Received a claim form for parking at work parking space

Gr1pr

You use your initials and a number for the exhibits references,  so ABC01, ABC02 etc

That statement at the end is much too short and was retired 4 or 5 years ago,  so check newer WS examples. Your court order may have the correct statement of truth on it, typically 2 or 3 lines

always_ontime

Thanks Gr1pr. So exhibits would look like this, See Exhibit NH01, See Exhibit NH02 and so on?

Regarding the statement, is this one good?

Statement of Truth

I confirm that the facts set out in this witness statement are true to the best of my knowledge and belief. I am aware that making, or causing to be made, a false statement in a document verified by a statement of truth without an honest belief in its accuracy may result in proceedings for contempt of court.

Signed: ____________________

Date: ____________________

Thanks a lot.

Gr1pr

Yes to both queries  ( I nearly fainted when I saw the old SoT in your WS draft  )

always_ontime

Gr1pr said:

Yes to both queries  ( I nearly fainted when I saw the old SoT in your WS draft  )

  newbie here!  

Coupon-mad

always_ontime said:

Gr1pr said:

Yes to both queries  ( I nearly fainted when I saw the old SoT in your WS draft  )

  newbie here!  

maxim024 and aza123 are posters with recent good WS on their threads.

always_ontime

Hi everyone
I have received the WS from Gladstones. I am posting it here for any ideas that I can use at the court.
Thanks

always_ontime

I, Elise Davies of Gladstones Solicitors Limited, Unit B, 210, Cygnet Court, Centre Park, Warrington WA1 1PP, will say as follows:

INTRODUCTION
 1. I am a Solicitor in the employment of Gladstones Solicitors Limited, who act for the Claimant in this matter. I have conduct of this action. The matters to which I refer within this witness statement are within my own knowledge or based on information provided to me by my client within the course of my instruction, save where expressly stated to the contrary. I am duly authorised by the Claimant to make this statement on their behalf.

 2. I make this witness statement in readiness for the hearing listed on 3rd December 2025 at Willesden and in support of the Claimant’s claim against the Defendant.

 3. Within this statement, I make reference to various documents. These are now produced by me to the court as exhibits and are specifically referred to within the statement by reference to their exhibit numbers. These exhibits have been provided to me by the Claimant in support of their claim. Any reference to an exhibit number within this witness statement is a reference to the corresponding exhibit unless otherwise expressed to the contrary.

 The Claimants Authority to Issue Parking Charges

 4. The Claimant manages and enforces parking on private land (warden-controlled and ANPR) under a Landholder Agreement authorising regulation and the levy of charges for breaches. That agreement confirms the Claimant’s standing and legitimate interest to (a) issue PCNs for breach of the displayed terms and (b) bring proceedings in its own name. In any event, per One Parking Solution Ltd v Wilshaw [2021], the Claimant need not prove landowner authority to sue; it need only show a binding contract formed by clear, prominent signage. The operator–landowner contract does not affect the motorist’s liability.

 5. The Claimant was at all material times a member of an Accredited Trade Association, as reflected on site signage and correspondence. The Claimant is and was also KADOE signatory, entitling it, subject to DVLA “reasonable cause” criteria, to obtain registered keeper details for the relevant date.

 Site Details

 6. The Claimant provides, manages and enforces private parking at the land located at 802 Uxbridge Road, Hayes, London UB4 0RA (the ‘Site’). Now shown at Exhibit reference GS1 is a copy of the agreement between the landowner and the Claimant which sets out, inter alia, the Claimant’s standing and rights to manage and enforce the regulations in situ at the Site.

