MANOR PARKING, GLADSTONES court claim 2025

Skintandangry

Having read newbies pages, I remain a little confused as to the best defence to a small claims court claim from Gladstones Solicitors on behalf of Manor Parkings PCN regarding Lotties Road Birmingham in 2024.
I wrote to Manor parking at the time (copy below) but they ignored my letter. I did later find a scanned copy of my letter to them filed on their website with photos of the vehicle.

Some 12 months later I started getting hounded by Gladstone Solicitors by letter and text message all of which I ignored until I received "letter before claim" to which I replied by email (also copied below).

PCN ............Dear Sirs, I dispute your 'parking charge', as the keeper of the vehicle. I deny any liability or contractual agreement and I have made a complaint to the landowner.
There will be no admissions as to who was driving and no assumptions can be drawn. Since your PCN is a vague template, I require an explanation of the allegation and your evidence. You must include a close up actual photograph of the sign you contend was at the location on the material date as well as your images of the vehicle already provided.
If the allegation concerns a PDT machine, the data supplied in response to this appeal must include the record of payments made - showing partial VRNs - and an explanation of the reason for the PCN, because your Notice does not explain it.
If the allegation involves an alleged overstay of minutes, your evidence must include the actual grace period agreed by the landowner.                                                                                           Your notice to keeper is not Protection of Freedoms Act compliant on either dates or wording, I the keeper cannot be held liable, I therefore suggest you cancel the notice in order to save all concerned time and money.

Dear Gladstone Solicitors,                                                                  Ref letter before claim.

Your client Manor Parking Ltd has chosen to ignore my letter to them dated 03/04/2024 disputing their inflated parking charge notice number -------- of £170.00 to myself the registered keeper.

Any court proceedings will be vigorously defended as the alleged debt is disputed as set out in my letter to Manor Parking Ltd over 14 months ago.

Regards ----------

Gr1pr

Study the first 2 posts in the defence template thread in announcements near the top of the forum,  paying particular attention to anything regarding Gladstones Solicitors 

Also study other recent Gladstones claims

Post the Issue date from the top right of the claim form below and also post a redacted picture of the POC from the lower left of the claim form below after hiding the VRM details first 

Coupon-mad

And wait and see if you get a Claim Form to defend, or not.

Skintandangry

Gr1pr

Skintandangry

Here you go

Gr1pr

Get the correct defendant named on the N1SDT claim form to complete the AOS online ASAP 

No actual breach has been identified or pleaded

kryten3000

You can use the Chan and Akande paragraph 3 with the template defence.  

Coupon-mad

Which the template defence thread already explains and links to a pre-written para 3.

Car1980

There is nothing in law stated in their particulars that enables them to recover the charge from the keeper if they were not the driver ie. they've forgotten to state POFA.

Theoretically, you could simply state you were not the driver, no contract exists between the two of you and they have not brought their claim under any legal mechanism that would alter these facts and make the keeper liable. Therefore under CPR 3.4(2) the court should (a) strike out a statement of case if it appears to the court ‘that the statement of case discloses no reasonable grounds for bringing the claim’.

Skintandangry

Many thanks for all the comments so far,I'm slowly finding my way around the forum now by using my mobile rather than laptop on which I could not find templates or top of the page etc.

Quick question when I file my AoS online can I use the government gateway login that I already have for my self assessment tax returns or should I create a new login.

Coupon-mad

You can and should use your existing one.