MET NTK RECEIVED FROM THE EVER SO POPULAR SOUTHGATE PARK, STANSTED

Coupon-mad

Redacted claim form.

No more advice needed. We already said where to find the defence.

🙂

Le_Kirk

With an issue date of 07/07/26 and providing you complete(d) the AoS before or on 26/07/26 your defence deadline date is 4.00 p.m. on 10/08/26

baldy10

Thank you for all the advice. AoS completed. Now I need to prepare my defence. Where can I find the template?

Coupon-mad

In the Template Defence thread, which we will never link! See my signature below.

baldy10

20260809_195912.jpg

My reply to PoC,

Left the template exactly as it is and have modified section 3 as below:

3. Referring to the POC: paragraph 1 is denied. The Defendant is
not indebted to the Claimant. Paragraph 2 is denied. The Defendant
does not accept that a contravention occurred on 17/04/2025, as
alleged. Whilst the Defendant was the registered keeper and
driver, 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.

3.1 The Defendant has parked in this car park many times whilst dining in McDonalds. On the date in question, the Defendant entered the site to refuel at the BP petrol station located within the car park. Following this, the Defendant proceeded to McDonald's, also within the same complex, for a quick meal. The entire visit was well within the 1-hour free parking limit that applies at the location, 18 minutes to be precise. It is important to note that Southgate Park has only one entrance and one exit, meaning that any activity within the petrol station and adjacent businesses (such as McDonald's) is recorded under a single continuous stay. This does not accurately reflect the legitimate and permitted use of multiple services within the site during the allowable time frame.

Hope this is ok. Thanks in advance for any adjustments or recommendations.

Coupon-mad

I looked back at your thread and see that you already know that you'd have won at POPLA if you hadn't admitted to driving. Oh well, you live and learn!

This is such a pointless claim that they will discontinue later, before the hearing fee is due.

Also, you say you were in the petrol station at first so go and read the regulator's (the CMA) current investigation into Euro Car Parks' operation at petrol stations and about unfair appeals processes.

Your case is effectively the same as the CMA concerns about ECP but with more issues:

• they have lied (again) about the PoFA and keeper liability applying at Airport sites. That law does not apply because the Airports Act applies and this site is under statutory control of byelaws (everywhere on site: Airside and non-Airside included). There can be no keeper liability on this land (in your case that doesn't matter because you blabbed about driving but in all other cases it's seriously misleading);
• Like with Euro Car Parks, the petrol station usage time has been wrongly and disingenuously assumed by the AI camera system to be part of a 'parking period' and churned out a PCN pretending you were parked the whole time;
• They have knowingly continued to use poor, confusing signs and no obvious delineation between the two car park areas, which look like one;
• They applied an unfair appeals process that spouted a load of nonsense, effectively saying that drivers are somehow supposed to 'know' that these parking spaces are two separate car parks, despite that not being clear, and comedian Joe Lycett doing a memorable piece about this scam site with the same concerns, many years ago.
• Here's the TV show piece and the signs then, seven years ago:

Seems they have done nothing of any use to address the ambiguity and in your case they told POPLA, which of course isn't fully impartial and as usual, the naive pre-programmed BPA-funded assessor swallowed every word:

"yeah, but it's the driver's fault because look, the signs on one side are red and on the other side, the signs are blue!"

You could not make it up but they did.

Your defence is fine because they'll discontinue by Xmas, so you could even write a nursery rhyme as para 3!

Doesn't matter what you put. It won't actually go in front of a judge.

What does matter (much more, because we are confident the CMA will unearth consumer protection lawbreaking and will massively fine some parking companies) is showing your evidence to the CMA this month and asking them to investigate MET at Southgate Park, for the above reasons.

Please do that this week once you've defended your case.

CMA Contact emails (use both, the first one goes directly to their parking investigation) :

parking@cma.gov.uk

general.enquiries@cma.gov.uk 

The circumstances you describe represent a clear breach of the DMCC Act 2024, with a lack of transparent terms and with this whole set up, MET has knowingly carried on for years. This is not open dealing, it's blatantly unfair and not 'in good faith'.

Now, if you have not yet seen and read the CMA's Open Letter and consumer protection compliance warning to the parking industry 3 weeks ago, we suggest you go read it now.

Google it. You'll see!

This is the style to aspire to with your email:

https://forums.moneysavingexpert.com/discussion/comment/82095067#Comment_82095067

Your email could see an investigation opened. It is literally one email with attachments needed. Job done.

Be aware that you won't be assisted re your case, as the CMA cannot reply as such about individual consumer concerns but they are collecting evidence right now for wider investigations of this rogue sector.

We believe their parking investigations team will look at all well-constructed emails with photos & maps, copies of appeals & replies, their POPLA evidence pack and the court claim, as proof of what people are going through.

Do the right thing to protect others from what you went through.

We predict many parking operators will get investigated and fined massively. This is the ultimate fightback.

baldy10

I will definitely be doing this, all the unfair fines which a lot of drivers will have paid….

baldy10

What also needs to investigated is the time POPLA give to reply to a 39 page evidence pack MET sends, 7 days…

Coupon-mad

That's true but that change can & will come later when the MHCLG has a statutory Code in place later this year, and when we know who is running the appeals service.