The court may set aside default judgment if:
- You can show that it has reasonable prospects of successfully defending the claim; or
- It appears to the court there is some other good reason why:
- the judgment should be set aside or varied; or
- the defendant should be allowed to defend the claim.
-See CPR 13.3
You have valid reasons. The problem is the application has to be made "promptly". Promptly" means as soon as possible after the judgment was obtained. Case law established that after 60, an application is not made promptly.
However, the court has broad discretion in set-aside applications, and they often set aside even if the application is not made promptly. For example, they will consider the date on which the defendant became aware of the judgment.
You will also have to show that it has a realistic prospect of defeating the claim that you seem to have.
You will need to file a witness statement in support of the application to set aside default judgment. his statement will form the defence
Explain in the witness statement why you should be allowed to defend the claim (legal argument and issue with the wrong address and so on). It's a good practice to Provide a draft defence as an exhibit. hat helps the court to understand what the dispute is about and why they should allow the case to proceed to a proper trial.
Explain in the witness statement the detriment that the default judgment is causing you and why you were unable to respond to the claim before the judgment was entered. Often a court will set the judgment aside, even though the claim is admitted.
This link has more guidance:
https://www.gov.uk/government/publications/form-n244-application-notice
-The fee is £275
I am happy to answer any questions arising out of this.