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Court claim for overstay at now closed Homebase site (G24)

DrGronod
DrGronod Posts: 26 Forumite
Part of the Furniture 10 Posts Combo Breaker
edited 18 September at 11:25PM in Parking tickets, fines & parking
Hi

Advice sought please on how to respond in the court claim defence template. I have seen other similar threads (e.g. https://forums.moneysavingexpert.com/discussion/6608886/g24-) but mine is slightly different. It is much more recent (so can’t really claim no recollection) and I have what I’d consider mitigating circumstances. Basically I overstayed without realising (don’t deny this - evidence pretty clear) and spent a reasonable amount of money but the store closed before I could reach anyone to cancel the PCN.

The background is that G24 sent a PCN for overstaying their 90 minute limit by 27 minutes at the now closed Homebase site “Woodside Retail Park” in Sheffield. The situation was that it was a closing down sale and my wife and I spent a long time trying to see what we might want from the stock left which was quite a jumble. So a lot of decision making etc etc. We ended up spending £64 and then a further £104 the next week having worked out what we further needed. To be honest we never considered that we’d spent too long and I’m not questioning the evidence that we were there 117 minutes. Revisiting the site afterwards there are small signs saying the 90 minute limit on the outside walls of the store but very few in the centre of the car park, and none on the entrance mentioning any time limit (just says “customers only, see notices in car park” etc). I guess I assumed 2 or 3 hours as often the case. I also went to the toilet which contributed to the time spent (being a man of a certain age)!

Sod’s Law that I got the PCN the day after the store closed so no manager to contact. I did manage to speak to a manager at another Homebase store which was in the process of had being taken over by the Range, who said ring back the next day and he’d sort it, but I never managed to speak to him again (and no-one else at any Range store was interested). I haven’t managed since to find out who owns the site. It’s a small site split into 2 with the other half advertised as owned by “Ryden” - contacting them I eventually got an email from someone there who said he’d pass it in to the relevant person for the Homebase side, but never heard back despite chasing.

I ignored the PCN, and then the subsequent “debt recovery threat” letter. And now have received the court claim form. I did the MCOL acknowledgement and the 30 days are up on 25th Sept (have been on holiday in between hence now looking into this).

So I now I’m looking at filling in the defence template as per https://forums.moneysavingexpert.com/discussion/6108153/template-defence-to-adapt-for-all-parking-cases-with-added-admin-dra-costs-edited-in-2025/p1.

For section 2, as the evidence is pretty clear and I do have clear recollection of events (to be used in mitigation), is the below therefore appropriate (or do I still deny all knowledge?!)?

 
2. The allegation(s) and heads of cost are vague and liability is denied for the sum claimed, or at all. At the very least, interest should be disallowed; the delay in bringing proceedings lies with the Claimant. The Defendant seeks fixed costs (CPR 27.14) and a finding of unreasonable conduct and further costs (CPR 46.5). The Defendant’s recollection of events are as set out below and admit that they were the registered keeper.

For section 3, wondering how detailed should I go?
I guess I acknowledge that I was the driver and registered keeper.
Then I’m wondering exactly what to put: along the lines of “I knew it was 90 minutes but didn’t notice the time”, or “I thought it was 120 minutes and the signage was inadequate for all the car park”? I guess the spending in store is relevant (that we “spent £64 and the a further £104 in the store due to that first visit”)?  Also would it matter that the car park was barely a quarter full? And finally do I mention going to the toilet?! Are things like this considered in mitigation at this stage or should I just outline the basics? I’m quite prepared to go to court and argue my case to a hopefully sympathetic judge if it comes to it!

Timeline is:
- Carpark visit for 117 minutes 7/3/25
- Homebase closed 19/3/25 (AFAICR)
- PCN for £100 dated 13/3/25 received 20/3/25 (AFAICR) - ignored 
- Letter from dcbi “debt collector bailiffs ltd” for £170 - ignored
- Court claim form for £260.82 (£175.72+£35+£50) dated 18/8/25 received 19/8/25 
- MCOL acknowledgement completed 26/8/25
Claimant is G24 via DCB Legal Ltd - see below


Thanks in advance.