 7. The “regulations” referred to above (the ‘Terms and Conditions’) are displayed on signs erected by the Claimant at various points throughout out the Site. Exhibit reference GS2 The Terms and Conditions of the Site, Inter alia, express the following conditions for any motorist using the Site:
 Vehicles must be registered on the digital NPM E-Permit database Or Vehicles must fully and clearly display a valid NPM parking permit in the front windscreen

 8. The signs are displayed at various points throughout the site as evidenced by the attached site plan. Exhibit reference GS3 The Driver would have had the opportunity to read and understand them when entering and then parking at the Car Park. An objective observer would consider this action to have been done in acceptance of the Terms and Conditions. It is the signage that forms the basis of the contract between the driver and the Claimant (the ‘Contract’). The signage also states that any breach of the terms and conditions of using the site will result in the issuing of a Parking Charge in the sum of £100.00, plus additional costs if the same remains unpaid.

 9. The Claimant submits that the Site’s terms and conditions are clear, fair, and compliant with its ATA’s Code of Practice and established case law. The signage constitutes a unilateral offer, accepted by the act of parking and remaining on the Site; a driver may always leave to avoid liability. By remaining in breach, the driver agrees to pay the stated parking charge and any lawful additional costs. Every recipient has the right to challenge the PCN via the Claimant’s internal appeals process, and, if dissatisfied, to appeal to the independent ATA appeals service, ensuring early, fair, and independent resolution of any dispute.

 The Defendant’s/Driver’s Breach of the Terms and Conditions

 10. On the 14th December 2023, vehicle registration number YS59HKK was observed by the Claimant to be parked in breach of the terms and conditions applicable at the site. The photographic evidence shows the vehicle parked and unattended at the Site, in close proximity to a prominently displayed sign. The images provide a clear view of the windscreen and interior. No permit is visible on the windscreen or dashboard, and there is no evidence of any permit within the vehicle’s interior. Exhibit reference GS4

 PCN

 11. A PCN was affixed to the vehicle’s windscreen at the time of the contravention. Exhibit reference GS5 The PCN afforded the recipient two options, to pay the £100 charge (discounted to £60 if paid within 14 days) or appeal the charge via the appeals process.

 12. On 14 December the Defendant appealed, asserting that he held a permit which had been placed on the dashboard but fell when the door was closed. The appeal was considered and rejected. The contemporaneous images show a clear view of the windscreen and interior with no permit visible; there was no evidential basis to accept that a valid permit was present at the time. Exhibit reference GS6

 13. The Defendant subsequently appealed to the IAS. The appeal was considered on the basis of the evidence submitted by the parties. The IAS rejected the Defendant’s appeal stating they were satisfied that no valid permit was displayed. Exhibit reference GS7

 14. Thereafter, the Defendant sent further correspondence disputing the IAS decision, asserting, based on what he had read and after consulting others, that the IAS lacked independence. He made various allegations and sought cancellation of the PCN. As the appeal process had been exhausted and no grounds existed to cancel, the PCN remained valid and outstanding.

 THE DEFENCE

 15. The Defendant relies upon a generic internet-sourced defence which is wholly inappropriate, outdated, inaccurate, and irrelevant to the facts of this case. There has also been a misunderstanding of the Civil Procedure Rules, the requirements of the Protection of Freedoms Act 2012 (POFA), or the well-established case law regarding parking charge notices and keeper liability. This demonstrates a lack of proper grounds to defend the claim.

 16. Notwithstanding the above, unless where admitted the Defence is denied in its entirety and the Claimant responds under the sub-headings below.

 Facts known to Defendant

 17. The assertion that “the facts in the defence come from the Defendant’s own knowledge and honest belief” is not accepted. The wording mirrors widely available internet templates and is inconsistent with other parts of the Defence (which speculate about matters outside the Defendant’s knowledge). Where facts are not within the Defendant’s own knowledge, they must be identified as such and verified accordingly; a bare “cut-and-paste” narrative does not satisfy CPR 16.5.

