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    • I've inserted their poc re:your.. 1 ..they did send 2 paploc's  3. neither the agreement nor default is mentioned in their 2.        
    • Hi Guys, i read a fair few threads and saw a lot of similar templates being used. i liked this one below and although i could elaborate on certain things (they ignored my CCA and sent 2 PAPs etc etc) , am i right in that at this stage keep it short? If thats the case i cant see what i need to add/change about this one   1)   the defendant entered into a consumer credit act 1974 regulated agreements vanquis under account reference xxxxxxx 2)   The defendant failed to maintain the required payment, arrears began to accrue 3)   The agreement was later assigned to the claimant on 29 September 2017 and notice given to the defendant 4)   Despite repeated requests for payment, the sum of 2247.91 remains due outstanding And the claimant claims a)The said sum of £2247.91 b)The interest pursuant to S 69 county courts act 1984 at the rate of 8% per annum from the date of issue, accruing at a daily rate of £xxxx, but limited to one year,  being £xxxx c)Costs   Defence:   The Defendant contends that the particulars of claim vague and are generic in nature. The Defendant accordingly sets out its case below and relies on CPR r 16.5 (3) in relation to any particular allegation to which a specific response has not been made.   1. The Claimant has not complied with paragraph 3 of the PAPDC ( Pre Action Protocol) Failed to serve a letter of claim pre claim pursuant to PAPDC changes of the 1st October 2017.It is respectfully requested that the court take this into consideration pursuant to 7.1 PAPDC.   2. The Claimant claims £2247.91 is owed under a regulated consumer credit account under reference xxxxxxx. I do not recall the precise details or agreement and have sought verification from the claimant and the claimants solicitor by way of a CPR 31.14 and section 78 request who are yet to fully comply.   3. Paragraph 2 is denied. I am unable to recall the precise details of the alleged agreement or any default notice served in breach of any defaulted payments. 4. Paragraph 3 is denied.The Defendant contends that no notice of assignment pursuant to s.136 of the Law of Property Act & s.82 A of the CCA1974 has ever been served by the Claimant as alleged or at all.   5. It is therefore denied with regards to the Defendant owing any monies to the Claimant, the Claimant has failed to provide any evidence of assignment/balance/breach requested by CPR 31. 14, therefore the Claimant is put to strict proof to:   (a) show how the Defendant has entered into an agreement; and (b) show and evidence any cause of action and service of a Default Notice or termination notice; and © show how the Defendant has reached the amount claimed for; and (d) show how the Claimant has the legal right, either under statute or equity to issue a claim;   6. After receiving this claim I requested by way of a CPR 31.14 request and a section 78 request for copies of any documents referred to within the Claimants' particulars to establish what the claim is for. To date they have failed to comply to my CPR 31.14 request and also my section 78 request and remain in default with regards to this request.   7. As per Civil Procedure Rule 16.5(4), it is expected that the Claimant prove the allegation that the money is owed.   8. On the alternative, as the Claimant is an assignee of a debt, it is denied that the Claimant has the right to lay a claim due to contraventions of Section 136 of the Law of Property Act and Section 82A of the consumer credit Act 1974.   9. By reasons of the facts and matters set out above, it is denied that the Claimant is entitled to the relief claimed or any relief.  
    • i understand. Just be aware I am prepared to take some risks 😉
    • Thanks Tnook,   Bear with us while we discuss this behind the scenes - we want you to win just as much as you do but we want to find the right balance between maximising your claim without risking too much in court fees, and in possible court costs awarded to the defendant bank.
    • Tell your son and think on this. He can pay the £160  and have no further worries from them. If he read POFA  Scedule 4 he would find out that if he went to Court and lost which is unlikely on two counts at least [1] they don't do Court and 2] they know they would lose in Court] the most he would be liable to pay them is £100 or whatever the amount on the sign says. He is not liable for the admin charges as that only applies to the driver-perhaps.If he kept his nerve, he would find out that he does not owe them a penny and that applies to the driver as well. But we do need to see the signage at the entrance to the car park and around the car park as well as any T&Cs on the payment meter if there is one. He alone has to work out whether it is worth taking a few photographs to help avoid paying a single penny to these crooks as well as receiving letters threatening him with Court , bailiffs  etc trying to scare him into paying money he does not owe. They know they cannot take him to Court. They know he does not owe them a penny. But they are hoping he does not know so he pays them. If he does decide to pay, tell him to wait as eventually as a last throw of the dice they play Mister Nice Guy and offer a reduction. Great. Whatever he pays them it will be far more than he owes as their original PCN is worthless. Read other threads where our members have been ticketed for not having a permit. [We know so little about the situation that we do not know if he has a permit and forgot to display it. ]
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Easier if I just copy and paste the following which is a warning for people

