Hx Parking/gladstones CCJ - Exceeded 1hrs Free - McDonald's Alma Leisure Park Chesterfield CCJ issued thanks to useless parking fines ltd ***Claim Dismissed***

[Digital_2012]

@FTMDave thanks for pointing out my reading mistake yes i read it but i thought hearing on paper is good for me. 

 

The court sent me N159 form to fill in with return envelope i will fill it and send it back asap

[Digital_2012]

@brassnecked thanks for detail explaination i have signed N159 form which says i disagree with hearing on paper so i can attend the hearing i am making copies as well and sending to Gladstone as well

[Digital_2012]

@FTMDave i have tried numerous times to contact chesterfield council also contacted the original land owner who owned by canada life but no one actually gave me a clear answer. Chesterfield council are useless they never responded well and asked me to original land owner. Only thing left that going back to car park and take photos and vids of sign boards and attac with WS. PS i have submitted N159 form to the court and Gladstone as well

Edited May 20, 2022 by Digital_2012

[Digital_2012]

@FTMDavewhen i visited Alma leisure park there were pandemic restrictions but they ease down for couple of weeks . I went there night time and yes it took time to get to the McDonald's car park and finding the suitable parking bay. Then i went to McDonald's I still have statement showing purchase from McDonald's. Now i need a good WS template and good photo evidence to prove that how bad and unclear their signs boards are

[Digital_2012]

@FTMDaveokay a lot to read but i will keep reading and prepare WS accordingly

[Digital_2012]

@lookin4infothanks it seems like there are a lot of points to chose from your post for WS.

 

Is it possible if can post a draft so i can copy points and include in my ws

 

i will attach the photographs as exhibit and also attach the proof of purchase from the McDonald's as well.

PS shall i include defence as exhibit with Witness statement?

[Digital_2012]

Draft i meant template of witnesse statement

[Digital_2012]

Thanks guys i am working on it i will post the draft when i complete the ws

[Digital_2012]

Ok guys here is the draft of WS please guide me if needs any changes. Thanks

 

 

IN THE COUNTY COURT SHEFFIELD 

 

CLAIM NO: XXXX

 

HX PARKING LTD  (CLAIMANT)

VS

XXX (DEFENDANT)

 

Date: 3^rd May 2022

 

Witness Statement

 

1. I Mr XXX, of xxx and I am the Defendant against whom this claim is made.

1.1. I was the registered keeper of the vehicle XXX.

1.2. The facts in this statement come from my personal knowledge. Where they are not within my own knowledge they are true to the best of my information and belief.

 

2. I confirm that i was the registered Keeper of the vehicle which is in question in this case and the vehicle was parked in Alma leisure centre Chesterfield. The vehicle was parked there because the driver went to McDonald’s for eat in ( the bank statement proof exhibit 1).

 

3. There were no clear signs at the entrance nor in the car park, it was night time and weather was not clear as well.

 

3.1. The photographs of the  NTK letter shows that the car entering the car park at 00.02.00 midnight but the fact is that the car entered before midnight and it took time for the driver to find the suitable parking bay so it allows driver to park the car there for five hours.

 

4. I am not liable to the Claimant for the sum claimed, or any amount at all and this is my Witness Statement in support of my defence as already filed.  

 

5. The Particulars of Claim do not clarify in what capacity they believe I am liable but state that the Defendant is “liable as the driver or keeper” of the vehicle. This appears to be “fishing” for liability. 

 

5.1. Schedule 4 of Protection of Freedom Act 2012 (PoFA) allows recovery of unpaid parking charges from the keeper of the vehicle but the first paragraph 1 (1) (a) states that it only applies “in respect of parking of the vehicle on relevant land:”. The definition of “relevant land” is given in paragraph 3 (1) where subsection (c) excludes Any land … on which the parking of a vehicle is subject to statutory control” 11. The road on which the alleged contravention took place is subject to the Road Traffic Act 1988 (RTA), by virtue of Section 192(1) of RTA and it being a road “to which the public has access”, It is also subject to the Liverpool Airport Byelaws 2019, Schedule 4 of PoFA therefore, does not apply, and the Claimant is unable to hold the keeper of the vehicle liable for the charges.

 

5.2. As part of the KADOE contract, it states under paragraph B2.1(a) seek recovery of unpaid Parking Charges in accordance with the Accredited Trade Association Code of Practice, and using the procedure in Schedule 4 to the Protection of Freedoms Act 2012 (where the vehicle was parked on private land in England or Wales on a particular date). 

