MET Park ticket from 2023

Mikee_F

Gr1pr said:

Mikee_F said:

Gr1pr said:

So MET Parking,  presumably via DCB LEGAL  ?
....

The exhibits bundle (I assume is what's on point 7)? if so that's due on the 28th January 2026

Its your Witness Statement plus Exhibits bundle that they usually want,  which is a deadline next week,  earlier than the hearing fee deadline,  but still likely to be discontinued before the hearing fee is due,  or earlier 

On the post you mentioned it states "It's a good idea to wait until you receive the Claimant's WS..." I haven't received anything like this, I am assuming I will need to send it before the 28th Jan

Gr1pr

WS,  plus all your numbered evidence, numbering being ,  the defendants initials plus a number,  such as CAMK01 for Clark Adam Mark Kent 

Coupon-mad

You need exhibits too. Not a bare statement.

It's Southgate Park. Surely you are ready with Joe Lycett's video as an exhibit, for starters?!

Copy another Southgate Park MET WS.

Mikee_F

Coupon-mad said:

You need exhibits too. Not a bare statement.

It's Southgate Park. Surely you are ready with Joe Lycett's video as an exhibit, for starters?!

Copy another Southgate Park MET WS.

Sorry no, not sure what the Joe Lycett's video is. 

So basically I need to go back to the car park and take pictures of the place, despite being now about 3 years? (mentioning this as I seen on this case) 

Would this be an example of a WS, pending adapting to my current situation.

Coupon-mad

Google and watch on Youtube Joe Lycett's piece about MET at Southgate Park.

Mikee_F

Coupon-mad said:

Google and watch on Youtube Joe Lycett's piece about MET at Southgate Park.

Thank you, just found it actually whilst looking at other cases in here, sorry it's just I feel very lost on exactly what to do. You mentioned to have the video as exhibit, does this mean I will send the link alongside the WS?

EDIT: Also, I am watching the video and I am noticing something, that I parked on the starbucks park however, Starbucks was closed by the time I went in. Would I be able to use that as proof? Showing the opening times? 

Gr1pr

It was a programme by him on TV a few years ago too

Coupon-mad

Mikee_F said:

Coupon-mad said:

Google and watch on Youtube Joe Lycett's piece about MET at Southgate Park.

Thank you, just found it actually whilst looking at other cases in here, sorry it's just I feel very lost on exactly what to do. You mentioned to have the video as exhibit, does this mean I will send the link alongside the WS?

EDIT: Also, I am watching the video and I am noticing something, that I parked on the starbucks park however, Starbucks was closed by the time I went in. Would I be able to use that as proof? Showing the opening times? 

Yes if it helps your case.

Mikee_F

Just spent the last couple hours working the a WS template, could someone just proof read it or help me on what you think also, my exhibits will be a google maps layout of the place plus the picture provided on the letter by the claimant showing the night picture taken.

Also, the stay was under 1h, not sure if that would make a difference or not but if so could someone assist me? 

-----------------------------------------------------------------------------------------------------------------------------------------------------

IN THE COUNTY COURT

CLAIM No: [REDACTED]

BETWEEN:

MET Parking Services Ltd, (Claimant)

-and-

[REDACTED] (Defendant)

____________________________________

WITNESS STATEMENT OF [REDACTED]

I, [REDACTED], of [REDACTED] will say as follows:

I am the Defendant in this matter, and I was the registered keeper of the vehicle, registration number [REDACTED], on the date of the alleged event. The facts in this statement are true to the best of my knowledge and belief and are based on my own direct experience unless otherwise stated.

On the evening of [REDACTED], the vehicle was driven to the Southgate Park site while awaiting the arrival of an individual travelling from Stansted Airport. The Claimant’s own ANPR evidence confirms that the vehicle entered the site at [REDACTED] and exited at [REDACTED]. The entirety of the visit therefore took place during hours of darkness, and the vehicle left the site shortly thereafter in order to collect that individual.

Inadequate Signage and No Contract Formed

The visit to the site took place late at night, during hours of darkness. At the material time there were no lamp posts illuminated within the car park. In such conditions, a driver’s attention would reasonably be directed towards navigating the site safely rather than searching for signage positioned away from the roadway.

The Claimant has not provided any photographs of the signage at the site, whether taken in daylight or during hours of darkness. In particular, the Claimant has provided no evidence that any signage was illuminated, prominent, or capable of being read at the time of the visit.

The Claimant relies solely on ANPR images to support their claim. These images are exhibited at EX‑02. They show only my vehicle and number plate during hours of darkness. No signage, contractual terms, lighting, or notices of any kind are visible in those images. I rely on this as evidence of the conditions at the material time.

