Serving a claim by WhatsApp, Facebook or Instagram

If the only way you can reach the person who owes you money is a messaging app, the rules do not let you simply send the claim form as a message. They do let you ask the court for an order permitting service that way, if your evidence shows the message is likely to reach them.

Checked against official sources on 30 September 2026. Court fees from 13 July 2026; enforcement agent fees from 1 May 2026.

Key facts

A WhatsApp, Messenger or Instagram thread is not consent to be served that way: PD 6A para 4.1 requires a prior written indication that the person will accept service by electronic means (Barton v Wright Hassall [2018] UKSC 12).
The route is a paper N1 claim form, which the court issues and retains (PD 16 para 2.3), plus an N244 application under CPR 6.15 for service by an alternative method, fee £126 if made without notice.
The application must be supported by evidence showing why the message is likely to reach the defendant, for example prior replies on that exact channel and read receipts (PD 6A paras 9.1 and 9.3(2); Bunina v Nasibov [2026] EWHC 605 (Ch)).
Any order must state the method, the deemed date of service and the time for responding (CPR 6.15(4)), and must then be followed exactly (MBR Acres v McGivern [2022] EWHC 2072 (QB)).
Orders are made on evidence, not automatically: in Chirkunov v Persons Unknown [2024] EWHC 3177 (KB) the court refused where the channel was not shown to be monitored.

Why you cannot just message the claim form

A claim form must be "served" by one of the methods in CPR Part 6. Electronic service is on the list, but only in accordance with Practice Direction 6A, and para 4.1 requires that the person to be served has previously indicated in writing that they will accept service by electronic means and has given the address or identifier to be used. A chat thread in which the defendant used WhatsApp or Instagram to agree the deal is not that.

The Supreme Court applied this strictly in Barton v Wright Hassall LLP [2018] UKSC 12: a litigant in person who emailed his claim form without prior agreement had not served it, and being unrepresented does not usually justify a lower standard of compliance. Sending the claim form as a message without an order therefore risks the claim never having been validly served.

Online Civil Money Claims (the gov.uk "Make a money claim" service) and Money Claim Online both need a postal address in England or Wales for the defendant. Read Finding someone's address first: the court will expect you to have looked for one before asking to serve by message.

The route the rules provide: issue on paper, then apply under CPR 6.15

CPR 6.15(1) allows the court, where "there is a good reason", to permit service "by a method or at a place not otherwise permitted by this Part". Abela v Baadarani [2013] UKSC 44 says nothing exceptional is needed, but Cameron v Liverpool Victoria [2019] UKSC 6 confirms the method must be one that "can reasonably be expected to bring the proceedings to the attention of the defendant".

The mechanics work like this:

Complete a paper claim form N1 for the Civil National Business Centre, St Katharine's House, 21–27 St Katharine's Street, Northampton NN1 2LH, with the issue fee (see Court fees). Give the defendant's details as far as known and state that a postal address is unknown and a CPR 6.15 application is attached.
Under PD 16 para 2.3 a claim form without a full address "will be issued but retained by the court and not served" until an address is supplied or the court dispenses with the requirement. CPR 6.6(3) confirms the address requirement falls away once a CPR 6.15 order specifies the method.
Complete application notice N244 asking for an order permitting service by the messaging channel. Under CPR 6.15(3) the application "must be supported by evidence" and "may be made without notice". The fee without notice is £126 from 13 July 2026 (£321 on notice); Help with Fees can be claimed on it.
Ask on the N244 for the application to be dealt with without a hearing (PD 23A para 5.2 allows a District Judge to consider it on paper) and attach a draft order.
Send the N244, witness statement, draft order and fee with the N1.

The High Court has permitted service by Facebook (AKO Capital v TFS Derivatives, 2012), Instagram (DDF v YYZ, 2015), WhatsApp (Gray v Hurley [2019] EWHC 1636 (QB)) and Telegram (Bunina v Nasibov [2026] EWHC 605 (Ch), where the judge said it is "well established that the Court may order alternative service by WhatsApp"). None of these makes the order automatic; each turned on the evidence.

What the court looks for in your evidence

PD 6A para 9.1 says the evidence must state (1) why the order is sought, (2) what method is proposed and (3) why you believe the document "is likely to reach the person to be served" that way. Para 9.3(2) gives the closest example: an application to serve by text message must show "appropriate steps to ensure that the party being served is using that telephone number and is likely to receive the message". The cases show what satisfies that test and what does not:

In AKO Capital the Facebook account belonged to the defendant and was "active and frequently accessed by him", after conventional methods of locating him had failed; in Blaney (2009) the Twitter account was "regularly accessed".
In Bunina v Nasibov (2026) a demand had already been sent to the Telegram handle and a screenshot showed "two green ticks, indicating receipt"; the defendant had used that handle about the very subject matter of the dispute.
In Chirkunov v Person(s) Unknown [2024] EWHC 3177 (KB) the court refused service by email to addresses published on the defendants' websites: publishing an address did not show anyone monitored it, earlier emails had gone unanswered, and such orders "are not granted as a reward for persistence".