 

5.3. the only basis in the DVLA KADOE contract for obtaining the Keeper details is for using POFA. Of course, POFA can’t apply on airport land where byelaws apply – plus POFA is only relevant for parking. PROHIBITION 6. It is also my position that the Claimant has no standing, or cause of action, to litigate in this matter. I base this on the case PCM vs Bull, Claim No. B4GF26K6 (page 79, Exhibit 10), where the Defendant was issued parking tickets for parking on private roads with signage stating “no parking at any time”. District Judge Glen in his final statement mentioned that: “the notice was prohibitive and didn’t communicate any offer of parking and that landowners may have claim in trespass, but that was not under consideration”. 

 

6.1. I question the existence of the alleged contract which the Claimant claims to have been breached by “stopping in a zone where stopping is prohibited”. The signage is wholly prohibitive and makes no offer of consideration. In the absence of consideration, no contract exists 

 

6.2. In case Ransomes vs Anderson, Claim No. 3YS16797, the Defendant went to the industrial estate and after not being able to get into their designated parking area, parked on the road, on a double yellow line, for which he was issued a parking ticket. In his judgment the district judge rejected the contract claim on the basis that the noticed was too vague and uncertain to generate contractual liability. The sign, in question, started with: “Warning: Private property. Not Trespassing. No Parking. No Stopping. No Waiting.

You have entered this private property. You are now subject to the terms and conditions of the landowner listed below”. District Judge accepted in principle that Mr. Anderson committed a trespass and that trespass must have caused some loss to the claimant, in terms of expenses incurred, but made no award of damages in relation to it and dismissed the claim

 

The Service Agreement between Vehicle Control Services (hereby known as VCS) and Liverpool Airport dated 08/07/2013 clearly states “for a fixed period of 24 months” (Exibit C), therefore this contract expired in July 2015.

 

It is contended that no legal contract existed between VCS and Liverpool Airport, at the time of the alleged breach of contract. 

 

7.1. Definition of “Relevant contract” from PoFA 2 [1] means a contract (including a contract arising only when the vehicle was parked on the relevant land) between the driver and a person who is— (a)the owner or occupier of the land; or (b) authorized, under or by virtue of arrangements made by the owner or occupier of the land, to enter into a contract with the driver requiring the payment of parking charges in respect of the parking of the vehicle on the land.

7.2. According to Companies Act 2006, Section 44, a contract to be valid requires a director from each company to sign and then two independent witnesses must confirm those signatures. The fact that no witness signatures are present means the deed has not been validly executed. Therefore, there can be no contract established between VCS and the motorist. And even if “no stopping” could form a contract [which it cannot], it is immaterial. There is no valid contract.

 

7.3. According to information on John Lennon Liverpool Airport website (https://www.liverpoolairport.com/ ). Peel Group/Ancala are the land owners NOT Liverpool Airport. More recently, Ancala Partners LLP, the independent infrastructure Investment Manager completed the acquisition of a 45% interest in the Airport in September 2019, with Peel and Liverpool City Council retaining 45% and 10% interests respectively.  7.4. Surely VCS a company that signs innumerable contracts must be aware that no contract exists at the Liverpool Airport. Two points arise from that. 

 

7.4.1. 7.4.2. The first is that by issuing many PCNs at Liverpool Airport with knowingly not having a valid contract is bordering on fraudulent. Second, VCS in order to gain access to DVLA data VCS have averred that they have complied in their CoP that they have complied with all the legal necessities, which appears patently untrue.

 

7.5. Claimant contract contains logo of BPA (British Parking Association) which implies that VCS operates under BPA code of practice which is false. According to information on BPA website (https://www.britishparking.co.uk/bpa-approved-operators ) VCS is not a member of BPA. (Exhibit C) ILLEGAL SIGNAGE

 

8. After receiving the claim form I subsequently submitted my CPR 31.14 request (Exhibit D), in which I requested copies of the claimant’s planning permission for the signage at the site in question. The claimant failed to produce any, and after checking this myself, I found out that there in NO planning permission granted for said signs, therefore making them illegal as lack of planning permission is a criminal offence under the Road Traffic Acts 1962 and 1991 and no contract can be performed where criminality is concerned.

