Euro Car Parks - DCB Legal LTD - Court Claim 2025

Coupon-mad

Merseyside1978 said:

Im not sure of what my defence would be , can you help on what i should be putting as my defence ? i know it hasnt got to be done right away but just not sure of what i would be putting in the document ? 

Please use the Template Defence you will have found linked in the NEWBIES thread.

Merseyside1978

Ive looked at the examples but can only see residential examples - mines is for parking at Morrisons so not sure where i would look for what i would put in for #2 and #3 .  

Gr1pr

Study the template defence,  you will be using all of it,  only amending paragraphs 2 & 3

Study other recent similar cases over the last 2 months, see what their couple of paragraphs said

Merseyside1978

where would i see similar cases - are they in the the stickys ? 

Gr1pr

No, you use the search function tools here with suitable keywords,  same as using Google or Bing or Duck duck go, filtering the results accordingly

Or

As this thread is on page 1, look at the threads for cases, then select page 2, rinse and repeat,  then page 3 , etc

The forum has dozens of them every month 

Merseyside1978

Would this do for paragraph 2 & 3 for No valid permit was purchased 

3. Referring to the POC: paragraph 1 is denied. The Defendant is not indebted to the Claimant. Paragraph 2 is denied. The Defendant does not accept that a contravention occurred on 01/10/2023, as alleged.  Whilst the Defendant is the registered keeper, paragraphs 3 and 4 are denied. The Defendant is not liable and has seen no evidence of a breach of prominent terms.  The quantum is hugely exaggerated (no PCN can be £170 on private land) and there were no damages incurred whatsoever.

3.1 Due to the length of time, the Defendant has no recollection of the day in question. The Defendant has parked in this car park many times while shopping in Morrisons .The User of the vehicle attempted to use the on site machinery to pay for a parking ticket but was unable to do so due to equipment malfunction. Upon realising they would not be able to pay, they left the car park. The signage provided at the car park entrance is barely legible from a moving vehicle upon entering, and the tiny signs setting out the terms of parking are completely unreadable unless standing directly in front of the aforementioned sign. See paragraph 24 for relevant remarks from ParkingEye vs Beavis regarding small signage and miniscule font."

Gr1pr

Those two are certainly a good start,  but you haven't posted your paragraph 2, with a suitable ending   ( see the template defence in the template defence thread   )

Merseyside1978

how about this 

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. Referring to the POC: paragraph 1 is denied. The Defendant is not indebted to the Claimant. Paragraph 2 is denied. The Defendant does not accept that a contravention occurred on 23/06/2020, as alleged.  Whilst the Defendant is the registered keeper, paragraphs 3 and 4 are denied. The Defendant is not liable and has seen no evidence of a breach of prominent terms.  The quantum is hugely exaggerated (no PCN can be £170 on private land) and there were no damages incurred whatsoever.

3.1 Due to the length of time, the Defendant has no recollection of the day in question. The Defendant has parked in this car park many times while shopping in Morrisons .The

User of the vehicle attempted to use the on site machinery to pay for a parking ticket but was unable to do so due to equipment malfunction. Upon realising they would not be able to pay, they left the car park. The signage provided at the car park entrance is barely legible from a moving vehicle upon entering, and the tiny signs setting out the terms of parking are completely unreadable unless standing directly in front of the aforementioned sign. See paragraph 24 for relevant remarks from ParkingEye vs Beavis regarding small signage and miniscule font."

Coupon-mad

Getting there ... but why in para 2 have you said you were driving, yet in 3 you've put:

"The User of the vehicle attempted to use the on site machinery to pay for a parking ticket but..."

1505grandad

Also  -  para 3  -  why is this date there?:-

"The Defendant does not accept that a contravention occurred on 23/06/2020, as alleged."