Received a claim form for parking at work parking space

always_ontime

Hello everyone.
Now I have received a court date for December. I went through the court papers and have two question, any idea will be highly appreciated.

1- on the court order it says:"  Each party must deliver to the other party and to the court office copies of all documents on which that party intends to rely at the hearing no later than fourteen days before the hearing". I have got nothing except for my parking permit. Do I need to send it to them?

2- It also mentions "witness statement", should I write one and send to the Gladstones and court?

Thanks for all your kind replies.

Gr1pr

1) read a few recent Witness Statement plus Exhibits bundle posts on here,  because you will be adding other exhibits as well as a copy of your parking permit etc

2) yes, definitely,  so study those other recent cases,  see what they wrote and submitted

Coupon-mad

always_ontime said:

Hello everyone.
Now I have received a court date for December. I went through the court papers and have two question, any idea will be highly appreciated.

1- on the court order it says:"  Each party must deliver to the other party and to the court office copies of all documents on which that party intends to rely at the hearing no later than fourteen days before the hearing". I have got nothing except for my parking permit. Do I need to send it to them?

2- It also mentions "witness statement", should I write one and send to the Gladstones and court?

Thanks for all your kind replies.

This stage is already fully explained in the NEWBIES thread post 2.

always_ontime

Hi
Thanks for your considerations. As I have explained before I went through the IAS and was rejected but what I received from them was a template decision with lots of spelling mistakes and wrong registration numbers (uploaded the photos before), I want to highlight this in my WS to the court. What is the best way to write? It is Gladstones solicitors which I read a lot about them here, anything useful to mention about them?

Thanks 

Coupon-mad

always_ontime said:

Coupon-mad said:

always_ontime said:

Coupon-mad said:

They offered IAS and I accepted (it was wrong, but I didn’t know at the time). The refusal email I received from IAS was full of spelling mistakes and the registration numbers mentioned was not even mine! So I asked for an independent service which was ignored.

Please could you show us that (minus the VRMs)

It is a very long email. I guess they sent it by mistake to me (anyway I don't know the purpose of this email or why it was written) but I will post some parts here tonight.

No the whole thing please, with headers/dates (but cover full email addresses, part of the VRMs they wrongly quoted, and cover your data).

I want to show is as evidence to the Government.  The whole response please.

As it is a long one I'll share a link here I hope you can find it. Please let me know.
https://www.dropbox.com/scl/fo/rjz7a3hio3t2lfwwyx7ls/APBnrK5QrTlXsrAwS1X2phQ?rlkey=he94y0kry42fr8prbcs2dsdum&st=aunlanfp&dl=0

Ah yes, the one with the apparently drunk IAS Assessor ordering Majestic Wine.

You need to exhibit it!

Copy & paste the entire thing into a word doc in the right order, then save it as a PDF and compress it. That'll be one of your exhibits as well as anything related to your case (signage photos placed alongside the Beavis sign) and the usual Beavis paragraphs seen in the exhibits list in post 2 of the NEWBIES thread.

Plus links to transcripts of:

- Chan
- Akande
- Mazur (if Gladstones send a WS from a paralegal, not a solicitor).

always_ontime

Hi. I have prepared the following WS. I would highly appreciate any ideas. Do I need to add/remove/change anything?

1. I am the Defendant in this matter and the permit holder for the designated workplace parking area at...... I continue to hold a valid permit issued by NPM.

 2. On the date in question, my vehicle registration number ......... was parked in the correct permit holder bay at my place of work.

 3. The permit was valid and active at the time (see Exhibit A). However, it had inadvertently fallen from its usual display position on the dashboard and was not visible to the enforcement officer.

 4. Upon discovering the issue, I immediately repositioned the permit and have since taken steps to ensure it remains securely displayed (see Exhibit .

 5. I made every reasonable effort to resolve this matter directly with the Claimant. I submitted evidence of my valid permit and explained the circumstances clearly. They refused to accept my explanation and continued to pursue enforcement. I also contacted the landlord of the site by email to request assistance, given that my permit was valid and the parking space was allocated through my workplace. Unfortunately, the landlord did not intervene or assist, and the Claimant continued enforcement (see Exhibit C).

 6. I had a scheduled appointment with the Small Claims Mediation Service. The mediator attempted to contact the Claimant, but they failed to answer and gave no explanation. The mediator confirmed this would be noted and reported to the Court (see Exhibit D). This obstructed a reasonable opportunity to resolve the matter. In Halsey v Milton Keynes NHS Trust [2004] EWCA Civ 576, the Court held that refusal to mediate may justify a costs sanction. I respectfully seek costs under CPR 27.14(2)(g).

