Victoria Jones
Victoria has over 17 years’ experience as a commercial litigator, with a particular expertise in property litigation, and has been a professional support lawyer, both for law firms and on a freelance basis, since 2010.
Victoria is currently an associate and professional support lawyer at Freeths, where she provides technical support to the Dispute Management lawyers across all offices. This includes: developing and maintaining the know-how folders with precedents and guidance notes; ensuring that lawyers and clients are kept up to date on developments in the law; delivering and organising training; and undertaking research.
Practice Areas
Panels
- Contributing Author
- Q&A Panel
Qualified Year
- 2000
Membership
- Association of Litigation Professional Support Lawyers
Education
- University of Durham, BA (Hons) Classics
- De Montfort University, Postgraduate Diploma in Law
- Nottingham Law School, Legal Practice Course
14 Contributions by Victoria Jones
PRACTICE NOTES
CPR Part 55 Possession Claims: Entitlement, Issuing, Defences, Hearings, Orders and Enforcement after Commercial or Residential Lease or Licence Expiry (England and Wales)
This Practice Note sets out how to bring a possession claim when a lease or licence has ended, for both residential and commercial premises. It covers Part 55 of the Civil Procedure Rules (CPR 55), preparing the claim, and practical points for the hearing. For guidance in other situations requiring possession proceedings, see Practice Notes:
Terminating assured and assured shorthold tenancies—pre-Renters' Rights Act position
Forfeiture of a lease
Trespassers—possession proceedings
LTA 1954 business lease renewal—proceedings
Mortgage possession claims
Entitlement to possession
A tenant’s right to occupy ends after the contractual term expires in several cases, including:
the lease is commercial and is contracted out of the security of tenure provisions of LTA 1954, or security of tenure is otherwise lost (see Practice Note: LTA 1954 business lease renewal—termination)
the lease is residential but falls outside the criteria for security of tenure (see Practice Note: A summary of types of private residential tenancies)
Where a fixed term ends, the tenant’s right to possession ceases and the landlord is entitled to possession...
Property Disputes
PRACTICE NOTES
Residential service charge disputes: reasonableness, compliant demands, 18‑month rule, BSA 2022 remediation, FTT applications, tenant information rights, landlord cost recovery and enforcement under the LTA 1985
This Practice Note sets out the steps for dealing with many of the most frequent residential service charge disputes under the Landlord and Tenant Act 1985 (LTA 1985). It covers a landlord’s ability to recover residential service charges, whether a demand is reasonable, when demands must be issued, the timing and wording of formal notices, and the process for issuing an application in relation to service charge demands and recovery before the First Tier Tribunal (Property Tribunal), together with the recovery of the landlord’s costs arising from service charge proceedings. For broader guidance on the statutory consultation regime for qualifying works and qualifying long term agreements, and the kinds of disputes that process may trigger, see the separate Practice Note: Consultation for residential service charges.
The power to recover residential service charges
A core principle for service charge recovery is that a landlord has no duty to provide any service unless the lease states it expressly. Equally, a landlord cannot impose a service charge, and a leaseholder need not pay for any item, unless it falls within the lease.
Reasonableness of the service charge demand
For residential dwellings, a service charge must be reasonable, to the extent in each case...
Property Disputes
PRACTICE NOTES
Section 49(1) LPA 1925 vendor and purchaser summons: pre-completion land contract disputes—jurisdiction, CPR Part 8 procedure, orders and limits (England and Wales)
Section 49 of the Law of Property Act 1925
This Practice Note outlines the procedure under section 49(1) of the Law of Property Act 1925 (LPA 1925). It enables a buyer or seller of any interest in land (or their representatives), during the period between exchange and completion, to make a summary application to the court in relation to:
any requisitions or objections
any claim to compensation, or
any other issue arising from or connected with the contract (other than a matter affecting the contract’s existence or validity)
The provision applies to contracts for the sale or exchange of any interest in land. The court may make whatever order appears just, including directions on the costs of and incidental to the application. The court has no power to award damages. For guidance on the court’s discretion to order repayment of a deposit under LPA 1925, s 49(2), see Practice Note: Return or forfeiture of a deposit.
