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What about this rule:
6.1.2 (b) the defendant is known not to hold insurance cover,
the CNF must be sent to the defendant’s registered office or principal place of business and no Defendant Only CNF is required.
The Rule infers that the matter can commence outside the Portal so my view is that as long as the Portal rules are complied with then Portal costs should apply notwithstanding it being outside. Where does it say in the Portal that anyone has to be signed up to it. The rule needs clarifying.........