Having a PCN CCJ Set Aside and Defending

bohomark

OK, thanks.

I've been through their list of exhibits and there is no reference to proof of none-payment, in the exhibits, but I will go through the actual documents, to be sure. 

In paragraph 27 of the witness statement, they say that the new legislation, which we have referenced has been withdrawn. Is that true?

Coupon-mad

Of course.  As the Template Defence already explains.

bohomark

Other than the supplementary points which you made above, should I add anything else to my witness statement? For example, should I address any of the other points, which they made in their statement, or reemphasise any of the points which I made in my defence, included below, in case you have time to reread it.

IN THE COUNTY COURT

 

Claim No.: 

Between

ParkingEye Limited

(Claimant) 

- and -  

 (Defendant)

_________________

DEFENCE

 

1)    The Defendant denies that the Claimant is entitled to relief in the sum claimed, or at all.  It is denied that any conduct by the driver was in breach of any term.  Further, it is denied that this Claimant (understood to have a bare licence as agents) has standing to sue or form contracts in their own name. Liability is denied, whether or not the Claimant is claiming 'keeper liability', which is unclear from the boilerplate text in the Particulars of Claim ('the POC').

 

The facts as known to the Defendant:

 

2)    The facts in this defence come from the Defendant's own knowledge and honest belief.  Conversely, the Claimant sets out a cut-and-paste incoherent and sparse statement of case. The POC appear to be in breach of CPR 16.4, 16PD3 and 16PD7, and fail to "state all facts necessary for the purpose of formulating a complete cause of action". The Defendant is unable, on the basis of the POC, to understand with certainty what case, allegation(s) and what heads of cost are being pursued, making it difficult to respond. However, the vehicle is recognised, and it is admitted that the Defendant was the registered keeper and driver.

 

3)    On the morning of 12th August 2022, the Defendant had been working a night shift, in London, in his role as a Close Protection Operative. He was driving back to his home in Sheffield, when he realised that his fatigue was affecting his ability to drive. He pulled off the M1 motorway, at London Gateway Services, to rest. He pulled into a parking space at the services, and slept for what he thought was an hour or so. He then left the services and continued his journey.

 

4)    On entering the carpark, the Defendant did not see any signage specifying a time limit, parking charge or penalty, nor did he leave his vehicle to enter the service buildings, and was therefore totally unaware of any contractual obligation to do so. It is therefore rigorously denied that any contract ever existed between the Claimant and the Defendant.

 

5)    Furthermore, the Defendant had never paid for parking at motorway services in the past. In fact, to the contrary, he was under the now obviously mistaken impression that the main reason for having motorway services (or rest stop, as they are known in the US) was to provide a public service in the form of a location to rest. Fuel and other conveniences being sold to provide a revenue stream for the landowner. It never crossed his mind that there would be a charge to simply rest.

 

6)    The Claimant will concede that no financial loss has arisen and that in order to impose an inflated parking charge, as well as proving a term was breached, there must be:

 

a)     a strong 'legitimate interest' extending beyond mere compensation for loss, and

 

b)    'adequate notice' of the 'penalty clause' charge which, in the case of a car park, requires prominent signs and lines.

 

7)    The Defendant denies (a) or (b) have been met. The charge imposed, in all the circumstances is a penalty, not saved by ParkingEye Ltd v Beavis [2015] UKSC67 ('the Beavis case'), which is fully distinguished.

Exaggerated Claim and 'market failure' currently being addressed by UK Government

 

8)    The alleged 'core debt' from any parking charge cannot exceed £100 (the industry cap).  It is denied that any 'Debt Fees' or damages were actually paid or incurred.

 

9)    This claim is unfair and inflated and it is denied that any sum is due in debt or damages. This Claimant routinely pursues an unconscionable fixed sum added per PCN, despite knowing that the will of Parliament is to ban it.

 

 

10) This is a classic example where adding exaggerated fees funds bulk litigation of weak and/or archive parking cases. No checks and balances are likely to have been made to ensure facts, merit or a cause of action (given away by the woefully inadequate POC).

 

11) The Department for Levelling Up, Housing and Communities ('the DLUHC') published a statutory Parking Code of Practice in February 2022:

https://www.gov.uk/government/publications/private-parking-code-of-practice.