The more recent the defendant's activity on the channel, and the more clearly it is tied to them personally, the stronger the application. A channel that has gone silent for months is much harder to rely on.

What to put in your witness statement

The N244 guidance says to state at question 3 what order you want and why, and at question 10 to attach a witness statement or set the evidence out on the form, ending with a statement of truth in the wording of PD 22 para 2.2. A checklist drawn from PD 6A paras 9.1 and 9.3 and the cases above:

Who the defendant is and how you know them: the agreement, when it was made, and that it was made in the app.
The identifier: the WhatsApp number, Facebook profile URL or numeric ID, or Instagram handle, and the display name.
Why that identifier is the defendant's: they used it to make the agreement; they sent bank details, photos or voice notes from it; the account shows their face, name or workplace.
That the channel is still in use: the date of their last message, ticks or read receipts on recent messages, recent public posts, with dated screenshots.
The steps you took to find a postal address and the result: asking the defendant, Companies House, directory sites, Land Registry, mutual contacts, any tracing agent report.
Why the proposed method is reasonably likely to reach them.
The order you ask for: permission to serve the claim form, particulars, response pack and the order as attachments by [WhatsApp to +44…] and, if you have one, by email; deemed service on the second business day after sending; 14 days after that to respond; and permission for you to serve.
A request that the application be decided without a hearing.

Keep the original device and export the chat as well as taking screenshots: see Evidence from messaging apps.

What the order must say, and following it exactly

CPR 6.15(4) requires the order to specify (a) the method or place of service, (b) the date on which the claim form is deemed served, and (c) the period for filing an acknowledgment of service, an admission or a defence. If the order does not deal with all three, consider asking the court to clarify before you serve.

Then follow it to the letter. In MBR Acres Ltd v McGivern [2022] EWHC 2072 (QB) the judge held that "the Court should require strict compliance with the terms of an alternative service order", and a failure to follow the order exactly was fatal. If it says send a PDF attachment to a specific number, do precisely that and keep a screenshot of the sent message, its ticks and the time. Send privately, by direct message, not as a public post. The claim form must be served within four months of issue (CPR 7.5(1)).

After service: the certificate of service and what comes next

Because you, not the court, are serving, CPR 6.17(2) applies: file a certificate of service on form N215 within 21 days of serving the particulars of claim; you "may not obtain judgment in default" until it is filed. For an alternative method the certificate gives the details "as required by the court", so mirror the order.

If the defendant does not respond within the period set by the order, you can request default judgment. If they reply, keep anything showing they have read the papers; in Pirtek (UK) Ltd v Jackson [2017] EWHC 2834 (QB) that was what proved receipt.

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Quick answers

Can I serve a county court claim by WhatsApp without asking the court?

Not unless the defendant has previously said in writing that they will accept service by that channel (PD 6A para 4.1). Otherwise you need an order under CPR 6.15 permitting service by that method. Barton v Wright Hassall [2018] UKSC 12 shows the courts apply this strictly, even to litigants in person.

Which form do I use and what does it cost?

A paper claim form N1 sent to the Civil National Business Centre in Northampton with the issue fee, plus an application notice N244 under CPR 6.15. The N244 fee is £126 when the application is made without notice (from 13 July 2026), or £321 on notice. Help with Fees can be claimed on both.

Can I use Online Civil Money Claims or Money Claim Online if I only have a phone number?

No. Both online services require a postal address in England or Wales for the defendant. The paper N1 route, with the claim form issued and retained by the court under PD 16 para 2.3 while the CPR 6.15 application is decided, is the route the rules provide.

What evidence do I need for the application?

Evidence that the number, profile or handle is the defendant's and is actively used: recent replies, read receipts or ticks, the fact that they used it to make the agreement, and screenshots showing dates and times. You also need to show what you did to find a postal address and why a message is likely to reach them (PD 6A paras 9.1 and 9.3(2)).

Will the court definitely make the order?

No. The order is discretionary and depends on the evidence. In Chirkunov v Persons Unknown [2024] EWHC 3177 (KB) the court refused because the channel was not shown to be monitored and earlier messages had gone unanswered. A live, recently used channel tied to the defendant personally is what the successful cases had in common.

What must the order contain?

Under CPR 6.15(4) it must specify the method or place of service, the date on which the claim form is deemed served, and the period for filing an acknowledgment of service, admission or defence. You then serve exactly as the order says and file a certificate of service on form N215 within 21 days.

Should I post the claim form on the defendant's Facebook page?

No. Send it privately by direct message in the way the order specifies. The courts have required care over personal data where a method of service is public, and a public post is not what a CPR 6.15 order for message service contemplates.