Bank Park ANPR PCN Claimform - Blue Car Park 2 Merry Hill Brierley DY5 1QX - *** Claim Dismissed ***

[Andy711351]

Thankyou Dx100

 

Phew what a relief I dont have to do the CPR stuff. thankyou

 

I am employed but as a trust bank. meaning i work in the hospital, but only go when they need me and fill in a timesheet. Once timesheet is filled, I get paid PAYE as an employee

 

 

Re Skype

 

 

I refer to post by Ericbrother  post #133 dated August 6/20202 on link 

 

https://  www.consumeractiongroup.co.uk/topic/410445-ukcpmgladstones-windscreen-pcn-claimform-vista-centre-salisbury-rd-hounslow-tw4-6jq-claim-dismissed/page/6/#comments

 

 

Post #133 ericsbrother august 6,2020

Ok new position is that many cases are heard with one side actually attending and the other by video link or skype. you want to be the one turning up so if you dotn ahve skype or the like let the court know soon so they pencil you in for a real chair.

 

So according to EB, is that still correct or have things change. of course I will call Gloucetser court to ask but wondered if you knew more

 

 

Finally, as raised in my post #73, can I use Appenidx instead of Exhibit , to avoid confusion?

 

Thankyou

 

 

 

[FTMDave]

17 minutes ago, Andy711351 said:

Finally, as raised in my post #73, can I use Appenidx instead of Exhibit , to avoid confusion?

 

Sorry, missed that question.  Yes, use whatever term you want, it just has to be clear to the judge.

[Andy711351]

Thankyou Dave

[Andy711351]

Just called Gloucester court

 

Spoke to one of the admin

 

she said you can email us, explaining why you prefer to attend in person and the Judge will consider that

 

the hearing is on the 8th of April

 

My reason would be that my internet is not that reliable, and its true, I am relying on hotspot provided by my phone rather than a dedicated separate broadband

 

also, Im better at presenting my case in person face to face

 

 

 

 

[lookinforinfo]

I am sorry to have come to your thread rather late. But a couple of observations. The Defence statement that you sent them way back was in fact in everything but name a WS. And a pretty comprehensive one. But of course not having seen their WS first some things have changed. 

 

One of the things that was picked out on the first submission and rejected by DCBL was their signage being to small. But this is confirmed by them in their bundle by sneakily increasing the font size in their photos so that it appears much larger than on their signs. If the signs were the correct size why would they enhance them?  Signage is a very important part of the contract and if the signage is not clear then the contract fails.

 

Also on none of their signs, apart from the one by the payment meter does it stipulate that not paying or not paying sufficient leads to a charge at all. As you appear to have moved from car park to car park with different rules then you can stipulate which ones you want to apply to you. I have ust realised that as you parked in several

different places within the car park then Schedule 4 section 9 [3] applies

(3)The notice must relate only to a single period of parking specified under sub-paragraph (2)(a) (but this does not prevent the giving of separate notices which each specify different parts of a single period of parking).

what they should have done is broken your parking times into the sections wherin you stayed. As they have not done so they cannot state with any accuracy where your parking complied with their rules and where it didn't. They can't even say if you were parked all the time within their stipualted rules.

 

In other words if their ANPR cannot pick out movement of cars within all their car parks, then the ANPR is not fit for its purpose.

 

[Andy711351]

Thankyou Lookiforino

 

Its ok lol I dont expect everyone to focus on my case but thanks so much for the feedback

 

The initial defence was prepared by Private parking appeals for a fee of £20, but after that there was no trace of them.

 

The initial Defence I think maybe was a bit generic , rather than specific.

 

I have now summitted the final draft as today was the due date

 

 

The attached draft has been submitted . i have redacted it.

 

 

To avoid wasting anyone's time, as it is submitted I cant make any changes to it now.

 

final paginated WS redacted and submitted to court.docx

 

Thankyou to ALL of those who contributed. I am truly indebted to all of you, whether I win lor lose. Main thing is you all tried your best

 

 

BIG THANKYOU

 

Stay SAfe

 

xxxx

 

[Andy711351]

Question Please

 

1. The Caimants solicitors emailed me their Bundle on Friday 15/1/2021 at 2 pm. The deadline for my filing to court and serving them is today. Thats naughty

 

Lets say the deadline was in the middle of the week, like the 20th of January 2021. Does that mean the Claimants could potentially leave it till the 19th Jan 2021 4.59 pm to email me, as it wont give me any time to reply. 