 

12) The Ministerial Foreword is damning: "Private firms issue roughly 22,000 parking tickets every day, often adopting a labyrinthine system of misleading and confusing signage, opaque appeals services, aggressive debt collection and unreasonable fees designed to extort money from motorists." 

 

13) Despite legal challenges delaying the Code (temporarily withdrawn) it is now 'live' after a draft Impact Assessment (IA) was published on 30th July 2023. The Government's analysis is found here:  https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1171438/Draft_IA_-_Private_Parking_Code_of_Practice_.pdf

 

14) Paragraphs 4.31 and 5.19 state that the parking industry has shown the DLUHC that the true minor cost of pre-action stage totals a mere £8.42 per case (not per PCN).

 

15) This claim has been enhanced by a disproportionate sum, believed to enrich the litigating legal team. It appears to be double recovery, duplicating the intended 'legal fees' cap set by small claims track rules.

 

16) The draft IA shows that the intimidating letter-chains endured by Defendants cost 'eight times less' than the  fixed +£70 per PCN. This causes immense consumer harm in the form of some half a million wrongly-enhanced CCJs each year, that Judges are powerless to prevent.  MoJ statistics reveal several hundred thousand parking claims per annum, with c90% causing default CCJs totalling hundreds of millions of pounds. The false fee was enabled by the self-serving Codes of Practice of the rival parking Trade Bodies who aligned in 2021 to allow +£70, each led by a Board comprising the parking and debt firms who stood to gain from it.

 

17) It is denied that the added damages/fee sought was incurred or is recoverable. Attention is drawn to paras 98, 100, 193, 198 of Beavis.  Also ParkingEye Ltd v Somerfield Stores Ltd ChD [2011] EWHC 4023(QB) where the parking charge was £75, discounted to £37.50 for prompt payment.  Whilst £75 was reasonable, HHJ Hegarty (decision ratified by the CoA) held in paras 419-428 that 'admin costs' inflating a PCN to £135 exaggerated the cost of template letters and 'would appear to be penal'.

 

 

18) This Claimant has not incurred costs. A PCN model already includes what the Supreme Court called an 'automated letter-chain' and it generates a healthy profit. In Beavis, there were 4 pre-action letters/reminders and £85 was held to more than cover the minor costs of the operation (NB: debt collectors charge nothing in failed collection cases).

 

19) Whilst the new Code is not retrospective, all non-monetary clauses went unchallenged. It will replace the self-serving BPA & IPC Codes, which are not regulation and carry limited weight.  It is surely a clear steer for the Courts that the DLUHC said in 2023 that it is addressing 'market failure'.

 

20) At last, the DLUHC's analysis overrides plainly wrong findings by Circuit Judges steered by Counsel in weak appeal cases that the parking industry steamrollered through. In Vehicle Control Services v Percy, HHJ Saffman took a diametrically opposed position to that taken by DJ Hickinbottom, DJ Jackson (as Her Honour Judge Jackson then was), and other District Judges on the North Eastern Circuit, including DJ Skalskyj-Reynolds and DJ Wright (Skipton) all of whom have consistently dismissed extortionate added 'fees/damages'. District Judges deal with private parking claims on a daily basis, whereas cases of this nature come before Circuit Judges infrequently. The Judgments of HHJ Parkes in Britannia v Semark-Jullien, and HHJ Simpkiss in One Parking Solution v Wilshaw were flawed. These supposedly persuasive judgments included a universal failure to consider the court's duty under s71 of the CRA 2015 and factual errors. In Wilshaw: a badly outdated reliance on 'ticket cases' which allowed poor signage to escape fair scrutiny and a wrong presumption that landowner authority 'is not required' (DVLA rules make it mandatory). In Percy, HHJ Saffman made an incorrect assumption about pre-action costs and even sought out the wrong Code of Practice of his own volition after the hearing, and used it to inform his judgment.

 

21) In addition, pursuant to Schedule 4 paragraph 4(5) of the Protection of Freedoms Act 2012 ('the POFA') the sum claimed exceeds the maximum potentially recoverable from a registered keeper. The Claimant is put to strict proof of POFA compliance if seeking 'keeper liability'.