thinking of spending money at Currys or associated stores


I will never shop in a Currys or other associated stores again. Beware if you are thinking of spending

money in Currys, Dixon’s or PC World.


After purchasing a Vacuum Cleaner 9 weeks ago which was overheating and cutting

out I thought it would be straight forward to return to Curry’s St Helens for an exchange or refund.

(The Vacuum cleaner had only been used on 5 or 6 occasions as we have wood flooring throughout most of the house).




Anyway, it seems that Curry’s stores don’t bother with the Sales of Goods Act 1979 and have their own laws.


Never had any problems at any other stores with returning goods and this was actually reported and covered by Which magazine in 2001 stating that staff from stores of Currys and Dixons were wrongly stating that responsibility lay with the Manufacturer. Five years later and they are still at it, passing the buck.


It is Currys responsibility as the seller to resolve the issue and yet Currys refused to take the vacuum cleaner from me. I certainly don’t want to have to take a days holiday to wait for them to send out an engineer which

from reading many other reports on other sites tend to not turn up anyway.


From start to finish there was no indication that Currys wanted to help the customer and they simply wanted to pass the responsibility on elsewhere.


Needless to say that after stating the Sales of Goods Act 1979 in the store I was asked to leave the premises by one of their vertically challenged Security Guards stating that I was trespassing on their property!!!


I think that they are in need of some well overdue Consumer Law and Customer Service training, fast!!

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Personally I would have no further dealings with a store that refused to deal with a complaint to my satisfaction and in one visit; for one thing, there's no hard evidence of what's been said on either side. Tempers can easily get frayed too!


I would put my claims in writing to the head office, setting out the un-embellished facts and relaying an accurate summary of the action taken so far to resolve the matter locally, set out my aims to resolve the matter and mention the Sale of Goods Act as being the basis of the complaint/settlement required. I would then address the letter by name to a director.


You can get director's names from the co. website usually.


With some suitable modification, the 'Pre-Lim' and LBA' letters here form a good basis for a suitable letter.


Every business (Currys or anyone else's) must, by law, have a notice displayed at every place in which they do business concerning the ownership of that business and must also give the address for the 'service of documents'.

Jimbo 44 - always happy to help, but always willing to learn from being corrected too!!! Whilst any advice given may be based upon personal experience, please always be sure you seek guidance from a professional in the particular field.


Never be afraid to try something new. Remember that a lone amateur built the Ark, but a large group of professionals built the Titanic.


A 'click' on the scales is always appreciated if I have helped. Many Thanks!

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I had a same experience with Currys at Hounslow, London. The Staff (specially ladies) are useless as they have no clue on techology and products.

Note: The srest of the staff (I believe they are native Britisher) are quite ok.

. I bought headone which had specification of "Noise isolation". When I open it and tried it did not work the way it is supposed to work. I packed the headphone without any damage even to package.When I took went to return the headphone ,they denied saying it is opend and we can not take it due to heygine issues.

The manager (Black guy) was even worst. he said these items are like Nicker (Underwares) once you wear it u can not return it.

what the ....

I will highly recommend not to buy anything from such cheap mentality shops CURRYS LOT OF WORRIES. I think it is problem with UK return policies which they might have learned from Indian Shoppers. US,Netherlands are the best counrties to do real Electronics Shopping

I wish you Currues This Chrismas sale make yoru profit down by 99%

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