 

8.1. Planning application for the relevant signage (ref: 15A/0657) was made on 11/03/2015 which expired on 24/08/2015, however without permission being granted this application was later withdrawn by the applicant on 16/06/2021. ABUSE OF PROCESS

 

9. The Claimant seeks recovery of the original £100 parking charge plus an additional £60 described as “contractual costs and interest” or “debt collection costs”. No further justification or breakdown has been provided as required under Civil Procedure Rule 16.4. 

 

9.1. As part of the provisions of the Parking (Code of Practice) Act 2019, on 07/02/2022 a new Code of Practice was published by the government, designed to prevent these “rogue” traders from "ripping people off" (the minister's words) with extra charges, which have been deemed unfair (https://www.gov.uk/government/publications/privateparking-code-of-practice/private-parking-code-of-practice). 

 

9.1.1. 9.1.2. 9.1.3. Section 5.3 of the new Code of Practice states the following: “The provisions of Schedule of the Protection of Freedoms Act 2012 relate specifically to the parking of vehicles on relevant land and the recovery of parking charges – they arose from the need to respect landowners’ interests given the introduction of the prohibition on wheelclamping, and so largely envisage circumstances where a wheel-clamp may otherwise have been applied i.e. to a stationary, generally unoccupied, vehicle. However, this Code also applies to instances where the prohibition on stopping arises from a clear security concern e.g. within airports. Parking operators must only pursue parking charges in instances that could be interpreted as stopping if they have explicit consent to do so on evidenced security or safety grounds from their conformity assessment body, following audit of the adequacy of the signs and surface markings in place to inform drivers of the restrictions in place.” Section 7.2 of the new CoP, defines explicitly, when photographic evidence should be used to serve notice: “Care must be taken to ensure that photographic evidence from camera vehicles is only used to serve a notice of parking charge in respect of parked vehicles, not vehicles whose drivers have momentarily stopped e.g. to check directions or an address within a business park.” The Minister Neil O’Brien, who’s foreword I have attached (Exhibits E) also goes on to state “And there will be no wriggle-room for rogue companies who continue to flout the rules. If they fail to follow this Code, they will effectively be banned from issuing parking charges indefinitely”

 

9.1.4. The publication of this Code therefore marks the start of an adjustment period in which parking companies will be expected to follow as many of these new rules as possible. The Code will then come into full force before 2024, when the single appeals service is expected to be in operation. This indicates that the new CoP should be adhered to now, where possible, but clearly VCS are choosing to ignore these new rules, and continuing to go about their business as normal, regardless of the law.

 

9.2. Even before publication of the government’s Code of Practice, Parliament intended that private parking companies could not invent extra charges. PoFA Schedule 4, paragraph 4(5) states that “The maximum sum which may be recovered from the keeper is the amount specified in the notice to keeper” which in this case is £100. 

 

9.3. Section 9 of the new Code of Practice, regulates the matter of recovery costs: “The parking operator must not levy additional costs over and above the level of a parking charge or parking tariff as originally issued.”

 

9.4. Previous parking charge cases have found that the parking charge itself is at a level to include the costs of recovery ie: Parking Eye Ltd vs Beavis (2015) UKSC 67 which is the authority for recovery of the parking charge itself and no more, since that sum (£85) was held to already incorporate the costs of an automated private parking business model and the Supreme Court Judges held that a parking firm not in possession cannot plead any part of their case in damages. It is indisputable that an alleged “parking charge” penalty is a sum which the Supreme Court found is already inflated to more than comfortably cover all costs. The case provides a finding of fact by way of precedent, that the £85 (or up to a Trade Body ceiling of £100 depending on the parking firm) covers the costs of the letters. Since 2019, many County Courts have considered claims in excess of £100 to be an abuse of process leading to them being struck out ab initio. An example, in the Caernarfon Court in VCS v Davies, case No. FTQZ4W28 on 4^th September 2019, District Judge Jones-Evans stated ‘’Upon it being recorded that District Judge Jones-Evans has over a very significant period of time warned advocates [...] in many cases of this nature before this court that their claim for £60 is unenforceable in law and is an abuse of process and is nothing more than a poor attempt to go behind the decision of the Supreme Court v Beavis which inter alia decided that a figure of £160 as a global sum claimed in this case would be a penalty and not a genuine pre-estimate of loss and therefore unenforceable in law and if the practice continued, he would treat all cases as a claim for £160 and therefore a penalty and unenforceable in law it is hereby declared [...] the claim is struck out and declared to be wholly without merit and an abuse of process.’’