When is it appropriate to use the section 49(1) procedure?
The s 49(1) route (also known as a ‘seller and buyer summons’) is intended to be a relatively swift and economical means of resolving disputes between a seller and buyer arising...
Property Disputes
PRECEDENTS
Court directions order template for opposed LTA 1954 business lease renewal: preliminary section 30(1) issue (England and Wales)
Claim No. [ insert claim number ]. [ IN THE HIGH COURT OF JUSTICE [ BUSINESS AND PROPERTY COURTS [ OF ENGLAND AND WALES OR IN [ insert location ] ] ] [ State division ] [ Identify specialist court ] [ Insert location ] DISTRICT REGISTRY OR THE COUNTY COURT AT [ insert location ] [ BUSINESS AND PROPERTY COURTS LIST ] ] Before [ The Honourable Mr Justice OR The Honourable Mrs Justice OR His Honour Judge OR Her Honour Judge OR Master OR District Judge ] [ insert name ] dated: [ insert date ] between: [ insert name ] Claimant and [ insert name ] Defendant
Directions
Having considered the allocation questionnaires provided by the parties. [ upon the parties having agreed the directions set out below. AND upon hearing the parties. ] The following is ordered:
Allocation [ The matter is allocated to the multi-track. Cost budgeting is dispensed with. OR The matter is allocated to the fast-track. ]...
Property Disputes
PRECEDENTS
Defending section 21 standard possession claims: drafting Form N11R for ASTs, arrears proposals, counterclaims and precondition challenges (England)
FORTHCOMING CHANGE :
The Renters’ Rights Act 2025 was granted Royal Assent on 27 October 2025. For guidance on how the Act affects residential tenancies in England, see Practice Note: Renters’ Rights Act 2025—key provisions.
Introduction
The defence must be submitted on Form N11R. These drafting notes are provided solely to assist with completing Form N11R.
Relevant precedents
For further relevant precedents, refer to:
Drafting notes for claim form in section 21 standard possession proceedings
Drafting notes for particulars of claim in s 21 notice standard possession proceedings
General points
These notes are intended to help with completing Form N11R, the defence used where a landlord of property let on an assured shorthold tenancy (AST) has begun possession proceedings under the standard possession procedure. For these notes, it is assumed the landlord’s case also includes a claim for rent arrears. A landlord may instead elect to use the accelerated possession procedure where possession is sought from an assured shorthold tenant under section 21 of the Housing Act 1988 (HA 1988), provided there is no additional claim, such as for money...
Property Disputes
PRECEDENTS
Defending Section 8 possession (non‑arrears): completing Form N11R, grounds 1–7, 9, 12–17, counterclaims and reasonableness—England and Wales
FORTHCOMING CHANGE :
The Renters’ Rights Act 2025 obtained Royal Assent on 27 October 2025. For advice on the Act’s effect on residential tenancies in England, see Practice Note: Renters’ Rights Act 2025—key provisions.
Introduction
Where a possession claim relies on grounds other than rent arrears, the correct defence is filed using Form N11R (defence form—rented residential premises). These drafting notes are provided solely to support completion of Form N11R.
Relevant precedents
Drafting notes for a section 8 notice seeking possession of property let under an assured tenancy (AT) or assured shorthold tenancy (AST)
Drafting notes for the claim form in section 8 proceedings for possession (AT or AST) arising from rent arrears and/or other breaches
Drafting notes for particulars of claim in section 8 proceedings (AT or AST) relating to non-payment of rent and/or other breaches
Drafting notes for a defence to section 8 possession claims brought for non-payment of rent
General points
These notes are intended to guide completion of Form N11R, the defence document for possession claims concerning rented residential premises...
