park in the areas where UK CPM are being asked to enforce?

https://drive.google.com/drive/folders/1...DAc1Y4yXeP

[b789]

@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.

[Barbudaprince]

Hi, I've made a first draft  - please see here:

https://docs.google.com/document/d/1uKEc...ue&sd=true

[b789]

@Barbudaprince, for a first draft, it is very good but I would not submit it as-is. The structure is broadly right, but it needs tightening and a few corrections before it is safe. The draft currently includes a skeleton argument before the witness statement, then the WS itself begins on page 3 with exhibits PF-01 to PF-09.

The main edits are:

Remove the skeleton argument from the front unless you deliberately intend to file a skeleton now. The order is for updated witness evidence and documents. A skeleton can be prepared later, nearer the hearing, and should not be muddled into the WS bundle.

Correct the exhibit references. Paragraph 27 says signage photos are at PF-07, but the exhibit list says PF-07 is vehicle-location photos and PF-08 is signage photos. Paragraph 44 also needs checking because it refers to a Beavis sign comparison at PF-08, but PF-08 appears to be signage photos, not necessarily a Beavis sign comparison.

Correct paragraph 12. It says the Claimant’s witness statement is dated “4/09/2026”. That is impossible and should be “4 March 2026” if that is the date of the Claimant’s WS.

Change “the Defendant” to “I” where the statement is meant to be personal evidence. The obvious ones are the unnumbered “UNCLEAR KEEPER DRIVER ARGUMENT” section, paragraph 25, and the conclusion at paragraphs 71–73.

Paragraph 25 needs correction. It currently says “formed.enforcement was taken” and then switches to “The Defendant denies”. That should be rewritten.

The “Claimant’s witness evidence” section repeats itself. Paragraphs 54–59 and 63–65 cover the same ground. Keep it once.

Move the sentence after the Statement of Truth. “I respectfully request that the Court dismiss this claim…” must go immediately before the Statement of Truth, not after it.

The conclusion is repetitive. It repeats tenancy, authority, PoFA and driver identity points already made earlier. Keep it short and clean.

Use this as the correction wording for the affected sections:

Replace paragraph 14 with:

14. I have compared the Claimant’s boundary/authority map with the locations where the vehicle is shown in the photographic evidence. In my understanding, at least two of the alleged contraventions occurred outside the area marked on the Claimant’s own enforcement boundary/authority map.

Replace paragraphs 24–26 with:

24. The later evidential photographs relied upon by the Claimant cannot cure a defective Notice to Keeper. PoFA requires the Notice to Keeper itself to specify the relevant period of parking. Separate photographs served later may show the vehicle at particular moments, but they do not retrospectively repair a notice which failed to specify the period of parking required by Schedule 4.

25. I have not seen any evidence proving that a proper consideration period was given before enforcement action was taken. I do not accept that the Claimant has evidenced any continuous observation period or any fair opportunity for a driver to read the signs, consider the terms and leave.

26. The driver has not been identified and I have seen no evidence identifying the driver. In those circumstances, and in the absence of full PoFA compliance, I do not understand how the Claimant can pursue me as registered keeper.

Replace the unnumbered “UNCLEAR KEEPER DRIVER ARGUMENT” section with:

46. In paragraph 11 of the Claimant’s Reply to Defence, the Claimant states that I do not deny being the driver. That is not the same thing as proving that I was the driver. The Claimant must prove its case. If it seeks to pursue me as keeper, it must prove full compliance with Schedule 4 of the Protection of Freedoms Act 2012, which I dispute.

Replace paragraphs 54–65 with:

54. The Claimant’s witness statement was produced by Ms Nabeela Ahmed, who describes herself as a paralegal employed by BW Legal Services Limited.

55. Ms Ahmed is not an employee of the Claimant and does not state that she attended the site, witnessed any alleged parking event, erected or maintained any signage, issued any PCN, or has any first-hand knowledge of the matters alleged.

56. The Claimant’s evidence includes photographs which appear to have been taken by a parking attendant at the site. That parking attendant would be the person able to give first-hand evidence about the circumstances in which the photographs were taken, the vehicle’s location, the visibility of signs, and the conditions at the time.

57. No witness statement has been provided from that parking attendant. Instead, the Claimant relies upon second-hand evidence from its legal representative. I ask the Court to attach appropriate weight to that evidence.