Exhibit EX‑01 is a Google Maps satellite image showing the layout of the site. It demonstrates that this is a large, multi‑use area with multiple buildings, access roads, pedestrian crossings, and parking areas set back from the main routes of travel. This further supports my evidence that, on entry at night, any signage would not have been obvious to a driver exercising reasonable care.

As the Claimant has produced no evidence of signage visibility at the material time, they have failed to prove that any parking terms were adequately brought to the driver's attention before or at the point of parking. In the absence of clear, prominent, and readable signage, no contract can be said to have been formed.

This case is wholly distinguishable from ParkingEye Ltd v Beavis [2015] UKSC 67, where the Supreme Court placed significant emphasis on the presence of large, prominent, and clearly visible signage. In contrast, the Claimant in this case has provided no evidence at all to demonstrate that any comparable signage existed or was capable of being read in the conditions that applied.

I therefore submit that the Claimant has failed to discharge the burden of proof required to establish that a contractual parking charge was properly communicated or agreed. Any alleged terms were not transparent, prominent, or capable of being accepted, particularly during hours of darkness and in the absence of site lighting.

The Claimant's Lack of Standing (Locus Standi) 

I contend that the Claimant has failed to demonstrate that it has the legal standing to bring this claim, a point I raised in my Defence.

The Claimant is not the landowner. In order to pursue parking charges in its own name, the Claimant is required to have clear, contemporaneous written authority from the landowner or lawful occupier of the site. This authority must expressly permit the Claimant to offer parking contracts and to take legal action in respect of alleged breaches.

The Claimant has not provided any unredacted contract or agreement with the landowner that demonstrates such authority. In particular, the Claimant has produced no evidence showing that it was authorised to enter into contracts with drivers or to pursue this claim in its own name at the material time.

In the absence of strict proof of landowner authority, the Claimant has failed to establish locus standi. I therefore submit that the Claimant has no standing to bring this claim and that it must fail on this basis alone.

Unenforceable Additional Costs

The Claimant seeks a principal parking charge of £100 and an additional sum of £70 said to be “debt recovery” or similar, with correspondence threatening a total of £170. I submit the additional £70 is unrecoverable and amounts to double recovery.

First, Schedule 4 paragraph 4(5) of the Protection of Freedoms Act 2012 limits the sum recoverable from a registered keeper to the amount of the parking charge specified on the Notice to Keeper. No statutory entitlement exists to add a further £70.

Second, the Supreme Court in ParkingEye Ltd v Beavis [2015] UKSC 67 made clear that a parking charge already incorporates the operator’s minor running costs (the deterrent charge itself funds the business model). The Claimant has provided no breakdown or proof that any additional costs were actually incurred in this case, nor any evidence that a third‑party fee was paid. It follows that the added £70 is neither a genuine pre‑estimate of loss nor a contractual fee agreed at the point of any alleged contract.

Third, any attempt to layer fixed “debt recovery” sums on top of the already‑inflated parking charge is routinely found to be an abuse of process and/or double recovery in the small claims track. The added sum is arbitrary, not transparent on any sign in evidence, and was never brought to the attention of a motorist at the material time, particularly given that the Claimant has produced no signage photographs at all.

I rely on the Claimant’s own documents (Exhibit EX‑03) showing the threatened escalation to £170, which demonstrates that the £70 is simply an after‑the‑event add‑on rather than a term communicated to a motorist. In the circumstances, I respectfully invite the Court to disallow the additional £70 in its entirety. (In here should I put the claim document from MCOL? they're actually claiming about £180 plus £50 solicitor costs, or should I refer to their last letter as per my post?)

Conclusion

In summary, the Claimant has failed to discharge the burden of proof required to establish its claim. The Claimant has not demonstrated that it has the legal standing to bring this claim; it has failed to provide any evidence of signage capable of forming a contract, particularly given that the visit took place entirely during hours of darkness and in the absence of site lighting; and it has sought to recover additional sums which are not recoverable and amount to double recovery.

In the absence of clear, prominent, and illuminated terms, and without proof of landowner authority or entitlement to the additional sums claimed, I respectfully submit that no contract was formed and that the claim is without merit. I therefore ask the Court to dismiss the claim in its entirety.

Statement of Truth:

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.

Signed: _________________________ 

Date: [Date of signing]

 

Coupon-mad

"In here should I put the claim document from MCOL? they're actually claiming about £180 plus £50 solicitor costs"

No. The judge will have the Claim Particulars.  Not that this will get to a hearing!

Good WS except the overuse of the word 'individual' at the start sounds like you are hiding who is who.