Property Disputes
PRECEDENTS
Drafting notes: particulars of claim (Form N119) for section 21 standard possession proceedings for ASTs in England, including rent arrears and compliance with pre-conditions
FORTHCOMING CHANGE :
The Renters’ Rights Act 2025 obtained Royal Assent on 27 October 2025. For detailed guidance concerning the Act’s effect on residential tenancies in England, see Practice Note: Renters' Rights Act 2025—key provisions.
How to use these drafting notes
These drafting notes are intended for preparing particulars of claim where a private landlord has issued a notice under section 21 of the Housing Act 1988 (HA 1988) to the tenant of a property let on an assured shorthold tenancy (AST), and the standard procedure for possession is being followed, rather than the accelerated route. Form N119 should be used for the particulars of claim in this context. For further guidance, see Practice Note: Assured and assured shorthold tenancies—terminating...
Property Disputes
PRECEDENTS
Guidance on completing Form N11R for defending Section 8 rent arrears possession claims: arrears disputes, disrepair set-off, repayment terms and exceptional hardship (England and Wales)
FORTHCOMING CHANGE
The Renters’ Rights Act 2025 obtained Royal Assent on 27 October 2025. For guidance on the Act’s effect on residential tenancies in England, see Practice Note: Renters’ Rights Act 2025—key provisions.
Introduction
The defence to a possession claim arising from non-payment of rent must be filed using Form N11R (defence form—rented residential premises). These drafting notes assist with properly completing Form N11R only...
Property Disputes
PRECEDENTS
Opposed LTA 1954 Lease Renewal: Tenant’s Form N1 Drafting Notes, Particulars and Interim Rent Guidance (England and Wales)
Introduction
Where a landlord contests a request for a new tenancy under the Landlord and Tenant Act 1954 (LTA 1954), the application must be brought using Form N1. These drafting notes are provided to accompany, and are intended for use solely with, Form N1, which is the required claim form in such circumstances.
Other precedents
For other relevant precedents, see:
Directions—opposed LTA 1954 business lease renewal
Landlord’s defence opposing tenant’s claim for a lease renewal
General points
These notes are designed to assist with completing Form N1 where a tenant of business premises seeks a renewal under the LTA 1954 and the landlord is opposing that renewal. Opposed lease renewal proceedings are brought under the Part 7 procedure, and evidence is filed in accordance with the court’s directions, with the landlord serving their evidence first. A claim can be issued at any County Court hearing centre; however, if it is commenced at a centre that does not serve the address at which the land is located, the court will transfer it to the hearing centre that serves that address. Accordingly, time is saved by issuing the claim at the County Court hearing centre serving the area in which the land is situated...
Property Disputes
PRECEDENTS
Precedent Adjoining Owner Counter-notice under s.4 Party Wall etc. Act 1996 (England and Wales): additional works, special foundations consent, early start, and surveyor nomination
To:
[ insert Building Owner ] Of: [ insert Building Owner’s main address ] Being the Adjoining [ Owner OR Owners ] for the purposes of the Party Wall etc Act 1996 (the ‘Act’) in respect of [ insert Adjoining Owner’s building ], and noting receipt of a notice dated [ insert date ] concerning proposed works at [ insert Building Owner’s building ], and without prejudice to any of [ my OR our ] rights under the Act, [ I OR we ]...
Property Disputes
PRECEDENTS
Precedent defence opposing tenant’s 1954 Act business lease renewal (England and Wales)
Claim No. [ insert claim number ]
[ IN THE HIGH COURT OF JUSTICE [ BUSINESS AND PROPERTY COURTS [ OF ENGLAND AND WALES OR AT [ insert location ] ] ] [ Specify division ] [ Specify specialist court ] [ Insert location ] DISTRICT REGISTRY, OR THE COUNTY COURT AT [ insert location ] [ BUSINESS AND PROPERTY COURTS LIST ] ]
Between: [ insert name ] Claimant and [ insert name ] Defendant
Defence
[ The Defendant disputes the granting of a new tenancy on the grounds set out in its notice served pursuant to section 25 of the Landlord and Tenant Act 1954 (‘the Act’): [ ground or grounds plus full details ]. OR The Defendant disputes the granting of a new tenancy on the grounds identified in its notice under section 26(6) of the Landlord and Tenant Act 1954 (‘the Act’): [ ground or grounds plus full details ]. ]...
