Smart Parking Defence Feedback please!

dunkedondonuts

Firstly thanks to everyone who has contributed to the resources here, the are invaluable.
I have used the defence template from https://forums.moneysavingexpert.com/discussion/6108153/template-defence-to-adapt-for-all-parking-cases-with-added-admin-dra-costs-edited-in-2025 as is. This is what I am proposing for paragraph 3: 3. Referring to the POC: paragraph 1 is denied. The Defendant is not indebted to the Claimant. 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 as the Defendant was a customer. 3.1 The Defendent was unable to pay for parking due to malfunction of the payment devices. On enquiry, staff at an establishment on the land informed the Defendent that this was a regular occurance and advised that the facility could still be used. 3.2 The Defendant did attempt to appeal the PCN at the time but received no response. Is this sufficient? What do you think I should add/remove?

Gr1pr

dunkedondonuts said:

Firstly thanks to everyone who has contributed to the resources here, the are invaluable.
I have used the defence template from

 https://forums.moneysavingexpert.com/discussion/6108153/template-defence-to-adapt-for-all-parking-cases-with-added-admin-dra-costs-edited-in-2025  as is.

This is what I am proposing for paragraph 3:

 3. Referring to the POC: paragraph 1 is denied. The Defendant is not indebted to the Claimant. 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 as the Defendant was a customer.

 3.1 The Defendent was unable to pay for parking due to malfunction of the payment devices. On enquiry, staff at an establishment on the land informed the Defendent that this was a regular occurance and advised that the facility could still be used.

 3.2 The Defendant did attempt to appeal the PCN at the time but received no response.

 Is this sufficient? What do you think I should add/remove?

edited in order to separate everything 

For Smart Parking cases there are a couple more paragraphs to add,  including the untruth paragraph , I suggest that you study other recent Smart Parking DCB Legal cases 

https://forums.moneysavingexpert.com/discussion/6626291/dcb-legal-smart-parking-claim-missed-defence-deadline-ccj/p2

1505grandad

Can you post a copy of the claim form redacting all the usual personal data including VRM, password, QR codes etc. but leave all dates showing.

Coupon-mad

Best not to admit to driving in Smart defences unless you already admitted that earlier as part of an appeal.