 

Whats the courts veiws on theses?

 

2. i still dont understand why there was ever 2 deadlines from  court, the 18th Jan 2021 ( today) and 1st Feb 2021. Anyone knows why?

 

Thanks again for all your advice. 

 

lets now wait and see. 

 

Hearing 8/4/2021

[dx100uk]

its not usual with but covid changes..

typically what the court has done since covid is say hey you two, get together, exchange WS's by xx date, see if you can narrow issues is the real reason, the court hopes one or the other gives in. less hassle 

 

if you don't they usually have stated a date a few weeks later whereby the claimants solicitors forwards both WS's to the court.

in your case the court appears to have requested to poke their nose in earlier than usual which is of no use to them, as the judge wont see them till the hearing anyway...so

 

although not regarding PNC cases, bar one i think, what we see here is the claimants solicitor ignore the earlier date and simply file theres by the last due date without earlier involving the defendant at all. what i will guess because BCD(L) is rather new to the game, they've not yet found out they can all but ignore the earlier date.

 

this has ofcourse give you a huge advantage.

[Andy711351]

' what i will guess because BCD(L) is rather new to the game, they've not yet found out they can all but ignore the earlier date.

 

this has ofcourse give you a huge advantage.'

 

 

Thankyou.

 

Lol, lets hope thats the case. Unless they are much smarter than all of us and called a bluff.

 

In their email they say please find attached our bundle, a cop which has been filed at the court.

 

The bluff could be that they haven't filed it at the court by the earlier date, but they hope hope that I submit mine by the first deadline, which I have now done. Gives them a chance to look at my WS, make any changes to theirs and then actually use the later date to file their papers at the court, having had the benefit of looking at my WS

 

 

Who knows, these solicitors maybe me smarter poker players than we thinkk lol

[Andy711351]

Hello All

 

Update

 

As per post #83, I had mentioned that for some unusual  reason, there had been two deadlines from the court for responding, namely the 18th of January 2021 and 1st of Feb 2021.

 

With everyones great help I filed in the response by the18th of Jan 2021. I think I was bit concerned that the claimant, Mike Ashley may use the second deadline as a chance to add a supplementary statement in response to my defence. 

 

Well, Mike Ashely has in fact does exactly this. He has responded and filed a supplementary witness statement and has responded to all the defence points. He has addressed most the issues I had raised in my defence.

 

 

His Supplementary WS is dated 30 January 2021 and his solicitors emailed it to me on the 17th of February 2021.

 

Not sure what to do, but he seems to have amended everything which i could have used as a loophole leaving me with the thought of , should we have waited till the 2nd deadline ie 1ist Feb2021 and submitted the defence rather than the 18th January 2021. this would have deprived him of the chance to response with a supplementary WS. Thats what really had a worried me and I raised it a few times on this platform.

 

 

Not sure now because he has kind of amended a few things, removed the incorrect exhibit ( where the signages had belonged to a different site, and called it a clerical error).

 

Will post his redacted supplementary WS later as at work now.

 

Thanks all

[AndyOrch]

If a witness wishes to deal with matters not dealt with in the original witness statement a supplementary witness statement should be prepared and served on the other parties, as soon as possible. Permission is required to adduce a supplementary witness statement at trial if any other party objects to it. This need not be sought before service; it can be sought at a case management conference if convenient or, if need be, at trial.

 

Andy

[Andy711351]

'The bluff could be that they haven't filed it at the court by the earlier date, but they hope hope that I submit mine by the first deadline, which I have now done. Gives them a chance to look at my WS, make any changes to theirs and then actually use the later date to file their papers at the court, having had the benefit of looking at my WS

 

 

Who knows, these solicitors maybe me smarter poker players than we thinkk lol'

 

 

It seems that the claimant solicitors actually outsmarted me. They submitted the first Bundle before on the 1st deadline of 18 of January. I submitted the defence before that date as per court orders.

 

They then sneaked in the supplementary WS before the second deadline of 1st feb 2021, having benefited from covering any loopholes that I had of them in my defence WS.

 

So in the supplementary WS, they have produced the contract, they have said that any extra irrelevant signages in their initial set of exhibits were clerical errors and have produced a much tidier crisper WS . I wish I had not now submitted my defence by the 18th of jan 2021, but rather waited till the 1st of Feb 2021. 

