Court Letter defence - DCB Legal/National Parking Control

dustyyyeu

Hello, I have read the newbies thread and followed all points up to and including submitting MCOL AOS. 

I am now drafting my defence and would like some guidance on the following: 

3. Referring to the POC: paragraph 1 is denied. The Defendant is not indebted to the Claimant. paragraphs 3 and 4 are denied. 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 £170 on private land) and there were no damages incurred whatsoever. The Claimant is put to strict proof of all of their allegations.

3.1 The Defendant was not in possession of a valid NPC permit as no permit was provided. The Defendant was not provided with a valid NPC permit as the homeowner of the space in question was not supplied with a valid NPC visitor permit when they purchased the lease to their allocated space. The claimant offered no suitable alternative method of parking in this situation as all other spaces are allocated to residents. There are no pay and display machines available nor does the signage supply a reasonable way or guidance for how to request a valid NPC visitor permit. 

3.2 The Defendant has parked in allocated visitor spaces at the request of the residents who were being visited, who in turn, National Parking Control Group Limited claim to defend.

I intend to follow the rest of the template defence exactly as written, but I am starting to get a bit worried this won't  go away, or if i am in fact in the wrong  
Any advice on this specifically, and if you need more context, please let me know!

Gr1pr

Post a redacted picture of the POC on the lower left of the claim form after hiding the VRM details first 

It wont be going away for several months 

dustyyyeu

Gr1pr said:

Post a redacted picture of the POC on the lower left of the claim form after hiding the VRM details first 

It wont be going away for several months 

Thank you for responding so quickly. I copied the recommended DCB legal paragraph 3, I just can’t remember when the original Parking charge was issued and I can’t remember the dates exactly so didn’t include para 2 denial

ChirpyChicken

i really cant stand NPC
Bullies

Coupon-mad

I think you could add that any contract was void for impossibility.

dustyyyeu

Thank you @Coupon-mad and @Gr1pr - I submitted my AOS yesterday, i assume i wait a couple of weeks before sending my defence?

KeithP

dustyyyeu said:

I submitted my AOS yesterday, I assume I wait a couple of weeks before sending my defence?

What is the Issue Date on your Claim Form?

dustyyyeu

KeithP said:

dustyyyeu said:

I submitted my AOS yesterday, I assume I wait a couple of weeks before sending my defence?

What is the Issue Date on your Claim Form?

29 April 2025

Coupon-mad

dustyyyeu said:

Thank you @Coupon-mad and @Gr1pr - I submitted my AOS yesterday, i assume i wait a couple of weeks before sending my defence?

No need to delay.