 18. The Defendant’s criticism of the Particulars is unfounded. The claim pleads the essentials required by CPR 16 and PD 16 for a parking charge: site, date(s), contractual terms via signage, breach, and the sum claimed. If the Defendant considered any point unclear, the proper course was to request clarification, not to advance a generic complaint. The Defendant’s assertion that he cannot understand the case, allegations, or heads of claim is untenable. He appealed the PCN to the Claimant and then to the IAS, addressing the alleged breach and advancing reasons why liability should not arise. Those steps demonstrate that he understood the nature of the claim, the contractual terms relied upon, and the remedy sought.

 19. The Claimant can neither admit nor deny the Defendant’s occupation or reason for parking at the site.

 20. The contention that gated entry confers “de facto authorisation” is denied. Access control is not the contract. The contractual right to park arises only on compliance with the displayed terms. Site access by code does not displace those terms or convert a non-compliant stay into an authorised one. Passcodes can be shared, misused, or remain active after a permit has expired or been revoked. Accordingly, possession or use of a gate code is not proof of entitlement.

 21. The signage requires that a valid permit is displayed or the vehicle registered for an E-Permit at all material times. The contemporaneous photographs show a clear view of the windscreen/interior with no permit visible. That objective record contradicts the assertion that a permit was displayed. The suggestion that “the permit moved” is not a defence. It is the motorist’s obligation to ensure the permit is clearly displayed and remains so. A permit that slips, is obscured or not legible fails the contractual requirement. Albeit the interior of the vehicle is visible in the images showing no permit. In the premises, there is no evidence of a valid permit being displayed as required. The breach is made out and the parking charge remains due.

 22. The Defendant’s reliance on an email sent the following day is misconceived. That email constituted a formal appeal and was addressed on its merits. The “duty to mitigate” is misconceived. The parking charge is a contractual sum payable upon breach, not a claim for unliquidated damages. Mitigation principles do not arise in respect of an agreed charge that is reasonable and in accordance with normal industry guidelines. Liability is determined at the material time. Retrospective production of a permit after a PCN has been issued does not cure non-compliance at the time of the contravention. The appeal was considered. The Claimant reviewed the contemporaneous photographs for the Defendant’s vehicle at the material time. In those circumstances there was no contractual basis to cancel. Any ex post facto “evidence” could not establish compliance at the time of parking.

 23. Goodwill cancellation policies are discretionary and do not impose a legal duty to “act reasonably” by waiving a properly issued charge. In the premises, the suggestion that the Claimant failed to mitigate loss or acted unreasonably is denied. The “permit fell” explanation is not a defence. The obligation rests on the motorist; the risk of mis-display (slipping, obscured, facedown, covered by papers) is allocated to the driver by the terms. The doctrine relied upon (casus fortuitus/“unavoidable accident”) is inapplicable. A permit slipping is neither extraordinary nor unforeseeable; it is a routine contingency easily avoided by correct placement, use of a holder, or checking visibility on exit. There is no contemporaneous proof that a valid permit was displayed and later “fell”, nor that any external event caused it.

 24. Where an e-permit/whitelist facility exists, the onus is upon the motorist to obtain authorisation by applying for registration and ensuring the details are correct and current. It is not for the Claimant to register a vehicle on the motorist’s behalf merely because the motorist parks at the Site regularly.

 25. The Defendant’s allegations concerning the IAS are irrelevant to the determination of this claim and should be directed to the IAS through its own complaints process. In particular, the assertion that an adjudicator was “intoxicated” is a serious allegation. The Defendant will be required to provide full particulars and cogent supporting evidence if he wishes to persist with it. Absent such proof, the allegation should be disregarded as wholly immaterial and inflammatory.

 26. The Defendant’s “no loss” argument is misconceived. The Supreme Court has confirmed that properly signposted private parking charges are not penalties and are not assessed by reference to an operator’s loss. They are enforceable contractual sums that serve a legitimate interest and are reasonable and in accordance with normal industry guidelines.