Comments

  • Coupon-mad
    Coupon-mad Posts: 154,617 Forumite
    Part of the Furniture 10,000 Posts Name Dropper Photogenic
    Doesn't matter what you put because DCB Legal always discontinue G24 claims before hearings. But you could copy this one with the brand new bits instead of the usual Template Defence paras 9 &10 which you can replace:

    https://forums.moneysavingexpert.com/discussion/6629202/bay-sentry-via-dcb-legal-issue-date-9th-september-poc-has-pleaded-the-alleged-contravention/p2
    PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT (except N.Ireland).
    CLICK at the top or bottom of any page where it says:
    Home»Motoring»Parking Tickets Fines & Parking - read the NEWBIES THREAD
  • Le_Kirk
    Le_Kirk Posts: 24,865 Forumite
    Part of the Furniture 10,000 Posts Photogenic Name Dropper
    With an issue date of 18/08/25 and having completed the AoS in a timely manner
    your defence deadline date is 4.00 p.m. on 22/09/25
  • DrGronod
    DrGronod Posts: 26 Forumite
    Part of the Furniture 10 Posts Combo Breaker
    Le_Kirk said:
    With an issue date of 18/08/25 and having completed the AoS in a timely manner
    your defence deadline date is 4.00 p.m. on 22/09/25
    Ah - thanks for that. I must have misread somewhere it was 30 days from AoS submission.
    I see now it is 28 days after the “date of service”, which is “5 business days after the issue date”, which for Mon 18th Aug is Mon 25th Aug, and therefore 28 days is Mon 22nd Sept as you say (just clarifying for myself). Just in time then - I would have been late otherwise!
  • Coupon-mad
    Coupon-mad Posts: 154,617 Forumite
    Part of the Furniture 10,000 Posts Name Dropper Photogenic
    DrGronod said:
    Le_Kirk said:
    With an issue date of 18/08/25 and having completed the AoS in a timely manner
    your defence deadline date is 4.00 p.m. on 22/09/25
    Ah - thanks for that. I must have misread somewhere it was 30 days from AoS submission.
    I see now it is 28 days after the “date of service”, which is “5 business days after the issue date”, which for Mon 18th Aug is Mon 25th Aug, and therefore 28 days is Mon 22nd Sept as you say (just clarifying for myself). Just in time then - I would have been late otherwise!
    There's another deadline next week too:

    FIGHTBACK ALERT:

    Please do the government's Public Consultation. We need every poster to complete this vital survey before the deadline next week.

    See this thread:

    https://forums.moneysavingexpert.com/discussion/6617396/parking-code-of-practice-consultation-now-extended-closes-friday-26th-september/p1

    We understand that you may need some pointers. It looks laborious, we get that. It doesn't matter; no knowledge is needed except re your own experiences so you can call out a scam industry and you'll protect millions of motorists and help change the law. 

    I've written some guidance to help focus new posters on the issues. I've covered almost every question, providing ideas if you agree with our stance on things like DRFs, which we say must be banned.

    Ordinary people like you are falling victim to this scam over 18 million times per annum. Motorists need your voice added please.

    CLOSES ON FRIDAY 26th SEPTEMBER.

    PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT (except N.Ireland).
    CLICK at the top or bottom of any page where it says:
    Home»Motoring»Parking Tickets Fines & Parking - read the NEWBIES THREAD
  • DrGronod
    DrGronod Posts: 26 Forumite
    Part of the Furniture 10 Posts Combo Breaker
    Doesn't matter what you put because DCB Legal always discontinue G24 claims before hearings. But you could copy this one with the brand new bits instead of the usual Template Defence paras 9 &10 which you can replace:

    https://forums.moneysavingexpert.com/discussion/6629202/bay-sentry-via-dcb-legal-issue-date-9th-september-poc-has-pleaded-the-alleged-contravention/p2
    Ok thanks - not quite sure of the significance of that but will have a look at it. Looks to be very different circumstances but if you think it is relevant will use it.
  • DrGronod
    DrGronod Posts: 26 Forumite
    Part of the Furniture 10 Posts Combo Breaker
    DrGronod said:
    Le_Kirk said:
    With an issue date of 18/08/25 and having completed the AoS in a timely manner
    your defence deadline date is 4.00 p.m. on 22/09/25
    Ah - thanks for that. I must have misread somewhere it was 30 days from AoS submission.
    I see now it is 28 days after the “date of service”, which is “5 business days after the issue date”, which for Mon 18th Aug is Mon 25th Aug, and therefore 28 days is Mon 22nd Sept as you say (just clarifying for myself). Just in time then - I would have been late otherwise!
    There's another deadline next week too:

    FIGHTBACK ALERT:

    Please do the government's Public Consultation. We need every poster to complete this vital survey before the deadline next week.