[dx100uk]

2 hours ago, Andyorch said:

If a witness wishes to deal with matters not dealt with in the original witness statement a supplementary witness statement should be prepared and served on the other parties, as soon as possible. Permission is required to adduce a supplementary witness statement at trial if any other party objects to it. This need not be sought before service; it can be sought at a case management conference if convenient or, if need be, at trial.

 

Andy

 

so object then..

[Andy711351]

Thankyou

 

I called the court today

 

I asked two specific questions

 

1. Why was there 2 deadlines, one of the 18 Jan 2021 and a further one 1 Feb 2021

2. When did the claimant submit their supplementary WS ( they have signed it as 30 Jan

 

 

The clerk replied

 

1. The first deadline of 18/1/2020 was for filing the DOCUMENTS upon which either party had wished to rely on, not the WS. the second deadline of 1/2/2021, was for the WS to be submitted by. 

 

2. The claimant filed submitted their supplementary WS to the court on 17/2/2021. In other words, they did not respect the deadline. I asked if that could invalidate. She said that you can put that in writing and it would be at the discretion of the judge. 

 

 

So any thoughts on the fact that the supplementary clamant WS was dated 30/1/2021 but in fact emailed to both  the court and myself on the 17/2/2021, 17 days after the due deadline?

 

Thankyou

 

 

 

[FTMDave]

Firstly, even if they get away with this, it doesn't mean you won't win.  The solicitor can eloquently waffle on as long as they like that the signage isn't carp.  I'm afraid the signage is carp and the photos show it is.

 

Virtually everyone who has beaten these companies in court was facing a solicitor, but still won.

 

So do what dx, Andy and the court woman said.  Write to the court now pointing out this is a supplementary WS and it was submitted to you & the court 17 days after the deadline albeit with a date on to pretend it was written before the deadline, and you invite the court not to accept it.

 

If you get nowhere, then challenge it on the day in court.

[dx100uk]

1 hour ago, Andy711351 said:

1. The first deadline of 18/1/2020 was for filing the DOCUMENTS upon which either party had wished to rely on, not the WS. the second deadline of 1/2/2021, was for the WS to be submitted by. 

 

 

 

just because you didnt read the order properly

its quite usual for docs to be exchanged then you both file WS's later.

 

a SWS does not have to have any deadline

just that you can object at the hearing.

 

you got had..oldest trick in the book.

you fell for it

[Andy711351]

Dear All

 

Thanks alotso far for all your help and advice

 

I will post the following again to refresh the memory

 

1. Claimants WS

2. Defendants WS

3. Supplementary Claimant WS

 

Before even going into the case, I just want to highlight maybe a few things to demonstrate to the judge why they are just so dishonest and devious. I wanted to see if you can advise the merit of raise these points

 

A. total disregard for CPR rules

 

Prior to me submitting my WS, private parking appeals had submitted a template defence ( thats before they went bust). In that defence, we had very clearly stated that 

 

' Please note that, pursuant to CPR PD 6A, I do not consent to being served by electronic means , and my use of such means to file and serve any documents is not indicative of a waiver' 

 

 

On the 15th of January 2021 at 13 45 I receive the Claimants paginated bundle etc.. electronically.

 

Q. I had asked specifically not to be served by electronically means yet the Claimants/solicitors totally ignore that and send me the bundle electronically

 

B. Devious behavior by Claimant/Solicitors

 

1. The first deadline for submitting WS was the 18th of January 2021. That's a Monday. 

Not only do the claimants solicitors serve the documents by electronic means ( contrary to pint made above), but they wait till Friday 15th january at 1.45 pm, knowing that the deadline for me to submit my WS was Monday 18th January. Thats devious and an attempt to give me the least amount of time to gather my thoughts/defence

 

 

2. As discussed earlier there were two court deadlines as mentioned in post 89. The first was 18 jan 2021 and the second was 1st feb 2021. Now the supplementary WS by the claimant was emailed to me on the 17th Feb 2021.

 

To me, these points above illustrate that they first ignore my request for not being served documents electronically, and second they deliberately choose to serve things very very close to the deadline and then in the supplementary WS they dont even adhere by the deadline of 1st feb 2021. 