 Exaggerated Claim

 27. The Defendant’s assertion that PCN claims are “exaggerated” and that any purported issues constitute a market failure is fundamentally flawed and denied. Private parking charges are based on the terms and conditions agreed by motorists upon entering the site. The claim amounts sought are consistent with industry standards and are clearly referenced on signage and within the notices issued. Any suggestion that the UK government is addressing “market failure” is irrelevant to the enforceability of the claim, as private parking operators are legally entitled to recover charges for breaches of the contract. The suggested Code of Practice is not live as it was temporarily withdrawn by the Government and no new timeline has been published yet.

 28. The charge sought is therefore reasonable, proportionate, and recoverable, and is not impacted by broader policy considerations or ongoing regulatory reviews.

 CRA Breach

 29. The Defendant’s allegation that the terms and conditions fail to comply with the Consumer Rights Act 2015 or the Independent Parking Committee (IPC) guidance is wholly denied. The signage at the Site constitutes a clear and transparent contractual offer, which was accepted by the motorist upon entering and remaining on the premises. The signs are prominently displayed, legible, and compliant with IPC standards, providing sufficient notice of the terms, including any parking restrictions. The Parking Charge Notice of £100 is industry standard intended to deter breaches rather than to penalise, consistent with the Supreme Court’s decision. At no stage are the terms hidden, misleading, or unfair under the CRA; they are clearly communicated and proportionate to the breach. Accordingly, the Defendant’s assertion that the signage or the charge is unenforceable or unfair is entirely misconceived.

 Costs 30.

The burden of proof in relation to any allegation of unreasonable conduct by the Claimant rests entirely with the Defendant. The Claimant denies, in full, that any such conduct occurred, and the Defendant is required to provide evidence to substantiate these assertions. It is therefore submitted to the Honourable Court that notwithstanding the defence that has been filed, the Claimant has satisfied the burden of proof in this case and is entitled to judgement.

 STATEMENT OF TRUTH

 I believe that the facts stated in 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. Signed Name: Elise Davies Date: 4th November 2025 Ref: 104383.13599 Gladstones Solicitors Limited

 THE CLAIMANT CLAIMS: SCHEDULE OF LOSSES 

 The sum of £100 in respect of the unpaid PCN (‘The Principal Debt’).

 Additional costs as referred to in the signage on display at the site and referred to in the liability notice sent to the Registered Keeper in the sum of £70.00.

 By virtue of the IPC Code of Practice where a parking charge becomes overdue a reasonable sum may be added. This sum must not exceed £70 (inclusive of VAT where applicable) unless Court Proceedings have been initiated. The Claimant therefore seeks an additional amount of £70 in addition to the monies in respect of the unpaid PCN as a contractual entitlement which the Court should enforce. The Claimant however understands that the additional costs, in terms of amount, are completely at the discretion of the court and are subject to its equitable power to disallow unreasonable expenses. It is the Claimant’s position however, that as the PCN remained unpaid, additional costs were incurred by them that were both reasonable and reasonable and proportionate in the circumstances of the case. The Claimant had to divert time and resources to recover the PCN charge, including but not limited to referring the matter to debt recovery services and instructing Solicitors (incurring yet further expense). These costs could have been avoided had the Defendant paid the PCN within the 28-day period, specified in the respective notice.

 Additional costs incurred by the Claimant in respect of issue fee, trial fee and fixed costs.

 The Claimant also seeks interest at 8% or some other such rate as deemed appropriate by the Court, pursuant to Section 69 of the County Courts Act 1984.

 THE CLAIMANT THEREFORE CLAIMS:

 1. Judgment for The Principal Debt of £100.00.
 2. The additional costs of £70.00 or such other amount as the court considers fair and reasonable up to a maximum of £70 given the circumstances of the case.
 3. Any additional costs incurred by the Claimant to date.
 4. The Claimant also seeks interest at 8% or some other such rate as deemed appropriate by the Court, pursuant to Section 69 of the County Courts Act 1984.

 Dated 4th November 2025 Gladstones Solicitors 

Coupon-mad

Looks like John Davies' wife or daughter?

Anyway use the WS you were already signposted to read & adapt.