Here we go again. Just received a letter from Civil National Business for parking ticket case 2

IamWood

Thanks to this forum, I won a case against VCS 4 years ago. However, VCS still hasn't paid me. I’ll definitely be chasing them up to collect the payment from their lost court case.

Today, I received a letter from HM Courts & Tribunals Service, Civil National Business Centre, regarding another parking case. Here are the basic details:

Claimant: Euro Car Parks Limited
Claim Number: XXXXX
Defendant: XXXXX
Amount Claimed: £162.95
Court Fee: £35.00
Solicitor’s Costs: £50.00
Total Amount: £247.95
Issue Date: 08/04/2025
Payments to: DCB Legal Ltd – 0330 1744 172

Signed by: (Removed by Forum Team)

PoC: 
Particulars of Claim 1. The Defendant (D) is indebted to the Claimant (C) for a Parking Charge issued to vehicle XXXXXXX at East Oxford Health Centre Car Park.

2. The date of contravention is 04/02/2023

3. The defendant is pursued as the driver of the vehicle for breach of the terms on the signs (the contract). Reason: No Valid Pay And Display/permit Was Purchased

4. In the alternative the defendant is pursued as the keeper pursuant to POFA 2012, Schedule  4.
AND THE CLAIMANT CLAIMS

1. £140 being the total of the PCN(s) and damages.
2. Interest at a rate of 8% per annum pursuant to s.69 of the County Courts Act 1984 from the date hereof at a daily rate of £.03 until judgment or sooner payment.
3. Costs and court fees

I’ll need to refresh my memory on what I did last time. I’ll also document my process in this thread for the benefit of future victims.

IamWood

Helped by ChatGPT.

Assuming you're following the standard timeline laid out in most parking forum guides (like those on MSE or Pepipoo), the key date is 14 days from the issue date of the claim form to acknowledge service (AOS) on the MCOL (Money Claim Online) website.

Your claim form is dated 08/04/2025, so:

• Deadline to acknowledge the claim on MCOL: 22/04/2025
  (You get 14 days from the issue date, not including the issue date itself.)

However, once you acknowledge the claim (which you should do ASAP, ideally a few days before the deadline), you extend your time to file a defence to 28 days from the issue date:

• Deadline to submit your defence: 06/05/2025

So no, you should reply to MCOL somewhere before 22/04/2025 you should log in and acknowledge the claim only — don’t submit a defence yet.

Let me know if you want help drafting that defence or navigating MCOL — happy to guide you through it. 


Please let me know if the timeline is wrong. Thanks!

Gr1pr

Dont bother with AI, stick to current human advice from here , some of the information it gave seems incorrect to me

Especially study recent ECP cases from this year,  because the issued date for the pcn is probably incorrect,  its the incident date,  not likely to be the issued date   ( I believe that they changed recent POC to say contravention date   )

Issued date on the claim form is 8th April, so dont login to MCOL to do the AOS online yet,  not until the 13th or later,  but by day 19 after the issue date,  making your deadline date 33 days after the issue date,  so Monday 12th may at 4pm

Also study the first 2 posts in the defence template thread in announcements,  plus the 2nd post in the newbies sticky thread in announcements too 

Lastly,  email an LoC to VCS regarding the unpaid judgment 

IamWood

Thanks to @Gr1pr

Just to be sure, Should I login to MCOL before Monday 12th May at 4pm to do the AOS online?

Thanks

Gr1pr

Between 13th April and 27th April,  not May,  May 12th at 4pm is the defence deadline , not the AOS deadline 

Defences are emailed 

I would complete the AOS online on MCOL next week 

Coupon-mad

IamWood said:

Thanks to @Gr1pr

Just to be sure, Should I login to MCOL before Monday 12th May at 4pm to do the AOS online?

Thanks

Obviously, otherwise you'll get a default CCJ for not acknowledging.  It must be done in time.

Chat GPT has got those dates hopelessly wrong.  Do not use it.  Useless AI.

DO NOT USE IT FOR ANYTHING IMPORTANT.

Gr1pr

April,  not May,  12th may is the maximum 33 day deadline date,  AOS needs doing next week, 

AOS from Tuesday 13th April onwards IMHO  ( issue date was the 8th  )

IamWood

Thanks.

AOS done online on April 15th.

Will prepare for the defense in early May.

IamWood

Please can you check the draft defense? The changes from the template are in bold.

Thanks

The facts known to the Defendant:

5. The facts in this defence come from the Defendant's own knowledge and honest belief.  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.

6. Referring to the POC: paragraph 1 is denied. The Defendant is not indebted to the Claimant. Paragraph 2 is denied. Whilst the Defendant is the registered keeper, paragraphs 3 and 4 are denied. The vehicle in question was at the premises legitimately using the facilities provided by the landowner.  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 £140 on private land) and there were no damages incurred whatsoever. The Claimant is put to strict proof of all of their allegations.

Coupon-mad

That's not the right version for that POC.

IamWood

Thanks @Coupon-mad

Is this the right template? Thanks a lot!

The facts known to the Defendant: 

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 the driver at the time. 

3.     Referring to the POC: paragraph 1 is denied. The Defendant is not indebted to the Claimant. Paragraph 2 is denied. Whilst the Defendant is the registered keeper, paragraphs 3 and 4 are denied. The vehicle in question was at the premises legitimately using the facilities (NHS health centre) provided by the landowner.  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 £140 on private land) and there were no damages incurred whatsoever. The Claimant is put to strict proof of all of their allegations. 

4. The Claimant will concede that no financial loss has arisen and that in order to impose an inflated parking charge, as well as proving a term was breached, there must be: 

(i). a strong 'legitimate interest' extending beyond mere compensation for loss, and 
 
(Ii). 'adequate notice' of the 'penalty clause' charge which, in the case of a car park, requires prominent signs and lines. 
 
5. The Defendant denies (i) or (ii) have been met. The charge imposed, in all the circumstances is a penalty, not saved by ParkingEye Ltd v Beavis [2015] UKSC67 ('the Beavis case'), which is fully distinguished.