 

These may all sound irrelevant, but if I was making these mistakes, one can say, that im not legal and itsy first time, but should a legal firm representing the claimant be held to account. Im sure this is not the first time for them in front of a court/judge. 

 

I really would like this point to be emphasised because its all devious

 

 

 

These are general points regarding their conduct.

 

I will post the redacted initial statements and the latest supplementary claimant WS

 

 

Thankyou

 

 

 

 

 

defendant WS redacted and submitted to court (1).docx

Claimant first Witness Statement.pdf

 

I have attached the 3 statements

 

the claimant first WS which they submitted by 18 jan 2021

 

my defence WS submitted by 18 jan 2021

 

the claimants supplementary WS which they should have submitted by the 1st Feb but submitted on 17 Feb. The supplementary claimant WS responds to few points in my defence WS

 

In the Claimants supplementary WS, they raise these issues

 

5. There are numerous signs on the land which reflect ..

 

....     Blue Badge Holders

          Staff parking only

          Customer Parkings Only

          electric vehicles only and

          permit Holders only

 

 

very tactfully they choose not to mention the first signage in their exhibit two where the parking fine is £100 , £60 if paid initially.

 

In point 7, of the supplement WS, they mention that the amount of £100 was a typographical error. THATS NOT CORRECT. The fine of £100 is on the first signage on their exhibit 2, but they have deliberately not even mentioned it in their supplementary WS, in order for it to come across as a typographical error rather than an inconsistency

 

In point 6, they ask the court to disregard the final image of exhibit 2 because it was a clerical error and belongs to a different land.

 

 

I mean, how many typo/clerical errors are they allowed. They are inconsistent with the fine charge mentioning £90 or £100 as eluded to in my defence and then they also say its clerical errro when they include a photo of a signage from a different land, and they also fail to adhere to any deadlines and they also deliberately choose to email me their witness statements late and close to the deadline.

 

 

Is there a way i can raise all these to the judge. I think its way too much to keep on blaming clerical/typographical errors. rather it shows disrespect , in my view

 

 

In the Supp WS attached, exhibit 6 is included with the contract etc between them and the intu leasholders etc...There is a date at the footnote of all the pages of exhibut saying in small print 'Authorisation Date 09032016.    Is that relevant ??

 

any feedback much appreciated

 

 

I have emailed the court asking for me to be present in person rather than a telephone hearing

 

The set date is the week of the 5th of April 2021, so if I were to send one email to the judge, when is the latest I can. I really do want to raise some of these points.

 

 

Many many Thanks

 

Regards

 

 

 

 

claimant supplementary WS redacted.pdf

Edited March 29, 2021 by FTMDave
Thread tidied

[dx100uk]

I hope you haven't been using the word fine in your court documents like you have above?

[Andy711351]

Thanks Dx 100 uk

 

I sent it as PDF.

 

My apologies as I couldnt locate my redacted PDF version.

 

Would you like me to find the one i sewnt to court, redact it again and post it?

 

Thanks

 

[dx100uk]

no just hoping in any documents you've sent to the court you haven't used the word FINE. as you've used it above.

 

[FTMDave]

I think there's a danger here of focussing on minutiae and not seeing the wood ...

 

During the hearing, either in person or on-line, you need to show the judge it was impossible to have entered  into a contract to pay £60/£90/£100 for overstaying, as the charge is deliberately hidden in electron-microscope readable text.

 

Secondly, you did abide by the rule you could actually read, which was not to stay longer than four hours.  You moved your car within that time and can prove it by your shop receipts.  These are your main points.

 

By all means challenge their supplementary witness statement, as explained in posts 88 & 90 & 92.  It's completely unfair that you set out all your points promptly in your WS while they get two bites at the cherry.

 

However, even if the judge does allow their document, so what?  it's pants!  There are the "clerical errors" which change nothing, as you were never going to win because they'd put an irrelevant sign in.  You can turn this to your advantage and say the reason for the errors is that theirs is a cut & pasted roboclaim which no-one has bothered to proof read.

 

There's the usual lazy justification for the Unicorn Food Tax which all the PPCs always trot out.

 

The only "new" point is pretending you must have walked to the shops elsewhere which you have receipts for.  Make sure you're ready for this point and note the distances between the various shops which will show that it is much more probable that you moved your car.

