Two PCNs paid for by leasing company + defending claim against G24 for 3rd PCN due to keying error

travellover123

Thanks both @Coupon-mad @Car1980.

Can I paste the following into MCOL? It fits with 19 lines remaining:

1. The Claimant’s sparse case lacks specificity and does not comply with CPR 16.4, 16PD3 or 16PD7, failing to 'state all facts necessary for the purpose of formulating a complete cause of action'. The added costs/damages are an attempt at double recovery of capped legal fees (already listed in the claim) and are not monies genuinely owed to, or incurred by, this Claimant. The claim also exceeds the Code of Practice (CoP) £100 parking charge ('PC') maximum. Exaggerated claims for impermissible sums are good reason for the court to intervene. Whilst the Defendant reserves the right to amend the defence if details of the contract are provided, the court is invited to strike out the claim using its powers under CPR 3.4.

2. The allegation(s) and heads of cost are vague and liability is denied for the sum claimed, or at all. At the very least, interest should be disallowed; the delay in bringing proceedings lies with the Claimant. This also makes retrieving material documents/evidence difficult, which is highly prejudicial. The Defendant seeks fixed costs (CPR 27.14) and a finding of unreasonable conduct and further costs (CPR 46.5). The Defendant admits to being the lessee and driver of the vehicle but denies that any parking charge is owed.

3. On the material date, the Defendant parked at X shopping centre, where parking is advertised as free for Asda shoppers who register their vehicle details. The Defendant entered the vehicle registration number into the parking system inside the store. Unfortunately, due to a minor keying error, the registration was entered as “AA11ACB” instead of the correct “AA11ABC”. This was a genuine and trivial mistake, falling squarely within the definition of a “minor keying error” as set out in Annex F.1 of the Joint BPA & IPC Code of Practice (the Government-mandated Code). The Code requires that charges must not be pursued where only a minor keying error has occurred.

3.1 The Claimant was in possession of accurate ANPR data showing the Defendant’s vehicle entering and leaving within the permitted free parking period (120 minutes, the Defendant left after 116 minutes). The Claimant therefore suffered no financial loss and cannot reasonably claim that the Defendant failed to pay any tariff.

4. It is neither admitted nor denied that a term was breached but to form a contract, there must be an offer, acceptance, and valuable consideration (absent in this case). The Consumer Rights Act 2015 (s71) mandates a 'test of fairness' duty on Courts and sets a high bar for prominence of terms and 'consumer notices'. Paying regard to Sch2 (examples 6, 10, 14 & 18), also s62 and the duties of fair, open dealing/good faith, the Defendant notes that this Claimant reportedly uses unclear (unfair) terms/notices. On the limited information given, this case looks no different. The Claimant is put to strict proof with contemporaneous photographs.

5. DVLA keeper data is only supplied on the basis of prior written landowner authority. The Claimant (an agent) is put to strict proof of their standing to sue and the terms, scope and dates of the landowner agreement, including the contract, updates, schedules and a map of the site boundary set by the landowner (not an unverified Google Maps aerial view).

6. To impose a PC, as well as a breach, there must be: (i) a strong 'legitimate interest' extending beyond compensation for loss, and (ii) 'adequate notice' (prominence) of the PC and any relevant obligation(s). None of which have been demonstrated. This PC is a penalty arising as a result of a 'concealed pitfall or trap', poor signs and covert surveillance, thus it is fully distinguished from ParkingEye v Beavis [2015] UKSC67.

7. Attention is drawn to (i) paras 98, 100, 193, 198 of  Beavis (an £85 PC comfortably covered all letter chain costs and generated a profit shared with the landowner) and also to (ii) the binding judgment in ParkingEye v Somerfield Stores ChD [2011] EWHC 4023(QB) which remains unaffected by Beavis and stands as the only parking case law that deals with costs abuse. HHJ Hegarty held in paras 419-428 (High Court, later ratified by the CoA) that 'admin costs' inflating a £100 PC (already increased from £60) to £183.36 were disproportionate to the minor cost of an automated letter-chain and 'would appear to be penal'.

