DCB LEGAL RECORD OF PRIVATE PARKING COURT CLAIM

Real4all

Coupon-mad said:

Yep. We see. Dead easy to defend of course because you just use the Template Defence and in your paragraph 3 you just deny unauthorised parking.

Hi , I have filed AoS on 17/08/2025 on MCOL site. Claim Form issue date is 05/08/2025 . My calculation tells me to file my Defence by 07/09/2025. Is that right? And my main argument is UNAUTHORISED/AUTHORISED parking .So can i still use  Template Defence as it is and how to deny unauthorised parking in paragraph 3 ? Thank You All.

Coupon-mad

You just read a few threads where para 3 is already written in a similar case. Copy!

Search the forum for either

unauthorised defendant prohibitive denied

or 

authorised defendant prohibitive denied

Real4all

Coupon-mad said:

You just read a few threads where para 3 is already written in a similar case. Copy!

Search the forum for either

unauthorised defendant prohibitive denied

or 

authorised defendant prohibitive denied

 Please have a look and let me know your thoughts. , copying all Template Defence ( edited 2025)

and adding these as para 3 . Thanks .

 3. Referring to the POC: paragraph 1 is denied. The Defendant is not indebted to the Claimant. Paragraph 2 is denied. The POC  just lists two dates and says seven PCNs were issued 'between' those two dates.This is not sufficient in terms of a properly pleaded claim. Whilst the Defendant is the registered keeper, 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. On the dates stated in the  paragraph 2 of the POC, the Defendant was working as a contractor to "7Formation ltd" construction company ,doing fit out work for DFS Cardiff . Like all other contractors working on the site ,the Defendant was authorised  by the management to park on the allocated area for contractors.Authorisation confirmation available to submit when required. Parking agreement was made between "7Formation" and DFS Cardiff.

Coupon-mad

Coupon-mad said:

Real4all said:

Castle said:

6th September to 11th September is only 6 days; therefore, they would appear to have issued two for the same day; unless it was two visits on one day.

Yes, they issued 2 tickets for the first day, because I drove out to get some materials 

But the  POC  just lists two dates and says seven PCNs were issued 'between' those two dates. That doesn't cut it in terms of a properly pleaded claim. 

You forgot this important point, above.

And do this on or before 5th September! 

PLEASE bookmark this thread below and do the government's Public Consultation.

Their proposals are wrong and in some parts,  anti-consumer. We must stop them.

See this thread: -

https://forums.moneysavingexpert.com/discussion/6617396/parking-code-of-practice-consultation-8-weeks-from-11th-july-2025/p1

We need every poster to come back & complete this vital Consultation before the deadline.

We understand that you may need some pointers. It looks laborious and you may not be that familiar with the worst conduct of this scam industry, we get that. It doesn't matter - no previous knowledge is needed - you can call out a scam industry with our help, with little preparation needed and you'll protect millions of motorists and help change the law.

I've written some guidance on that thread.

Any questions on the Consultation please ask - on the dedicated thread - but I've covered up to question 20 already in that first post and I will add more tonight.

Ordinary people like you are falling victim to this scam 15 million times per annum. Motorists need your voice added please!

 

Real4all

Coupon-mad said:

Coupon-mad said:

Real4all said:

Castle said:

6th September to 11th September is only 6 days; therefore, they would appear to have issued two for the same day; unless it was two visits on one day.

Yes, they issued 2 tickets for the first day, because I drove out to get some materials 

But the  POC  just lists two dates and says seven PCNs were issued 'between' those two dates. That doesn't cut it in terms of a properly pleaded claim. 

You forgot this important point, above.

And do this on or before 5th September! 

As i understand ,5th September is deadline for government's Public Consultation.?

Coupon-mad

Please read the thread - yes! It is urgent.

Real4all

Coupon-mad said:

Coupon-mad said:

But the  POC  just lists two dates and says seven PCNs were issued 'between' those two dates. That doesn't cut it in terms of a properly pleaded claim. 

You forgot this important point, above.

 

I have added that point to the para 3.
 
 ( Paragraph 2 is denied. The POC  just lists two dates and says seven PCNs were issued 'between' those two dates.This is not sufficient in terms of a properly pleaded claim.)

Please advise if everything is OK, before i submit my Defence. Thank you .

Coupon-mad

Yes it looks good but you could even add to that extra bit:

This is a serial litigator parking firm using a court 'superuser' bulk processing legal firm who know, or should know, how to plead a small claim properly and in accordance with Civil Procedure Rules. The Defendant hereby invites the court to strike out the claim for failure to comply with Part 16.