 

Sure, if you get the chance mention that they served you their documentation in the "wrong" way, but is it really so important in comparison with the two main points?

 

BTW, in the communications from Bank Park - Bank Park themselves, not debt collectors or solicitors - is there anything written about the letter coming from their legal department or saying the case will be/has been passed to a legal department?

Edited March 29, 2021 by FTMDave
Thread tidied

[lookinforinfo]

The entrance sign is confusing me. The one they show at the entrance says Merry Hill and states it is £100  per default [albeit in impossibly small writing]yet your PCN says £90 and so does their director. So my question is what amount does the entrance sign actually state?  Their entrance signage is not capable of offering a contract with drivers as the charges are far too small to be read when arriving. I have already pointed out that the signage has been deliberately increased in their paperwork to conceal the actuality of their smallness in the carparks.

 

Looking at ther amended WS in point 7 he states the £100 was a " typographical error". Really? The signs are supposed to be the actual signs that are in place there. They are not to be cobbled together from pictures in their offices somewhere. It is supposed to be within Kelley's knowledge as it was not acknowledged that it wasn't, so it should have been the actual notice. Could this be perjury?

 

And point 8 is amazing. " It is not unreasonable to suggest that the Defendant has walked to the other shops situated at a different car park whilst leaving their Vehicle at the Blue Car Park. 9 " Really? You mean that their much vaunted ANPR system only showed the arrival and departure of vehicles but had no idea where each motor was within the  carpark complex. You have stated that you moved around there because of the distances involved. It is for them to provide strict proof that you didn't move around since it is them that is saying that you stayed in the one place all the time.

 

Point  9 wouldn't apply to you as the keeper since only the driver is liable but I think you have revealed you were the driver?

 

Regarding the lack of Council permission two things spring to mind.

1] the IPC insist that all their members comply with all applicable laws for parking and it is that adherence to the IPC Code that enables them to access DVLA records.

3.1 Outside of this Code  [the IPC code], it is members responsibility to ensure they adhere to all relevant legal provisions

Moving to the contract they have with the land owner 

They also state that all parking laws have to be observed.

And while they state in the contract that Bank are responsible for running the car park issuing NTKs , Reminders and Debt Collection under 'Administration" nowhere does it allow them to take out Court proceedings. And the fact that the Land owner allows 30 minute grace time would further suggest that want their carpark run in a more lenient  fashion than most land owners. 

 

 

[Andy711351]

Thanks Dave and look for info

 

I will addrss the points you raised

 

The hearing is in th week on the 5th of April so need to wrap things up so im very clear

 

Daves points in post #96

 

'During the hearing, either in person or on-line, you need to show the judge it was impossible to have entered  into a contract to pay £60/£90/£100 for overstaying, as the charge is deliberately hidden in electron-microscope readable text'

 

LOOKFORINFO :

 'I have already pointed out that the signage has been deliberately increased in their paperwork to conceal the actuality of their smallness in the carparks'.

 

So  i suppose the signages seems to be the most important point. As you know what is available to the judge would be the exhibits and the electronic copies of the signages . How will i be able to actually; proof that thy are small enough in real life. The judge , as pointed, will see the electronic versions as in the exhibits supplied by the claimant, or even a printed copy. How, can I , as the defendant, on the day , actually proof that the signages in real life ( I have revisited the site) are in fact so small ?  I have also raised several point in para 12-14 regarding the signages being actually inside the car park and not at the entrance and not facing the driver

 

Dave : 'Secondly, you did abide by the rule you could actually read, which was not to stay longer than four hours.  You moved your car within that time and can prove it by your shop receipts.  These are your main points'

 

LOOKFORINFO : 'And point 8 is amazing. " It is not unreasonable to suggest that the Defendant has walked to the other shops situated at a different car park whilst leaving their Vehicle at the Blue Car Park. 9 " Really? You mean that their much vaunted ANPR system only showed the arrival and departure of vehicles but had no idea where each motor was within the  carpark complex. You have stated that you moved around there because of the distances involved. It is for them to provide strict proof that you didn't move around since it is them that is saying that you stayed in the one place all the time'.

 

So, I have raised this in my WS para 20-22 with my bank statements that i visited several places and didnt overstay. Is the point about  putting them to strict proof that I stayed in one place all the time , something they have to proof or I have to provide the evidence for, that i didnt stay there the whole time. 