Property Disputes
PRECEDENTS
Template case management directions and timetable for unopposed LTA 1954 business lease renewal (England and Wales)
Claim No. [ enter claim number ].
[ IN THE HIGH COURT OF JUSTICE [ BUSINESS AND PROPERTY COURTS [ OF ENGLAND AND WALES OR AT [ enter location ] ] ] [ name division ] [ name specialist court ] [ [ enter location ] DISTRICT REGISTRY OR THE COUNTY COURT AT [ enter location ] [ BUSINESS AND PROPERTY COURTS LIST ] ] ]
before [ The Honourable Mr Justice OR The Honourable Mrs Justice OR His Honour Judge OR Her Honour Judge OR Master OR District Judge ] [ enter name ] dated: [ enter date ] between: [ enter name ] Claimant and [ enter name ] Defendant
Directions
Having reviewed the allocation questionnaires lodged by the parties. [ And upon the parties having agreed the directions set out below. OR And upon hearing from the parties. ] It is ordered as follows:
1 Allocation
The claim is allocated to the multi-track...
Property Disputes
PRECEDENTS
Tenant’s Defence to Section 30(1)(f) Redevelopment: LTA 1954 (England and Wales) Opposed Renewal with Section 31A Works Proposals, Interim Rent (s24A), and Corporate Occupation Provisions
Claim No. [ insert claim number ] [ IN THE HIGH COURT OF JUSTICE [ BUSINESS AND PROPERTY COURTS [ OF ENGLAND AND WALES OR IN [ insert location ] ] ] [ Specify division ] [ Specify specialist court ] [ Insert location ] DISTRICT REGISTRY OR THE COUNTY COURT AT [ insert location ] [ BUSINESS AND PROPERTY COURTS LIST ] ] between: [ insert name ] Claimant and [ insert name ] Defendant
_______________________________________
DEFENCE
_______________________________________
1 The Defendant contests the Claimant’s attempt to end the tenancy granted by the Claimant to the Defendant. The Defendant does not accept that the Claimant intends to [ demolish or reconstruct the premises comprised in the holding or a substantial part of those premises or to carry out substantial work of construction on the holding or part thereof ], and calls upon the Claimant to prove the same.
2 [ The Defendant does not rely upon section 23(1A) of the Landlord and Tenant Act 1954 (‘the Act’)....
Property Disputes
PRECEDENTS
Unopposed Landlord and Tenant Act 1954 business lease renewal (tenant’s claim): completing Form LT503(LN), required particulars and example wording (England and Wales)
Introduction
Where a business tenant seeks a tenancy renewal under the Landlord and Tenant Act 1954 (LTA 1954) and the landlord does not contest the application, the correct vehicle is Form LT503(LN). These drafting notes accompany, and should be used solely with, Form LT503(LN). The form is available here: Form LT503(LN). It is for situations where renewal is unopposed by the landlord and should be used for that purpose only.
Other precedents
For relevant precedents, consult:
Directions—unopposed LTA 1954 business lease renewal
Acknowledgment of service by tenant in unopposed claim by landlord for new tenancy: Atkin’s Court Forms, Vol 24(2) [158]
Acknowledgment of service by landlord in unopposed claim by tenant for new tenancy: Atkin’s Court Forms, Vol 24(2) [157]
General points
These notes are intended to help with completing Form LT503(LN), being the claim form used when a tenant of commercial premises seeks a renewal under the LTA 1954 and the landlord raises no opposition. Uncontested renewals proceed via the Part 8 procedure; refer to the Practice Note: CPR Part 8 claims (alternative procedure for claims). Evidence is not required to be filed unless, and until, the court directs that it must be...
Property Disputes
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