PCN Court Claim – Sold Car, 20-Month Delay, Defense Review Needed

CounterC1ksp

Particulars of Claim

1. The Defendant (D) is indebted to the Claimant (C) for a Parking Charge(s) (PC) issued to vehicle 

2. The dates of contravention are 04/11/2023, 01/12/2023 and the D was issued with PC(s) by the Claimant

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. £340.00 being the total of the PC(s) and damages.

2. Interest at a rate of 8.00% per annum pursuant to s.69 of the County Courts Act 1984 from the date hereof at a daily rate of £0.07 until judgment or sooner payment.

3. Costs and court fees

Defendant Statement:

The Defendant was the registered keeper of the vehicle (registration [insert if known]) on 4th November 2023 but sold it on 30th May 2024, notifying the DVLA, and was not the registered keeper when the claim was issued on 9th July 2025. The Claimant must provide evidence that the Defendant is liable for the alleged contravention despite no longer owning the vehicle.

The 20-month delay between the contravention (4th November 2023) and the claim (9th July 2025) is unreasonable and prejudices the Defendant’s ability to defend the claim. The delay, combined with the Defendant’s sale of the vehicle on 30th May 2024 and change of address, has made it impossible to gather evidence such as receipts, witness statements, or records related to the incident, as these are no longer available or accessible. This invokes the doctrine of laches, rendering the claim unfair and inequitable.


Hello All,

I have mentioned details relating to claims made, kindly go through my case and please help me to write a defense to the court.
I don't have any letters or not able to gather any evidences due to address changes, i received claim letter only to my current address, iam not sure where did they get my address and where are the all other letters gone.  I only have the Vehicle sale transaction screenshot.

Thank you very much for helping.

Gr1pr

Bin it and start again,  you were the RK with the DVLA when the 2 charges were issued and your defence above doesn't deal with the POC,   namely,   Reason: No Valid Pay And Display/permit Was Purchased.

We have already seen one rubbish defence struck out today by Judge Iyer in Manchester , which didn't defend against the POC 

Start drafting your defence based on the template defence by coupon mad,  stick to facts and rebutting the POC  etc

The parking companies have 6 years to sue you by starting a court claim

Name the claimant Parking company and the lawyers involved,  if any 

CounterC1ksp

Name the claimant Parking company and the lawyers involved : Euro car parks Ltd / DCB Legal ltd

Car1980

Use the template defence.

They'll discontinue in the autumn.

Umkomaas

Car1980 said:

Use the template defence.

They'll discontinue in the autumn.

Tons of examples in this thread:

https://forums.moneysavingexpert.com/discussion/6377263/dcb-legal-record-of-private-parking-court-claim-discontinuations/p1 

CounterC1ksp

Gr1pr said:

Bin it and start again,  you were the RK with the DVLA when the 2 charges were issued and your defence above doesn't deal with the POC,   namely,   Reason: No Valid Pay And Display/permit Was Purchased.

We have already seen one rubbish defence struck out today by Judge Iyer in Manchester , which didn't defend against the POC 

Start drafting your defence based on the template defence by coupon mad,  stick to facts and rebutting the POC  etc

The parking companies have 6 years to sue you by starting a court claim

Name the claimant Parking company and the lawyers involved,  if any 

Hi Everyone,

Thank you for your comments.

I have drafted defense based on the POC please review and let me know can i go ahead.
below statement would be my 3rd point out of 10th in the Coupon mad templet.

3.  The Claimant alleges no valid pay and display ticket or permit was purchased on 4th November 2023 and 1st December 2023. I cannot recall where these alleged contraventions occurred due to the 20-month delay from 4th November 2023 and 19-month delay from 1st December 2023 to the claim on 9th July 2025. This delay, combined with my address change and the sale of the car on 30th May 2024, with DVLA notification, prevents me from accessing evidence like receipts or permits to verify payment. The Claimant must provide clear evidence to prove both alleged contraventions occurred as claimed. I don’t recall receiving a Notice to Keeper for either date that meets legal requirements, and the Claimant must prove these were sent correctly to hold me responsible. 

Happy helping.

Coupon-mad

"I cannot recall"

should be

The Defendant cannot recall.

Remove this because this is also written in the first person and anyway, lack of keeper liability is already in the template:

I don’t recall receiving a Notice to Keeper for either date that meets legal requirements, and the Claimant must prove these were sent correctly to hold me responsible. 

CounterC1ksp

Coupon-mad said:

"I cannot recall"

should be

The Defendant cannot recall.

Remove this because this is also written in the first person and anyway, lack of keeper liability is already in the template:

I don’t recall receiving a Notice to Keeper for either date that meets legal requirements, and the Claimant must prove these were sent correctly to hold me responsible. 

I changed and removed as suggested, will submit my defense , Thank you

Coupon-mad

CounterC1ksp said:

Coupon-mad said:

"I cannot recall"

should be

The Defendant cannot recall.

Remove this because this is also written in the first person and anyway, lack of keeper liability is already in the template:

I don’t recall receiving a Notice to Keeper for either date that meets legal requirements, and the Claimant must prove these were sent correctly to hold me responsible. 

I changed and removed as suggested, will submit my defense , Thank you

Great! Defence has no 's' so I assume your spellcheck is set to American? Best to put it right; judges are every bit as pedantic as us!

Now read this message and please do the Public Consultation:

https://forums.moneysavingexpert.com/discussion/comment/81552148/#Comment_81552148

It's vital the Government hears from Defendants.