 

 

So, seems these are the two strong points to argue with, though my only concern still is how do i actually proof to the judge that the the hidden charges in the small print is unreadable, given that the judge gets to only se the magnified electronic version

 

Can I now ask about the other points I raised in my WS

 

1. Locus standi- contract  etc... the claimants in para 4 of their supplement WS explain they have authority etc.. and they have added Exhibit 6 with lots of paperwork. Is this argument dead , in your views. Is the evidence provided by him in Exhibt 6 of the supplement WS enough proof they have authority? If so, what is the date at the bottom of their exhibit 6 documents  saying in small print 'Authorisation Date 09032016.    Is that relevant ??

 

 

I raise the point about planning permission in para 7. I emailed Dudley council and they didnt reply but then persisted and got a reply by email saying  

 

(((Apologies that you have not yet received a response to your enquiry.

 

In terms of signage, some signage can be carried out with deemed consent. I am unable to search for a specific planning application, as Merry Hill is a large site and each application is mapped spatially in relation to specific areas that applications relate to.

 

All planning applications are public information and can be found on the Council’s website where you can search by location and you may be able to find what you’re looking for. Here is the link that will take you to the specific part of the website: https://www.dudley.gov.uk/residents/planning/planning-services/search-for-planning-applications/

 

Kind regards

 

 

DUTY PLANNING OFFICER Planning Services

)))

 

So the council havent been helpful but whats this thing about deemed consent. again this may be irrelevant but does this reply from the counil help because in the claimant supplement WS thy havent addressed the issue of the planning permission

 

2. Double dipping/charging

I raised this in my defence in Para 25 as to where the charges came from. The claimants suppment WS para 9 is the reply. What do you think. has he provided a convincing answer or is this still a point I should persist on

 

 

 

 

 

 

 

 

Dave:

BTW, in the communications from Bank Park - Bank Park themselves, not debt collectors or solicitors - is there anything written about the letter coming from their legal department or saying the case will be/has been passed to a legal department?

 

 

Answer: 

 

This is the timeline  Dave ( how would these be relevant, just for my own curiosity) 

 

 

25/6/2019 NTK from BP management-- NO MENTION oF THE Debt COLLECTORS

24/7/2019 Reminder notice from BPM failure to pay this charge may result in enforcement action which may include County Court proceedings and which may incur additional charges- NO MENTION F THE Debt COLLECTORS

 

13/8/2019 Notice of debt recovery from DCBL certified bailiffs and high court enforcement- Dear XXX, your overdue amount of 90 due to BPM in relation to an unpaid debt has now been passed to DCBL ( direct collection bailiffs limited) to recover the debt on their behalf. A further £50 +VAT admin recovery has now been added

 

19/11/2019 dcb legal ( civil & commercial Litigation Solicitors) letter of Claim . We act on behalf of BPM ltd and write in respect of an unpaid parking charge. this is a formal letter of claim in accordance with pre-action protocol for Debt claims...  etc... The sum currently 

 

???? date ( no date on this one) - dcb legal ( civil & commercial Litigation Solicitors) Dear xxx. having reviewed the content of your defence  we are writing to inform you that our client intends to proceed with the claim. the court will direct both parties to file directions questionnaires in due course. in anticipation, we are enclosing a copy

 

 

 

Please be aware my case is in the week of the 5th of april. I do intend to write a short email regarding me not accepting the supplementary WS. So please any replies at this point to be focused rather than generic. 

 

Also, hen is the latest I can email the court with my so called ' unhappiness' about them submitting a supp WS well past the due date

 

 

Thanks all again

 

:)

 

 

 

[Gick]

Deemed consent are those signs which are accepted as being of PUBLIC/SAFETY interest, eg  bus stop, exit, emergency vehicle access only etc. The signs for parking are an ADVERTISEMENT, ie offering a service (with or without cost). As such, planning permission for their erection or display is therefore a LEGAL requirement. 

Failure to have such consent is a breach of the Code of Practice under which members of both BPA and IPC are bound, without which they are not permitted to obtain keeper details from DVLA.

[Andy711351]

Thankyou Gick

 

In that case I have searched the Dudley portal myself and have had the not so helpful email from there. The claimants supp WS does not mention anything or display any planning permission.

 

If the case is as you say, then thats another strong point , ie lack of planning permission, in addition as eluded to in posts #96 and 97