 

 9.5. In Claim numbers F0DP806M and F0DP201T, Britannia vs Crosby the courts went further in a landmark judgement in November 2019 which followed several parking charge claims being struck out in the area overseen by His Honour Judge Iain HamiltonDouglas Hughes GC, the Designated Civil Judge for Dorset, Hampshire, Isle of Wight & Wiltshire. District Judge Taylor echoed earlier General Judgment or Orders of District Judge Grand, stating ‘’It is ordered that the claim is struck out as an abuse of process. The claim contains a substantial charge additional to the parking charge which it is alleged the Defendant contracted to pay. This additional charge is not recoverable under the Protection of Freedoms Act 2012, Schedule 4 nor with reference to the judgment in ParkingEye v Beavis. It is an abuse of process from the Claimant to issue a knowingly inflated claim for an additional sum which it is not entitled to recover. This order has been made by the court of its own initiative without a hearing pursuant to CPR Rule 3.3(4) of the Civil Procedure Rules 1998...'' 

 

9.6. The addition of costs not previously specified on signage are also in breach of the Consumer Rights Act 2015, Schedule 2, specifically paras 6, 10 and 14They have no planning permission for their signs and ANPR cameras which means that in addition to them being unlawful because of the extra charges they are also illegal because they have not been given permission to be there under  the Town and Country [Advertisements} Regulations  1969. They are supposed to comply with the Law and the IPC code of Conduct and they have done neither. The new Private Parking Code of Practice  draws attention to it as well  s14.1 [g]  “g) responsibility for obtaining relevant consents e.g. planning or advertising consents relating to signs.”

 

 

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.

Edited May 23, 2022 by Digital_2012

[Digital_2012]

@FTMDave okay thanks in advance

[Digital_2012]

@FTMDave no  i did not request any CPR and i believe that PF Ltd also not requested from fleecers

[Digital_2012]

@FTMDave i am attaching the photographs of the Alama park please have a look. Checking your previous post where you corrected some line and suggest some but i could not understand. Is it possible if you edit and delete irrelevant lines. 

 

I have edited little bit but not sure what to add and what to look for

 

Mr XXX, of xxx and I am the Defendant against whom this claim is made.

1.1. I was the registered keeper of the vehicle XXX.

1.2. The facts in this statement come from my personal knowledge. Where they are not within my own knowledge they are true to the best of my information and belief.

 

INSUFFICIENT & CONFUSING SIGNAGE  This is likely to be one of your aces so will need a lot of work once you get photos.  The fleecers have also shown a plan where they claim there are signs (their WS post 12, PDF page 15 which you need to confront).

 

2. I confirm that i was the registered Keeper of the vehicle which is in question in this case and the vehicle was parked in Alma leisure centre Chesterfield. The vehicle was parked there because the driver went to McDonald’s for eat in (the bank statement proof exhibit 1).

 

3. There were no clear signs at the entrance nor in the car park, it was night time and weather was not clear as well.

 

3.  Even if the driver had seen the signs, they would have been extremely confusing.  A car is normally allowed to be parked for five hours, yet after midnight this is changed to one hour.  This begs the question for how long a motorist entering at 10pm for example is allowed to stay.  Is it for five hours until 3am or until 1am?

 

3.1. The PCN/NTK states "period of parking 00:02:05".  It is common sense that a couple of minutes was needed to enter the complex, find McDonald's and find a parking space, before the period of parking began, so it was likely the car entered the car park before midnight allowing the driver to park the car there for five hours.

 

4.  Even if the driver had seen the signage - they did not - the mention of a £100 charge is literally the last word on the last line of a long board of text.

 

4. I am not liable to the Claimant for the sum claimed, or any amount at all and this is my Witness Statement in support of my defence as already filed.  

 

UNFAIR TERM

 

4.  In an interview with the local newspaper (exhibit XXX) Ms Ellie Berkeley, HX PCN administration team leader, said: “The five-hour maximum stay prevents workers from close by abusing the land and parking there for free, without using the shops on site" which makes sense.

 

5.  This therefore begs the question of why this limit is cut by a massive 80% after midnight when the cinema and eateries are still open.  The driver indeed ate at McDonald's.

 

6.  Ms Berkeley continued: "Five hours is sufficient time to visit the cinema and also eat at a restaurant".  Certainly five hours are sufficient.  One hour is not. 

