HELP! Euro Car Parks PCN - No Parking Zone

Crispy_Pizza212

Morning, the email addresses varied and i wanted to ensure it was being sent to the correct one. I spoke with a rep of the courts earlier today to get some assistance. 

They mentioned that the only document that they recognise and is required to be returned as part of the defence is the N9B Form. They sent me a link via text to an interactive document.

They asked that if you intend to submit additional documents i.e. your defence in word/PDF because it doesn't fit in their tiny box, you need to state this in Section 3 i.e. the defence box. Something along the lines of "Please see the Defendant’s attached defence document, which is served and relied upon in full. This attachment forms part of this Defence."

The email address provided was ClaimResponses.CNBC@justice.gov.uk

In the hope that this helps someone else some day, please see the following defence provided, this alleged PCN reasoning was: "Your Vehicle Was Parked In A No Parking Area".

IN THE CIVIL NATIONAL BUSINESS CENTRE (REFERENCE No.)

Claim No.: XXXXX

BETWEEN:

EURO CAR PARKS LIMITED – [Reference] (Claimant)

– and –

XXXXXXX (Defendant)

DEFENCE

1.  Denial of Liability

1.1    The Defendant denies liability for the entirety of the claim.

2.  Deficiencies in Particulars of Claim

2.1  The Particulars of Claim are sparse, incoherent, and fail to meet CPR 16.4 requirements. They disclose no clear cause of action, failing to state how the alleged sum arose, the specific contractual terms relied upon, or the quantum calculation. The claim is therefore inadequately pleaded.

3.  Admissions

3.1  It is admitted that the Defendant was the registered keeper and driver of vehicle XXXXX on [DATE].

4.  Lack of Adequate Signage and No Contract Formed

4.1  The Defendant denies that any contract was formed with the Claimant. No adequate or prominent signage was in place to communicate any terms and conditions at the location of parking. The area where the vehicle was parked contained no visible “no parking” signs, no bay markings, and no indication that stopping was prohibited. This is supported by contemporaneous photographic and video evidence.

4.2  The Defendant parked their vehicle in a clear area of the car park where no signage or markings indicated parking was not permitted.

4.3  The Claimant asserts that signage onsite stated “No parking within the service area at any time.” The Defendant avers that such signage was absent from the location in question. Any signage present was either not in proximity to the parked vehicle or incapable of forming a binding contract.

4.4  The Defendant requested evidence of signage from DCB Legal Ltd. The signage provided was not from the correct car park and did not evidence the signs referenced in paragraph

4.5  The Claimant relies on a generic image stating “No Parking.” No such sign was present at the location in question, as confirmed by photographic evidence.

4.6  A lone sign stating “No parking – access required at all times” was attached to a shipping container approximately 8 metres away. The inference is that a parked vehicle would block access to the doors, and so the Defendant parked at a sufficient distance so as not to impede access.

4.7   In any case, the signage does not constitute a contractual offer. There is no offer or mention of consideration; merely a prohibitive instruction.

4.8  The Claimant appears to rely solely on this sign. Even if such a sign were relevant, it would constitute a “forbidding contract” where no offer exists and no consideration could be exchanged.

4.9  No contract exists between the Claimant and Defendant, and it follows that no contract could have been breached.

5.  Proof Required of Signage and Compliance

5.1  The Claimant is put to strict proof of:

 a.  The existence, location, size, wording, and lighting of all signage relied upon.

b.  The precise location of the Defendant’s vehicle in relation to such signage.

c.  That such signage complied with the BPA Code of Practice.

6.  Lack of Standing and Landowner Authority

6.1  The Defendant does not believe the Claimant has the necessary legal interest or landowner authority to bring this claim. A request for disclosure of the relevant landowner contract was refused. The Claimant is put to strict proof that it has full legal standing and authority from the landowner to enforce terms and recover sums in its own name.

7.  Abuse of Process – Inflated and Unrecoverable Costs

7.1  The Defendant avers that the claim includes an unrecoverable additional sum, described as “damages” or “debt recovery costs,” which are an attempt at double recovery. The Supreme Court in ParkingEye v Beavis [2015] UKSC 67 established that only the core parking charge (if valid) may be recoverable, not any enhanced sums.

8.  No Liability Arises

8.1  In the absence of clear terms, adequate signage, and landowner authority, no liability arises. The claim is without merit, misconceived, and should be struck out.

9.  Breach of Mandatory Grace Period

9.1  Further, the Parking Charge Notice was issued just 40 seconds after the Defendant entered the car park. This is a clear breach of the mandatory grace period required by the BPA Code of Practice, which stipulates that drivers must be allowed sufficient time to read signage and decide whether to remain. The unreasonable and predatory issuing of a charge within seconds of arrival demonstrates that no contract was capable of being formed.

STATEMENT OF TRUTH

I believe that the facts stated in this Defence 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.

Name:
Signature:
Date:

Coupon-mad

We have never used that form. Literally never. People always emailed signed defences tens of thousands of times. No form!

I suspect she also gave you the wrong email address which the CNBC has been doing a lot. Their admin is terrible!

Coupon-mad

By the way that's not a bad defence but why aren't you just using the Template Defence

Le_Kirk

Crispy_Pizza212 said:

I have until Thursday this week to provide my defence, I saw from the various forums that I should leave submission of my defence to the last minute (I have already completed the acknowledgement of service). 

My calculations show the defence due date as below. Issue Date     Served Date    AoS Due      Defence Due

08/08/25         13/08/25          27/08/25        10/09/25