    See this thread:

    https://forums.moneysavingexpert.com/discussion/6617396/parking-code-of-practice-consultation-now-extended-closes-friday-26th-september/p1

    We understand that you may need some pointers. It looks laborious, we get that. It doesn't matter; no knowledge is needed except re your own experiences so you can call out a scam industry and you'll protect millions of motorists and help change the law. 

    I've written some guidance to help focus new posters on the issues. I've covered almost every question, providing ideas if you agree with our stance on things like DRFs, which we say must be banned.

    Ordinary people like you are falling victim to this scam over 18 million times per annum. Motorists need your voice added please.

    CLOSES ON FRIDAY 26th SEPTEMBER.

    Ok will do!
  • Coupon-mad
    Coupon-mad Posts: 154,617 Forumite
    Part of the Furniture 10,000 Posts Name Dropper Photogenic
    DrGronod said:
    Doesn't matter what you put because DCB Legal always discontinue G24 claims before hearings. But you could copy this one with the brand new bits instead of the usual Template Defence paras 9 &10 which you can replace:

    https://forums.moneysavingexpert.com/discussion/6629202/bay-sentry-via-dcb-legal-issue-date-9th-september-poc-has-pleaded-the-alleged-contravention/p2
    Ok thanks - not quite sure of the significance of that but will have a look at it. Looks to be very different circumstances but if you think it is relevant will use it.
    What have circumstances got to do with it? You don't put circumstances in: you'll just use the Template Defence. I'm merely showing you the new legal point to add instead of the usual Template Defence paras 9 &10 (which you can replace).
    PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT (except N.Ireland).
    CLICK at the top or bottom of any page where it says:
    Home»Motoring»Parking Tickets Fines & Parking - read the NEWBIES THREAD
  • DrGronod
    DrGronod Posts: 26 Forumite
    Part of the Furniture 10 Posts Combo Breaker
    DrGronod said:
    Doesn't matter what you put because DCB Legal always discontinue G24 claims before hearings. But you could copy this one with the brand new bits instead of the usual Template Defence paras 9 &10 which you can replace:

    https://forums.moneysavingexpert.com/discussion/6629202/bay-sentry-via-dcb-legal-issue-date-9th-september-poc-has-pleaded-the-alleged-contravention/p2
    Ok thanks - not quite sure of the significance of that but will have a look at it. Looks to be very different circumstances but if you think it is relevant will use it.
    What have circumstances got to do with it? You don't put circumstances in: you'll just use the Template Defence. I'm merely showing you the new legal point to add instead of the usual Template Defence paras 9 &10 (which you can replace).
    Ok thanks - just wasn’t sure why you suggested that replacement, whether it was generic or specific to that case (new to all this).
  • Coupon-mad
    Coupon-mad Posts: 154,617 Forumite
    Part of the Furniture 10,000 Posts Name Dropper Photogenic
    edited 20 September at 12:17AM
    You missed the thread about it yesterday. This is new 'case law' hot off the presses:. So new it's not even in the Template Defence quite yet, but it will be:

    https://forums.moneysavingexpert.com/discussion/6629609/unqualified-staff-at-a-law-firm-are-not-allowed-to-conduct-litigation/p1


    PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT (except N.Ireland).
    CLICK at the top or bottom of any page where it says:
    Home»Motoring»Parking Tickets Fines & Parking - read the NEWBIES THREAD
  • DrGronod
    DrGronod Posts: 26 Forumite
    Part of the Furniture 10 Posts Combo Breaker
    You missed the thread about it yesterday. This is new 'case law' hot off the presses:. So new it's not even in the Template Defence quite yet, but it will be:

    https://forums.moneysavingexpert.com/discussion/6629609/unqualified-staff-at-a-law-firm-are-not-allowed-to-conduct-litigation/p1


    Ah - ok - thanks again.
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