 

7.  I would maintain this is an unfair term under the Consumer Rights Act 2015 part 2 section 62 (6) ""A notice is unfair if, contrary to the requirement of good faith, it causes a significant imbalance in the parties’ rights and obligations to the detriment of the consumer".  Such a term has absolutely nothing to do with efficient management of a car park and everything to do with trying to catch diners or cinema-goers out and thus have an excuse to issue PCNs.

 

NO KEEPER LIABILITY

 

5. The Particulars of Claim do not clarify in what capacity they believe I am liable but state that the Defendant is “liable as the driver or keeper” of the vehicle. This appears to be “fishing” for liability.  Is this really in the PoCs? - you need to look and find out. Where to look on PCN letter?

 

The rest of your section is about the use of POFA at airports which is completely irrelevant. 

 

Adapt LFI's suggestions re POFA and keeper liability -

 

First is the fact that they must have a parking period and it is quite clear that entering and leaving the car park does not constitute a parking period since some of the time the motorist is either driving around looking for a parking spot then leaving the spot and driving to the exit. All that takes time so that is one fail.

 

The other fail is in their wording when they are trying to transfer the liability of the alleged debt from the driver to the keeper. They are supposed to include at Schedule 4 s9 [2][f] this "(if all the applicable conditions under this Schedule are met)". That in itself makes it non compliant but the fact that they haven't got a parking period means they haven't met the applicable conditions.

 

PROHIBITION  This deals with no stopping cases.  Yours in not no stopping so it is completely irrelevant.

 

LOCUS STANDI

 

You have quoted a different contract in a different place with a different PPC.  You need to read and try to find holes in the contract they produced (post 12, page 15 of the PDF for anyone looking in). What shall i add here

 

Adapt LFI's suggestions -

 

Looking at their contract, the names of the signatories and their positions in their respective  companies have been redacted. You do need strict proof of who actually signed. There is no specific authorisation from the Client to allow Court action in pursuit of non payers. In section 11 which is like an addendum it states" the Company shall provide parking control" but doesn't state if that includes legal pursuit as well and it does not appear to be signed.

 

ILLEGAL SIGNAGE

 

8. After checking, I have found out that there in NO planning permission granted for said signs, therefore making them illegal as lack of planning permission is a criminal offence under the Road Traffic Acts 1962 and 1991 and no contract can be performed where criminality is concerned.

 

LFI's suggestion -

 

They are supposed to comply with the Law and the IPC code of Conduct and they have done neither. The new Private Parking Code of Practice  draws attention to it as well  s14.1 [g]  "g) responsibility for obtaining relevant consents e.g. planning or advertising consents relating to signs."

 

ABUSE OF PROCESS  I've cut some bits out as the CoP hadn't been published when the fleecers went after you.  Are you sure the Unicorn Food Tax in the PoCs is £60? ( I couldn't understand this)

 

9. The Claimant seeks recovery of the original £100 parking charge plus an additional £60 described as “contractual costs and interest” or “debt collection costs”. No further justification or breakdown has been provided as required under Civil Procedure Rule 16.4. 

 

9.1. As part of the provisions of the Parking (Code of Practice) Act 2019, on 07/02/2022 a new Code of Practice was published by the government, designed to prevent these “rogue” traders from "ripping people off" (the minister's words) with extra charges, which have been deemed unfair (https://www.gov.uk/government/publications/privateparking-code-of-practice/private-parking-code-of-practice). 

 

9.3. Section 9 of the new Code of Practice, regulates the matter of recovery costs: “The parking operator must not levy additional costs over and above the level of a parking charge or parking tariff as originally issued.”

 

9.2. Even before publication of the government’s Code of Practice, Parliament intended that private parking companies could not invent extra charges. PoFA Schedule 4, paragraph 4(5) states that “The maximum sum which may be recovered from the keeper is the amount specified in the notice to keeper” which in this case is £100. 