 

22) 19. The Defendant avers that there was no agreement to pay a parking charge or added 'damages' which were not even incurred, let alone quantified in bold, prominent text. This Claimant's lack of large, readable signs are nothing like the yellow & black warnings seen in Beavis, nor do they meet the signage requirements in the DLUHC Code which reflects the already statutory requirement for 'prominence' (Consumer Rights Act 2015 - the 'CRA').

 

 

CRA breaches

 

23) Section 71 CRA creates a statutory duty upon Courts to consider the test of fairness whether a party raises it or not. Further, claiming costs on an indemnity basis is unfair, per the Unfair Contract Terms Guidance (CMA37, para 5.14.3):

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/450440/Unfair_Terms_Main_Guidance.pdf

 

24) The CRA introduced new requirements for 'prominence' of both terms and 'consumer notices'.  In a parking context, this includes a test of fairness and clarity of 'signs & lines' and all communications (written or otherwise). Signs must be prominent (lit in hours of darkness/dusk) and all terms must be unambiguous and contractual obligations clear.

 

25) The Defendant avers that the CRA has been breached due to unfair/unclear terms and notices, pursuant to s62 and paying regard to examples 6, 10, 14 & 18 of Schedule 2 and the duties of fair/open dealing and good faith (NB: this does not necessarily mean there has to be a finding of bad faith).  

 

 

ParkingEye v Beavis is distinguished

 

26) Unlike in Beavis, the penalty rule remains engaged. The CRA covers disproportionate sums, which are not exempt from being assessed for fairness because a 'fee' is not the core price term and neither was it prominently proclaimed on the signs.

 

27) The Supreme Court held that deterrence is likely to be penal if there is a lack of a 'legitimate interest' in performance extending beyond the prospect of compensation flowing directly from alleged breach.  The intention cannot be to punish a driver, nor to present them with hidden terms or cumbersome obligations ('concealed pitfalls or traps').  This Claimant has failed those tests, with sparsely placed, dilapidated, small signs that are faded beyond being legible, and with hidden terms and minuscule small print, clearly incapable of binding a driver. Court of Appeal authorities about a lack of ‘adequate notice’ of a parking charge include:

 

a)     Spurling v Bradshaw [1956] 1 WLR 461 (Lord Denning's ‘red hand rule’) and

b)    Thornton v Shoe Lane Parking Ltd [1970] EWCA Civ2,

 

both leading authorities that a clause cannot be incorporated after a contract has been concluded; and

c)     Vine v London Borough of Waltham Forest: CA 5 Apr 2000, where Ms Vine won because it was held that she had not seen the terms by which she would later be bound, due to "the absence of any notice on the wall opposite the parking space''. 

 

28) Fairness and clarity of terms and notices are paramount in the DLUHC Code, and these clauses are supported by the BPA & IPC. In the official publication 'Parking Review' the IPC's CEO observed: "Any regulation or instruction either has clarity or it doesn’t. If it’s clear to one person but not another, there is no clarity. The same is true for fairness. Something that is fair, by definition, has to be all-inclusive of all parties involved – it’s either fair or it isn’t." 

 

Lack of standing or landowner authority, and lack of ADR

 

29) DVLA data is only supplied if there is an agreement flowing from the landholder (ref: KADOE rules). It is not accepted that this Claimant (an agent of a principal) has authority to form contracts at this site in their name. The Claimant is put to strict proof of their standing to litigate.

 

30) The Claimant failed to offer a genuinely independent Alternative Dispute Resolution (ADR). The DLUHC Code shows that genuine disputes such as this should see PCNs cancelled, had a fair ADR existed. The rival Trade Bodies' time-limited and opaque 'appeals' services fail to properly consider facts or rules of law and reject most disputes: e.g. the IAS upheld appeals in a woeful 4% of decided cases (ref: Annual Report).  This consumer blame culture and reliance upon their own 'appeals service' (described by MPs as a kangaroo court and about to be replaced by the Government) should satisfy Judges that a fair appeal was never on offer.

 

 

Conclusion

 

31) There is now evidence to support the view - long held by many District Judges - that these are knowingly exaggerated claims that are causing consumer harm.  The July 2023 DLUHC IA analysis shows that the usual letter-chain costs eight times less than the sum claimed for it.  The claim is entirely without merit and the POC embarrassing.  The Defendant believes that it is in the public interest that poorly pleaded claims like this should be struck out.

