“…s “he is unable to admit or deny” and if they are within his knowledge then he is not so unable: see SPI North Ltd v Swiss Post International (UK) Ltd and anor [2019] EWCA Civ 7, [2019] 1 WLR 2865, [3]. They also point out that they have admitted many other facts in their pleaded Defences that they are not strictly obliged to admit in …”