She only mentioned some goods and services act in the claim.
I have written a defence as follows.
This will give you a fair idea.
County Court Business Centre
Miss .. paid the institute for the services her claim is against the institute not me. request the honourable court to strike the claim under Civil Procedure Rule 3.4(2) on the basis that there are no reasonable grounds for bringing the claim.
Miss .. joined institute for her NVQ Level 2,3 and 4.(FAST TRACK 3 months).
She has paid the fee in 3 instalments spread over 3 months. She has completed her assignments, first practical assessments observed and assessed by Internal Quality Assurance. She did her all portfolio (except one module left). Her online theory exam was done(copy attached). We have given her complete services as per the guidelines of the awarding body (V...).
Nvq qualification specially in beauty sector need practical and theory work where you have to produce evidence that you are competent in both. She has been given an opportunity to gain work experience in a reputed local salon (..) arranged by....
The issue has been investigated by the Institute itself and awarding body V... over 3 levels and concluded that we acted in professional and supportive manner towards her learning and given her full required service.
The case is malicious as it is against me and not the institute as I'm the tutor and provide my services on behalf of Institute however she didn't want to admit that qualification run by a professional system not by one person and there is certain criteria which need to be fulfilled.
In spite of all the help and support which we have provided She didn't submit her portfolio and claimed refund. Although her registration is still valid and we have given her opportunities to finish her work.
I request the court to drop this case and I strongly believe that she should be given medical help as her mother who has hidden her medical condition and Miss .... withheld her condition on the enrolment form for special requirement.
I am enclosing all the supporting documents including proofs of the service provided to her and investigation reports of the awarding body V...