 

32) In the matter of costs, the Defendant seeks:

a)     standard witness costs for attendance at Court, pursuant to CPR 27.14, and

b)    finding of unreasonable conduct by this Claimant, and further costs pursuant to CPR 46.5. 

 

33) Attention is drawn to the (often-seen) distinct possibility of an unreasonably late Notice of Discontinuance. Whilst CPR r.38.6 states that the Claimant is liable for the Defendant's costs after discontinuance (r.38.6(1)) this does not 'normally' apply to claims allocated to the small claims track (r.38.6(3)). However, the White Book states (annotation 38.6.1): "Note that the normal rule as to costs does not apply if a claimant in a case allocated to the small claims track serves a notice of discontinuance although it might be contended that costs should be awarded if a party has behaved unreasonably (r.27.14(2)(dg))."   

 

Statement of Truth

I believe that the facts stated in this defence are true.  I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth.

 

 

14 December 2023

1505grandad

A heads-up  -  per first post of Template Defence:-

"On your thread, please don't put up paragraphs 4 to the end for critique if you have chosen to use all of the template example here. We don't need to see that, only the parts where you have made the defence your own, as you must, because it is your document to draft."

Coupon-mad

bohomark said:

OK, thanks.

I've been through their list of exhibits and there is no reference to proof of none-payment, in the exhibits, but I will go through the actual documents, to be sure.

This surely scuppers the case re breach of contract.  A parking firm can't be heard to say:

"Look Judge, he didn't pay the £15 tariff" but provide zero evidence.

bohomark

Coupon-mad said:

bohomark said:

OK, thanks.

I've been through their list of exhibits and there is no reference to proof of none-payment, in the exhibits, but I will go through the actual documents, to be sure.

This surely scuppers the case re breach of contract.  A parking firm can't be heard to say:

"Look Judge, he didn't pay the £15 tariff" but provide zero evidence.

Please could I have some feedback on the following WS? Thanks.

Witness Statement by the Defendant, ****** ****************

12/03/2024

 

IN THE COUNTY COURT

 

Claim No.:  **********

Between

ParkingEye Limited

(Claimant) 

- and -  

****** ****************

 (Defendant)

 

Witness Statement of ****** ****************

 

I, ****** ****************, of ****** ****************, ****** ****************, am the Defendant in this matter. This is my supporting Statement to my Defence.

1.     On reading the Statement on Behalf of the Claimant, the Defendant stands by his original statement that the alleged infringement is vague and without merit. The Claimant has failed to provide even the most basic of evidence that the parking charge was even unpaid. Although the Defendant remained in the vehicle for the entirety of his stay at the London Gateway Services, it is entirely possible that his passenger, ****** ****************, entered the services, saw the signs, and paid the parking charge. ****** **************** cannot remember whether she did or not, due to her lack of sleep, and the time elapsed since. If the Defendant had seen these terms (which he didn't) they state that vehicles staying between 2 and 24 hours must pay a tariff of £15 or summate. The alleged breach is NOT like Beavis, in that it is not an overstay.  It is "not paying the tariff" which was the only "relevant obligation". It is therefore entirely the responsibility of the claimant to prove that the charge was not paid, as alleged. A statement by ****** ****************, is attached, marked Appendix B.

 

2.     Even if the charge had not been paid, the defendant refutes the Claimants statement that there are ample visible signs in and around the carpark. This statement is clearly shown to be untrue by the following evidence:

a.      A video, recorded by a friend of the Defendant, entering the carpark at the time of my original witness statement, attached to this email, and marked “Video A” clearly shows the route from the motorway to the space in which the Defendant parked. On this route there are no obvious sign, and whilst the Claimant, asserts that if the Defendant could read official road signs, it should be possible to read the Claimant’s signs, this video clearly shows that this is not the case.

b.     Photographs A, B, C, D and E (listed as Appendix A and attached to this document), taken by a friend, at the time of my original witness statement, of the car park, shows the purported contractual sign at the location. It is clear from the photographs that:

                                               i.     There are no legible signs between the entrance of the carpark and the parking space in which the Defendant parked (marked with a blue arrow).

                                              ii.     There are no signs which can be seen, let alone read, from this space.