 7. The Claimant’s conduct appears to prioritise revenue generation over fair enforcement. Penalising a minor and unintentional error — despite clear evidence of entitlement to park — is disproportionate and unreasonable.

 8. As a teacher working in adult education, my time is dedicated to supporting learners and preparing lessons. The hours I’ve spent preparing appeals, gathering evidence, and responding to this claim — all due to the Claimant’s refusal to resolve the matter informally — have come at the expense of my students. This is a misuse of public time and resources.

 9. I believe the claim is without merit and amounts to an abuse of process. The Claimant has failed to engage with reasonable dispute resolution, disregarded valid evidence, and pursued litigation over a matter that could and should have been resolved informally.

 10. I am attaching a copy of my valid permit (Exhibit A) and a photograph showing the permit correctly displayed after I repositioned it (Exhibit to demonstrate my eligibility and good faith.

 11. I respectfully request that the Court strike out the claim pursuant to CPR 3.4(2)(a) and/or (b), on the basis that it discloses no reasonable grounds for bringing the claim and constitutes an abuse of the Court’s process. In Civil Enforcement Limited v Chan (Ref. E7GM9W44), HHJ Murch held on 15 August 2023 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.”

 This persuasive appeal judgment confirms that failure to comply with CPR 16.4 and Practice Direction 16 renders the claim defective. The same deficiency applies in this case: the Claimant’s particulars fail to identify the specific conduct alleged to constitute breach.

 12. I submitted an appeal to the Independent Appeals Service (IAS), but the decision I received raises serious concerns about the integrity of their review process. The adjudicator’s email contained multiple spelling errors, referenced two vehicle registration numbers that do not belong to me, and included irrelevant content about payment systems and Blue Badge holders — none of which apply to my case. The reasoning appeared contradictory and templated, with generic phrases that misrepresented the facts. These issues suggest that the appeal was not properly considered and that the IAS may rely on standardised responses rather than individual assessment. I attach the full decision email as Exhibit E.

 13. Given the Claimant’s refusal to engage in mediation and the disproportionate nature of this claim, I respectfully request costs for time and expenses incurred in preparing this defence and attending the hearing:

 •               (a) Standard witness costs under CPR 27.14(2)(a);

•               (b) Further costs under CPR 27.14(2)(g) and CPR 46.5, due to the Claimant’s unreasonable conduct.

 

Coupon-mad

A good start but you haven't challenged landowner authority (if you used the template defence then you did raise it then so you need to include it here too) and you're missing all the usual exhibits listed in detail, in post 2 of the NEWBIES thread.

You are also missing the usual name and address intro and you have no Statement of Truth.

Your WS has Chan but not Akande so I think you copied an old one. Newer ones include:

aza123 which has Chan & Akande

mtrolley123 has Mazur and is a good WS with sub headings for clarity.

Have you had Gladstones WS yet?

always_ontime

Thanks Coupon-mad,
This is the body of the WS, the original one comes with name and address intro and statement of Truth. I will read the ones you have mentioned and try to add them in my WS. I haven't received Gladstones WS yet. Regarding the land owner authority, I have exhibited my email to him, Do I need to add something else?
Anyway I will read more WSs and come back here. 

Coupon-mad

In a WS you should say you've seen no evidence of landowner authority.

always_ontime

Hi,
I have reviewed the WS and integrated Akande & Mazure and challenged landowner authority in a separate paragraph. I would appreciate any feedback. The other question I have is that: Is it okay if I write Exhibit A,B,..... by pen on the relevant page or it should be printed?

Thanks a lot.

In the County Court at ...........

Claim Number: ....................

Between:..................

And ..............................

 Witness Statement of .....................

 I am a litigant in person with no formal legal training. I have done my best to present my case and evidence clearly, truthfully, and in good faith. I respectfully ask the Court to take this into account when considering my submissions. My defence is repeated below, and I will say as follows:

 1. I am the Defendant in this matter and the permit holder for the workplace parking area at ............ I continue to hold a valid permit issued by NPM.

 2. On the date in question, my vehicle (registration number ........) was parked in the correct permit holder bay at my place of work.

 3. The permit was valid and active at the time (see Exhibit A). However, it had inadvertently fallen from its usual display position on the dashboard and was not visible to the enforcement officer.

 4. Upon discovering the issue, I immediately repositioned the permit and have since taken steps to ensure it remains securely displayed (see Exhibit .