 

9.4. Previous parking charge cases have found that the parking charge itself is at a level to include the costs of recovery ie: Parking Eye Ltd vs Beavis (2015) UKSC 67 which is the authority for recovery of the parking charge itself and no more, since that sum (£85) was held to already incorporate the costs of an automated private parking business model and the Supreme Court Judges held that a parking firm not in possession cannot plead any part of their case in damages. It is indisputable that an alleged “parking charge” penalty is a sum which the Supreme Court found is already inflated to more than comfortably cover all costs. The case provides a finding of fact by way of precedent, that the £85 (or up to a Trade Body ceiling of £100 depending on the parking firm) covers the costs of the letters. Since 2019, many County Courts have considered claims in excess of £100 to be an abuse of process leading to them being struck out ab initio. An example, in the Caernarfon Court in VCS v Davies, case No. FTQZ4W28 on 4^th September 2019, District Judge Jones-Evans stated ‘’Upon it being recorded that District Judge Jones-Evans has over a very significant period of time warned advocates [...] in many cases of this nature before this court that their claim for £60 is unenforceable in law and is an abuse of process and is nothing more than a poor attempt to go behind the decision of the Supreme Court v Beavis which inter alia decided that a figure of £160 as a global sum claimed in this case would be a penalty and not a genuine pre-estimate of loss and therefore unenforceable in law and if the practice continued, he would treat all cases as a claim for £160 and therefore a penalty and unenforceable in law it is hereby declared [...] the claim is struck out and declared to be wholly without merit and an abuse of process.’’

 

 9.5. In Claim numbers F0DP806M and F0DP201T, Britannia vs Crosby the courts went further in a landmark judgement in November 2019 which followed several parking charge claims being struck out in the area overseen by His Honour Judge Iain HamiltonDouglas Hughes GC, the Designated Civil Judge for Dorset, Hampshire, Isle of Wight & Wiltshire. District Judge Taylor echoed earlier General Judgment or Orders of District Judge Grand, stating ‘’It is ordered that the claim is struck out as an abuse of process. The claim contains a substantial charge additional to the parking charge which it is alleged the Defendant contracted to pay. This additional charge is not recoverable under the Protection of Freedoms Act 2012, Schedule 4 nor with reference to the judgment in ParkingEye v Beavis. It is an abuse of process from the Claimant to issue a knowingly inflated claim for an additional sum which it is not entitled to recover. This order has been made by the court of its own initiative without a hearing pursuant to CPR Rule 3.3(4) of the Civil Procedure Rules 1998...'' 

 

9.6. The addition of costs not previously specified on signage are also in breach of the Consumer Rights Act 2015, Schedule 2, specifically paras 6, 10 and 14.

 

 

Statement of Truth 

 

Alma Leisure.pdf Alma leisure centre.pdf

[Digital_2012]

@FTMDavethanks for guiding me step by step. I have captured the photos night time as well if you see they are not visible even in day time how can anyone see in the night

[Digital_2012]

@FTMDave  Those pics taken while in the McDonald's car park, this is the same place where I parked my car night time when i went to McDonald's . One thing to be noted that its a big car park where there are many shops and cinema in there

Edited May 24, 2022 by Digital_2012

[Digital_2012]

@FTMDave ok i attached the fleecers WS again. Also i am working on photographs to make separate day and night one

Hx parking- Witness Statement (D)(1)-Reduced.pdf

[Digital_2012]

@FTMDave okay so what next we need to do apart from sorting photographs or is it just wait till 14 days left then submit WS

[Digital_2012]

@FTMDave thanks i am sorting out photographs with headings so judge can see in detail how the entrance look like and how visible entrance borads are. Also giving headings while in McDonald's car park in night time so judge will see how clear and visible they are with naked eye. Also i would like add in WS that the recent photographs taken in good weather conditions and when i went first time in August 2020 it was cloudy and bit rainy as well.

[Digital_2012]

@FTMDave ok i have attached new pics with detail headings could you please align with correct exhibit so WS can be more accurate. Thanks

Alma Park 24th May 2022.pdf

[Digital_2012]

@FTMDave right the previous pictures taken by my mrs with her iPhone yesterday i have taken with my Samsung so maybe picture quality difference but one thing for sure that the picture taken by iphone match with when u see with your eyes

[Digital_2012]

@FTMDavei would go with the previous photographs they also captured recently i am giving them headings so will upload again here so far i have

 

Bank statement

Day photos and night photos 

 

I did not understand your previous post regarding article from local rag and governments cops

 

 

 

[Digital_2012]

@FTMDave thanks almost everything ready now i will post pics soon with headings soon

[Digital_2012]

Ok i have combined day and night view please have a look

Alma leisure centre.pdf

[Digital_2012]

@FTMDave many thanks

[Digital_2012]

@FTMDave looking great so all exhibits and WS is aligned properly so now waiting to submit

[Digital_2012]

Ok guys so probably we are expecting around 15th or 16th June 2022 as the actual date to submit is 29th June