                                            iii.     The nearest sign, pictured at the other end of the carpark, cannot be read from since it is faded to the degree that it is illegible from a distance and looks to be abandoned.

c.      Photograph F (listed in Appendix A and attached to this document), taken from Google Maps, shows the distance between the parking space and nearest sign (pictured in Photographs D and E). This is a distance of 30 meters or more.

d.     Although the Claimant had submitted maps showing the placing of signage around the carpark, it is apparent from the video and photographs that this signage is either neglected or missing altogether. It should also be noted that the Claimant has not taken into consideration the roadworks which were going on at the time. These roadworks caused a huge section of the carpark to be cordoned off, and many, if not all, the signs between the carpark and the motorway entrance to the services to be either obscured or removed. These roadworks, and the lack of signage can be seen in Photographs B and C, Appendix A.

 

3.     A recent persuasive appeal judgment (attached in Appendix C) in another private parking case: Civil Enforcement Limited v Chan (Ref. E7GM9W44).  This case confirms that where the POC fails to comply with Civil Procedure Rule 16.4 and the Practice direction to Part 16, the claim should be struck out, the CCJ set aside, and costs awarded to the Applicant/Defendant.  On the 15th August 2023, in the cited case, HHJ Murch held that 'the particulars of the claim as filed and served did not set out the 'conduct which amounted to the breach' in reliance upon which the claimant would be able to bring a claim for breach of contract'. The same is true in this case and in view of the Chan judgment, the Court should strike out the claim, using its powers pursuant to CPR 3.4 and award the Defendant costs in full, as happened in Chan appeal case (which also started with a N244 CCJ set aside application, which was initially wrongly refused by the first learned Judge).

 

4.     I believe that dismissing this meritless claim is the correct course, with the Overriding Objective in mind.  Bulk litigators (legal firms) should know better than to make little or no attempt to comply with the Practice Direction.  By continuing to plead cases with generic auto-fill unspecific wording, private parking firms should not be surprised when courts strike out their claims based in the above persuasive authority and award costs.

 

5.     I, ****** ****************, believe that the facts stated in this Witness Statement are true. I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth.

 

 

****** ****************

Date: 12/03/2024

----------

Coupon-mad

bohomark said:

That's quite a good start - but not enough.

Is the tariff actually £15 on the signs in their evidence? I was guessing.  Could be less?

You also need the other exhibits listed in the NEWBIES thread a-f exhibits list.  There are also five examples of WS bundles there to look at and copy from, all five times longer and more detailed than your draft statement.  So you do need to copy & adapt one of those.

Change 'the Defendant' to 'I' because (unlike the defence) a witness statement is your story.

This made me giggle: do you know what I meant by the slang phrase '£15 or summat'?! Google 'summat'!  Do not use that word here:

" must pay a tariff of £15 or summat "

  


I think your WS should start with your account of what happened:

1.  I am xxxxxxxxx xxxxxxx of xx xxxxxx xxxxx  (UK family address) and I am the defendant against whom this claim is made. The facts below are true to the best of my belief and my account has been prepared based upon my own knowledge.  This is my second witness statement, the first having been provided to support my CCJ set aside application, which was granted.

2.   This statement is provided as my witness account of events relating to the parking event, and is provided to support my defence now that the case has moved on and the CCJ was wiped.  I shall refer to numbered exhibits within this statement. My defence is repeated and I will say as follows: 

3.  I work in Close Protection and as such often work long and unusual hours. After working all night I attempted to drive back to base, in Yorkshire, from London, with a passenger whose own witness statement is appended separately to assist the court to narrow the issues and understand what happened from the only two eye-witnesses involved in this claim.

3.  By the time we reached London Gateway Services, on the M1, I realised that that I was too tired to complete the journey in one go, so I pulled off, parked and went to sleep in the driver’s seat of my vehicle. I thought I had merely slept for a couple of hours but I was unconcerned about the time, having no reason to think this was not OK.  My passenger slept for part of the time.

4.  I was shocked when at the family home the following month, I opened a 'PCN' letter from ParkingEye (whom I had no recollection of 'contracting' with) demanding £100.  This was a letter with grainy photos of the car that bore all the hallmarks of a scam demand.  This PCN did not really explain what I was supposed to have done wrong (I now see that it had a generic 'reason' hidden in small-print at the top of the back page). I was not provided with a copy of the supposed 'contract' so I had no idea what the unseen sign might have said.