8. The Parking (Code of Practice) Act will curb rogue conduct by operators and their debt recovery agents (DRAs). The Government recently launched a Public Consultation considered likely to bring in a ban on DRA fees, which a 2022 Minister called ‘extorting money from motorists’. They have identified in July 2025: 'profit being made by DRAs is significantly higher than ... by parking operators' and 'the high profits may be indicative of these firms having too much control over the market, thereby indicating that there is a market failure'.

9. Pursuant to Sch4 of the Protection of Freedoms Act 2012 ('POFA') the claim exceeds the maximum sum and is unrecoverable: see Explanatory Note 221: 'The creditor may not make a claim against the keeper ... for more than the amount of the unpaid parking related charges as they stood when the notice to the driver was issued (para 4(5))'. Late fees (unknown to drivers, not specified on signs) are not 'unpaid parking related charges'. They are the invention of 'no win no fee' DRAs. Even in the (unlikely) event that the Claimant complied with the POFA and CoP, there is no keeper liability law for DRA fees.

10. This claim is an utter waste of court resources and it is an indication of systemic abuse that parking cases now make up a third of all small claims. False fees fuel bulk litigation that has overburdened HMCTS. The most common outcome of defended cases is late discontinuance, making Claimants liable for costs (r.38.6(1)). Whilst this does not 'normally' apply to the small claims track (r.38.6(3)) the White Book has this annotation: '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))'.

travellover123

Coupon-mad said:

I would add how you found out about that. You must have found out from G24, but they still carried on to sue you?! It's an abuse of court.

no unfortunately this was just stupidity on my part, I realised afterwards that I was entering the registration incorrectly and that's what led to the 3 PCNs

when I originally appealed with the minor keying error defence they replied saying: 
“We have reviewed the authorised list for typing errors on your registration and can confirm your registration and no entries close to your registration was made on the day in question.”

Coupon-mad

travellover123 said:

Coupon-mad said:

I would add how you found out about that. You must have found out from G24, but they still carried on to sue you?! It's an abuse of court.

no unfortunately this was just stupidity on my part, I realised afterwards that I was entering the registration incorrectly and that's what led to the 3 PCNs

when I originally appealed with the minor keying error defence they replied saying: 
“We have reviewed the authorised list for typing errors on your registration and can confirm your registration and no entries close to your registration was made on the day in question.”

So you are saying they lied when you appealed.

Add that to your defence and show your evidence of this farce of an appeal to the MHCLG.

And just a reminder even though this is stressful: once your defence is submitted please please do the government's Public Consultation by next week at the latest.

We need every poster to come back & complete this vital Consultation before the deadline.

See this thread: -

https://forums.moneysavingexpert.com/discussion/6617396/parking-code-of-practice-consultation-8-weeks-from-11th-july-2025/p1

We understand that you may need some pointers. It looks laborious, we get that. It doesn't matter; no knowledge is needed except re your own experiences so you can call out a scam industry and you'll protect millions of motorists and help change the law.

I've written some guidance on that thread. I have covered almost every question, providing ideas if you agree with our stance on things like DRFs, which we say must be banned. You also have your evidence that (you say) G24 lied about looking for a keying error. 

Ordinary people like you are falling victim to this scam 15 million times per annum. Motorists need your voice added please.

travellover123

Coupon-mad said:

So they lied when you appealed.

Add that to your defence and show your evidence of this farce of an appeal to the MHCLG.

Is this okay:

3. On the material date, the Defendant parked at X Shopping Centre, where parking is advertised as free for shoppers who register their vehicle details. The Defendant entered the vehicle registration number into the parking system inside the store. Unfortunately, due to a minor keying error, the registration was entered as “AA11ACB” instead of the correct “AA11ABC”. This was a genuine and trivial mistake, falling within the definition of a ‘minor keying error’ in Annex F.1 of the BPA & IPC Code of Practice. In such cases, the Code is clear that a charge must not be pursued.

