Parking Ticket Have Received a Claim Form

Parker123456

I will update now and thank you. Do I add just the 3 Appendix (A, B, C) or do I need to add anything for the promissory estoppel?

Le_Kirk

If you are using the New Defence Template written by Coupon-mad, I believe that the instructions were clear in her thread but NO, you just need to add Appendix C as the other two were included in the defence IF you got to it via the link below: -

https://forums.moneysavingexpert.com/discussion/6108153/suggested-template-defence-to-adapt-for-all-parking-charge-cases-where-they-add-false-admin-costs/p1
I believe there was also a link to a Dropbox file: -
https://www.dropbox.com/s/mmq8o078e8uhia9/Judgements Merged.pdf?dl=0
where all judgments had been merged into one .pdf

nosferatu1001

OP -= i was suggesting you add another defence point. 
You accepted the contractual licence from the landholder
You therefore had NO NEED to accept any further contract from the PPC. They had nothing to offer you. Without any possible offer - you already had a licence to park - they cannot possibly say there was a contract. Its a VERY basic part of contradct law. 
I literally meant for you to add another defence point. Your choice if you do or not. Does THIS make sense?

Parker123456

Thank you for your input nosferatu I have update point 17 and added an additional point 18 as below.

16.      The Defendant was the driver of the vehicle in question and on two separate occasions the claim relates, was an authorised patron of the onsite business. The claim relates to an alleged debt arising from the driver’s alleged breach of contract, which is denied. It is further denied that there was no agreement to pay the claimant a punitive £200 (£100 per PCN) ‘parking charge notice’.

17.      The Defendant had parked his car to attend the business based on site. Having had permission and being authorised by the landholder Bahar Properties to park on site (contractual licence), the landholder would ensure this was properly registered with the Claimant. This promise from the landholder forms a superior contract to that of the alleged contract offered by the agent of the landholder

 

18.      The Defendant having entered into the contractual licence from the landholder had no need to accept any further contract from the Claimant as the Defendant already had a licence to park

 

19.      The Defendant further relies on the doctrine of promissory estoppel, since the prior contract with the landholder which granted permission to park, the Claimant is bound by the same promise being an agent of the landholder    

 

Le_Kirk

16.      The Defendant was the driver of the vehicle in question and on two separate occasions the claim relates, was an authorised patron of the onsite business. The claim relates to an alleged debt arising from the driver’s alleged breach of contract, which is denied. It is further denied that there was no agreement to pay the claimant a punitive £200 (£100 per PCN) ‘parking charge notice’.

Maybe better like this: -

16.      The Defendant was the driver of the vehicle in question and, on the two separate occasions to which the claim relates, was an authorised patron of the onsite business. The claim relates to an alleged debt arising from the driver’s alleged breach of contract, which is denied. It is further denied that there was no any agreement to pay the claimant a punitive £200 (£100 per PCN) ‘parking charge notice’.

Coupon-mad

Make sure you add the new (longer) April 2020 statement of truth, as it is NOT the single line currently in the Template Defence.  I need to edit it.

Parker123456

Thank you all for your help 
New Statement of Truth added

Le_Kirk

Have you also made the changes that I posted at 9.28 am today or 2.20 pm today?

Parker123456

Hello Le_Kirk
Yes I certainly did it reads much better now thank you for your input. 

Coupon-mad

Looks good, nice work!  Be ready for the next stages and you are likely to win, especially if you can now get some solid evidence in the coming weeks ready for WS stage, to corroborate your position that your car was already authorised.