CEL in-house Claim, Defended, Past Mediation

ARoyalPain

Hi everyone, 

After visiting a store, the driver and 2 passengers missed any mention of the requirement to enter registration upon visiting the store. 

I have appealed to the store and head office to have this removed but they are unwilling to do so without an invoice for a purchase. Being that this isnt exactly a supermarket for small purchases, nothing was purchased on the day (or frankly ever now).

Today I believe is the last day for the 28 day appeal window and I have checked the invoice and believe it to be POFA compliant. I think my best chance is to appeal for a major keying error by the driver, but not sure if that's best and whether it would work as nothing was entered.

I have since received the usual threat of the cost now increasing to £100 as well. 

Any help appreciated! 

Front and back of the first letter

Coupon-mad

ARoyalPain said:

Hi everyone, 

After visiting a store, the driver and 2 passengers missed any mention of the requirement to enter registration upon visiting the store. 

I have appealed to the store and head office to have this removed but they are unwilling to do so without an invoice for a purchase. Being that this isnt exactly a supermarket for small purchases, nothing was purchased on the day (or frankly ever now).

Today I believe is the last day for the 28 day appeal window and I have checked the invoice and believe it to be POFA compliant. I think my best chance is to appeal for a major keying error by the driver, but not sure if that's best and whether it would work as nothing was entered.

I have since received the usual threat of the cost now increasing to £100 as well. 

Any help appreciated! 

Front and back of the first letter

You just ignore them.

No worries.

Read the official MSE Guide linked at the top of this page as it explains every stage.

ARoyalPain

Hi,

Since receiving the original letter I have ignored it following the advice above and finally have the Court claim form (dated 26/05/2026). I have submitted the Acknowledgement of service on 07/06/2026.

I'm looking over the template defence but a little confused about what should be included for the CEL in-house claims. Is it as simple as copying 1, 2 (If I am the driver should this now be admitted?) 4-9 (and 10 if seeking costs) and then bolting in:

3. With regards to the POC in question, two recent persuasive appeal judgments in Civil Enforcement Limited v Chan (Ref. E7GM9W44) and Car Park Management Service Ltd v Akande (Ref. K0DP5J30) would indicate the POC fails to comply with Civil Procedure Rule 16.4(1)(e) and Practice Direction Part 16.7.5. On the 15th August 2023, in the Chan case, HHJ Murch held: 'the particulars of the claim as filed and served did not set out the conduct which amounted to the breach in reliance upon which the claimant would be able to bring a claim for breach of contract'. The same is true in this case and the Defendant trusts that the Court should strike out the extant claim, using its powers pursuant to CPR 3.4. The second recent persuasive appeal judgment also held that typical private parking case POC (like this) fail to comply with Part 16. On the 10 May 2024, in CPMS v Akande, HHJ Evans held: 'Particulars of Claim have to set out the basic facts upon which a party relies in order to prove his or her claim'."

Would this be everything or will I need to add further evidence from the event?

Again, appreciate all the help!

Gr1pr

No evidence is submitted with the defence !

Check your POC from the lower left of the claim form, check if the actual breach is detailed

If not, use the Chan and Akande defence template, so leave paragraph 2 ending in keeper

Chan and Akande in paragraph 3, no changes, no additions, use, the rest of the template, no changes

Copy and paste the 10 resulting paragraphs into the MCOL defence box, save it, submit it

Then

Edit your thread title to something more suitable like

CEL in-house court claim, Defended

Coupon-mad

"Would this be everything"

For the defence stage right now, yes. Nice work. Easy, innit?!

"…or will I need to add further evidence from the event?"

At WS statement stage yes of course you will (but you should hopefully already know when that comes, from when you read post 2 of the NEWBIES FAQs thread, under the red shouty heading 'IMPORTANT: KNOW WHAT HAPPENS WHEN').

Le_Kirk

With an issue date of 26/05/26 and having completed the AoS in a timely manner your defence deadline date is 4.00 p.m. on 29/06/26

Car1980

Excuse my French, by why the fck would you need a permit to go and visit a furniture showroom?

Coupon-mad

https://forums.moneysavingexpert.com/discussion/comment/82045231#Comment_82045231

CEL are an absolute scourge, aren't they, creeping needless 'exempt yourself or else' punitive 24/7 secret surveillance & enforcement into retail car parks.

Wholly inappropriate, unneeded and covert.

Look how high & far away the ANPR or CCTV camera in this case was hidden! Looks like it's on a different building with no obvious GDPR surveillance/data use warning…

…and look how empty this place was - don't they want customers?!

This sort of rubbish follows after their 'success' (extreme money-grabbing) in duping umpteen GP surgeries to sign up agreements that tie them for YEARS, to let CEL film their vulnerable patients' cars then alert their family (keeper) by post that they've been to the doctor.

Retail is not the place for 'permits/keypads' either. Look what the OP says about never shopping at this small business ever again:

"After visiting a store, the driver and 2 passengers missed any mention of the requirement to enter registration upon visiting the store. 

I have appealed to the store and head office to have this removed but they are unwilling to do so without an invoice for a purchase. Being that this isnt exactly a supermarket for small purchases, nothing was purchased on the day (or frankly ever now)."

Coupon-mad

Is it this entrance that used to be Wilko?

As Google Streetview doesn't show the current store or CEL signs it would be good if (AFTER your defence has gone in safely) you could go there on foot and take pics of where the cameras are covertly hidden and the signage at the entrance & inside.

And any 'data use' sign explaining how the camera data will be used.