3.1 When the Defendant appealed to the Claimant (G24), they explained that a minor keying error had occurred and requested cancellation of the charge in line with the mandatory Code of Practice. However, the Claimant rejected the appeal stating: “We have reviewed the authorised list for typing errors on your registration and can confirm your registration and no entries close to your registration was made on the day in question.” This was false, as the Defendant had in fact made an entry that was almost identical to the correct registration, save for two transposed characters. The Defendant then requested a partially redacted VRM entry log from that day (with unmatched entries visible) in order to evidence the error. The Claimant refused, replying that the appeal period had expired and that “any further correspondence may not receive a response.” This obstructive and misleading conduct amounts to unreasonable behaviour, contrary to the applicable Code of Practice and the duty of open dealing expected under the Consumer Rights Act 2015.

travellover123

Coupon-mad said:

And just a reminder even though this is stressful: once your defence is submitted please please do the government's Public Consultation by next week at the latest.

I definitely will do once i've submitted my defence! It closes on 5th September right?

Coupon-mad

travellover123 said:

Coupon-mad said:

And just a reminder even though this is stressful: once your defence is submitted please please do the government's Public Consultation by next week at the latest.

I definitely will do once i've submitted my defence! It closes on 5th September right?

Yes. Takes a couple of hours though, even with the ideas and tips in the thread.

That defence is great. Really strong.

Complete waste of your time because these cases all get discontinued by DCB Legal who are running them (the evidence suggests) with no reference to the Claimants.

This offends against public policy.

We also have evidence that bulk legals front the claim filing fees in exchange for a share of the artificially inflated £70, which is a conflict of interests for supposed officers of the court.

BTW had you considered a counterclaim for the two PCNs paid by your lease company? Now is your chance. You can do a £300 counterclaim for just a £35 fee. Even higher for a £50 punt. Needs pleading properly but why not think about it? You have to do it with the defence.

If these were all minor keying error PCNs then G24 should never have even obtained the DVLA data to send a notice to the lease firm and if you appealed them all then G24 were legally wrong to continue to send notices to the keeper. This caused you loss and distress.

= both are grounds for a counterclaim.

travellover123

Coupon-mad said:

Yes. Takes a couple of hours though, even with the ideas and tips in the thread.

No worries, happy to do it!

Ooh no I hadn't considered a counterclaim, am I able to since it was the lease company who actually paid it? Wouldn't they be the ones entitled to the money?

Coupon-mad

travellover123 said:

Coupon-mad said:

Yes. Takes a couple of hours though, even with the ideas and tips in the thread.

No worries, happy to do it!

Ooh no I hadn't considered a counterclaim, am I able to since it was the lease company who actually paid it? Wouldn't they be the ones entitled to the money?

No because that loss was then passed to you and remains a potential loss you are fighting (unless the lease firm cancelled their demands that you pay those two?).

If you are still living with that threat/loss, then this is an example of a Part 20 counterclaim:

https://forums.moneysavingexpert.com/discussion/comment/81613596/#Comment_81613596

In your case, if you are certain these were all single digit keying errors, you could argue that they should never have issued any PCNs and at all material times should have matched the payments, either using standard 'fuzzy whitelist' software that comes with PCN processing systems, or by mandatory human checks of AI data to prevent spurious PCNs. You could rely on Ferguson v British Gas (unjustified debt harassment) in breach of the PFHA.

Coupon-mad

Remind me again: how are you sure these are all just minor keying errors? Given they denied that on appeal, how can you be certain?

travellover123

Coupon-mad said:

No because that loss was then passed to you and remains a potential loss you are fighting (unless the lease firm cancelled their demands that you pay those two?).

So the lease firm had originally charged me for those two PCNs via direct debit but refunded me after a lot of back and forth (thanks to all the help I received from everyone in this thread) so I'm not at a financial loss anymore.