5.  I certainly did not agree to pay £100 to rest at Services.  Nor did I agree to pay another unknown entity, DCB Legal, a disproportionate rip-off £70 on top of that £100 for a 'service' provided by them to ParkingEye. A dubious service that the Claimant does not actually incur or ever pay for, and does not set out on their signage (based on images of ParkingEye signs I have researched for this case).

6.  Reading the so-called PCN I could see it was not from any statutory authority and I was furious that the minimum tariff to 'rest' for a few hours was £100. I could have had a room in the Travel Lodge for less than that!  In fact, the PCN did not ask for a tariff of £15 nor was that sum even mentioned.  It demanded £100 and made out that I had overstayed, even though that is not the way the Claimant's witness statement now phrases the alleged breach.

7.  In 33 years of driving, I've never been required to pay to park in a Motorway Services before so signs would have had to have been very prominent to alert tired drivers to that risk. Also, I don't live at my UK mailing address. It is my parents’ house and I'm sometimes based there when working in the UK, so on occasion, I get mail late if I haven't been there for a few weeks or months. My parents are both over 80 now, and can be a bit scatty, so I don't have them open the post and there has never been reason to do so, in the past.  I do not recall seeing a letter before claim and certainly not the claim form, hence the CCJ was set aside.

8.  I think the Judge should be made aware of a similar facts Motorway Services claim where ParkingEye failed against Nicolas Bowen KC (reported widely):
https://amp.theguardian.com/money/2017/aug/26/parking-eye-takes-on-top-barrister-85-fine

8.1.  My case is very similar indeed; to quote some of the article which is clearly not hearsay and well-known to ParkingEye who no doubt hold the transcript, if the court requires it:

8.1.1. "Exhausted and in need of a rest while driving from Hereford back home to London in May 2016, barrister Mr Bowen had pulled into Welcome Break’s Membury services on the M4, intending to have a short nap. But Bowen, who insists that where he parked there was no signage setting out any parking information, had exceeded the two-hour free period.  He claimed he was so tired when he drove in that he didn’t notice the signs that were there, and subsequently discovered (and says he has photos to prove it) that “the only reference to 24/7 charging was in microscopic print in a different part of the car park requiring 20/20 vision or a magnifying glass”.

8.1.2.  Mr Bowen stated: "My defence was that your contract was unenforceable, and that you have no legal right to charge members of the public for night parking in service station car parks. Charging overstayers at night is unfair and a violation of consumer protection law. I defended your misconceived claim on a public interest basis, as it would have been far easier just to pay the ticket."  The KC went further, telling ParkingEye that he was demanding the immediate payment of the costs for the work preparing his eight-page defence. He accused it of “indulging in pernicious bullying tactics against motorists” and claimed it was relying “either on apathy, or that most of your victims lack the ability or funds to fight back”. He added: “I hope ParkingEye will learn a lesson from losing this case, reconsider your contractual terms and change what is an unlawful and unconscionable practice.”

9.  On reading the Statement from the Claimant, my case is clearly almost identical to that of Nicolas Bowen KC and I stand by my original statement that ...

...continue with your exhibits/video etc...

...then add the stuff about the DLUHC and the added £70 that you see as standard in the exemplar WS linked in the NEWBIES THREAD.

Coupon-mad

Please show us the signs they've included.

bohomark

@Coupon-mad, thank you for all the above. It's a great help. I'm going to work on it now. In the meantime, I thought it may be worth mentioning that I got a call today from someone claiming to be from a mediation centre. I suspect that they were affiliated with Parkingeye. They asked if I would like mediation and I said that I had refused mediation, which they ought to know. However, I said, in the spirit of reconciliation, I would offer to pay the missed tariff of £15, and not a penny more. If the Claimant chose to reject my offer, I would ask the court for costs, when they found in my favour. The so-called mediator said that I could not claim costs in the Small Claims Court. I told him I thought he was mistaken. They rejected my offer and came back with a ridiculous offer of £160 paid over four months. I said I would see them in court.

bohomark

Coupon-mad said:

Please show us the signs they've included.

These are just examples. They included a lot of them, but no reference to where the signs are located, or if they were even visible from where I was parked.