 5. I made every reasonable effort to resolve this matter directly with the Claimant. I submitted evidence of my valid permit and explained the circumstances clearly. They refused to accept my explanation and continued to pursue enforcement. I also contacted the landlord of the site by email to request assistance, given that my permit was valid and the parking space was allocated through my workplace. Unfortunately, the landlord did not intervene or assist, and the Claimant continued enforcement (see Exhibit C).

6. I had a scheduled appointment with the Small Claims Mediation Service. The mediator attempted to contact the Claimant, but they failed to answer and gave no explanation. The mediator confirmed this would be noted and reported to the Court (see Exhibit D). This obstructed a reasonable opportunity to resolve the matter. In Halsey v Milton Keynes NHS Trust [2004] EWCA Civ 576, the Court held that refusal to mediate may justify a costs sanction. I respectfully seek costs under CPR 27.14(2)(g).

7. The Claimant’s conduct appears to prioritise revenue generation over fair enforcement. Penalising a minor and unintentional error — despite clear evidence of entitlement to park — is disproportionate and unreasonable.

 8. As a teacher working in adult education, my time is dedicated to supporting learners and preparing lessons. The hours I’ve spent preparing appeals, gathering evidence, and responding to this claim — all due to the Claimant’s refusal to resolve the matter informally — have come at the expense of my students. This is a misuse of public time and resources.

9. I believe the claim is without merit and amounts to an abuse of process. The Claimant has failed to engage with reasonable dispute resolution, disregarded valid evidence, and pursued litigation over a matter that could and should have been resolved informally.

10. I am attaching a copy of my valid permit (Exhibit A) and a photograph showing the permit correctly displayed after I repositioned it (Exhibit to demonstrate my eligibility and good faith (using double sided tape).

11. I respectfully request that the Court strike out the claim pursuant to CPR 3.4(2)(a) and/or (b), on the basis that it discloses no reasonable grounds and constitutes an abuse of process. The Claimant’s Particulars of Claim fail to identify the specific conduct alleged to constitute breach, contrary to CPR 16.4 and Practice Direction 16. This deficiency was confirmed in Civil Enforcement Ltd v Chan (Ref. E7GM9W44), where HHJ Murch held that the particulars “did not set out the conduct which amounted to the breach.” A second persuasive judgment in Car Park Management Service Ltd v Akande (Ref. K0DP5J30) reinforces this position: on 10 May 2024, HHJ Evans held that “Particulars of Claim have to set out the basic facts upon which a party relies in order to prove his or her claim.” These judgments confirm that vague or generic particulars — like those served in this case — render the claim defective.

12. I submitted an appeal to the Independent Appeals Service (IAS), but the decision I received raises serious concerns about the integrity of their review process. The adjudicator’s email contained multiple spelling errors, referenced two vehicle registration numbers that do not belong to me, and included irrelevant content about payment systems and Blue Badge holders — none of which apply to my case. The reasoning appeared contradictory and templated, with generic phrases that misrepresented the facts. These issues suggest that the appeal was not properly considered and that the IAS may rely on standardised responses rather than individual assessment. I attach the full decision email as Exhibit E.

13. Given the Claimant’s refusal to engage in mediation and the disproportionate nature of this claim, I respectfully request costs for time and expenses incurred in preparing this defence and attending the hearing:

•               (a) Standard witness costs under CPR 27.14(2)(a);

•               (b) Further costs under CPR 27.14(2)(g) and CPR 46.5, due to the Claimant’s               unreasonable conduct.

A full breakdown of my time and expenses is provided in Exhibit F – Cost Schedule.

14. Prior to Gladstones Solicitors’ involvement, the Claimant’s debt recovery agent sent letters threatening legal action. I understand that only authorised persons may conduct litigation under the Legal Services Act 2007. In Mazur v Charles Russell Speechlys LLP [2025] EWHC 2341 (KB), the High Court confirmed that litigation must be conducted by individuals with proper legal authority — supervision alone is insufficient. I respectfully submit that these threats were unlawful and constitute an abuse of process under CPR 3.4. Copies of the exchanged emails are attached as Exhibit G.

15. DVLA keeper data is only released to parking operators with written landowner authority. The Claimant is not the landowner and is put to strict proof of their right to issue charges and bring proceedings. I request disclosure of the full landowner agreement, including the contract, scope, dates, and a site boundary map issued by the landowner (not a generic aerial image).

Statement of Truth

I believe that the facts stated in this witness statement are true.

Signed: ____________________

Date: ____________________