Replace paragraphs 70–74 with:

70. For the reasons set out above, I do not accept that the Claimant has established any lawful basis upon which I may be held liable for the parking charges.

71. The tenancy agreement establishes a contractual relationship between me and L&Q. It does not create any contractual relationship between me and the Claimant, nor does it state that I agreed to pay parking charges to the Claimant.

72. The Claimant has not proved that it had authority at the precise locations of the alleged contraventions. In particular, at least two of the alleged contraventions appear to fall outside the area shown on the Claimant’s own enforcement boundary/authority map.

73. The Notices to Keeper do not specify any proper period of parking as required by paragraph 9(2)(a) of Schedule 4 of the Protection of Freedoms Act 2012. Later photographs cannot retrospectively cure that defect. The driver has not been identified and the Claimant has produced no evidence establishing driver identity.

74. I respectfully request that the Court dismisses the claim and considers any costs incurred in defending this matter accordingly.

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:

Dated:

Also change “Notice to Keeper” to “Notices to Keeper” where the point applies to all three PCNs. At the moment the PoFA section slips between singular and plural.

Finally, the L&Q temporary parking letter should be added as a further exhibit if you want to rely on it. It should be used carefully as later evidence showing that L&Q recognises external overflow parking areas, not as proof that the same temporary arrangements applied on the PCN dates.

I would not send a skeleton argument with the witness statement as the court has not specifically ordered one. The 24 June deadline is for updated witness evidence and supporting documents, so the witness statement and exhibits should be the priority.

A skeleton argument is best prepared after the WS bundle is finalised and once the re-listed hearing date is known. It should then be served shortly before the hearing, ideally with the agreed trial bundle or at least a few working days before the hearing, so the judge and the other side have it in time to use it.

Because the order says the parties must agree the bundle at least 7 working days before trial, and UKCPM must file the bundle at least 3 working days before trial, the skeleton can sensibly be sent around the bundle stage. That keeps it current and avoids filing a skeleton now that may later need amending.

The skeleton should be short and used as a roadmap for the judge, not as another witness statement. It should identify the main issues only: defective/unclear pleaded contract, residential tenancy position, UKCPM’s lack of authority at the precise vehicle locations, the boundary map issue, lack of a specified period of parking on the NtKs, no keeper liability, no proof of driver identity, poor signage/prohibitory wording, and the unrecoverable added sums.

For each point, refer briefly to the relevant paragraph of your witness statement and the relevant exhibit number. Do not repeat long factual detail already in the WS.

Any authorities relied on should be included in the bundle/authorities pack. Binding authorities such as ParkingEye v Beavis and Liberty Homes can be cited in the usual way. For county court appeal decisions or other persuasive authorities, such as Brennan v Premier Parking Solutions and VCS v Edward, include the transcript.

The skeleton should probably be no more than 4–6 pages. Its purpose is to help the judge find the issues quickly, not to bury the court in argument.

[Barbudaprince]

Thank you. Have made those changes and added the Exhibits. Should I readd Liberty Homes (Kent) Limited v Rajakanthan & Others [2022] EWHC 2201 (TCC)? 

Link here: https://docs.google.com/document/d/1uKEc...ue&sd=true

[b789]

@Barbudaprince, you do not need to read the entire Liberty Homes transcript. It is a lengthy High Court judgment and only a very small part of it is relevant to your case.

The reason it is referenced is because it deals with what a claimant must include in its Particulars of Claim. In simple terms, if someone brings a contractual claim, they must properly explain the contractual basis of that claim so the defendant knows what case they have to answer.

For your purposes, the relevant paragraphs are 35-37 and paragraph 144.

Paragraphs 35-37 explain that a claimant must plead the material facts necessary to establish its contractual case. A defendant should not be left guessing which contractual terms are relied upon or what is alleged to have been breached.

Paragraph 144 is particularly useful because it confirms that defects in pleadings cannot simply be fixed later through witness statements or evidence. The claimant is expected to properly plead its case from the outset.

The relevance to your case is that UKCPM's original PoC were extremely sparse and failed to explain the contractual basis of the claim with any real clarity. The fact that the court has now required detailed Particulars rather demonstrates the point.

So don't get bogged down reading dozens of pages. Just understand the principle: a claimant must properly explain its case in its Particulars of Claim, and that is why Liberty Homes is being relied upon. The only parts you really need to be familiar with are paragraphs 35-37 and 144.