Back again to win again. Need some advice. Thanks.

Gr1pr

Study the example by JackR1

When completed, save as a pdf document and email it to the local court and to the lawyers involved too

The court details are found using Courtfinder

Keep your WS under 50 pages too

AllSticks

Having read the WS by JackR1, I feel woefully unprepared for the hearing!

By comparison, I've scribbled down my story but JackR1 has detailed all sorts from other cases.

Oh my gosh, I'm overwhelmed.

Coupon-mad

Do it today. You've badly dropped the ball here which is awful news for us to hear, especially with a second witness statement to add too. Ouch! You cannot just rock up to hearings with no WS filed & served. This is made crystal clear in the NEWBIES thread.

Dropping off a passenger isn't parking. Quote the new MHCLG Code of Practice definition of parking period and cite the Equality Act 2010 that a disabled person needs an extension of any fixed policy, especially with mobility impairment.

AllSticks

First draft:

IN THE COUNTY COURT

Claim Number: [INSERT CLAIM NUMBER]

Between:

HORIZON PARKING LIMITED

Claimant

-and-

[YOUR FULL NAME]

Defendant

WITNESS STATEMENT OF THE DEFENDANT

I, [YOUR FULL NAME], of [YOUR ADDRESS], am the Defendant in these proceedings. I make this witness statement in support of my defence against the parking charge claimed by the Claimant.

The facts set out in this statement are true to the best of my knowledge and belief.

1. Arrival at the Travelodge and circumstances of the visit

1. On the date in question, my family and I arrived at the Travelodge at approximately 10:19pm, after dark.
2. My father-in-law, XXXX XXXX, was driving his vehicle immediately in front of mine. He pulled up outside the hotel entrance, and I stopped my vehicle directly outside the front doors of the Travelodge.
3. We did not park in any designated parking bay. We stopped directly outside the hotel entrance for the sole purpose of safely unloading our passengers and family luggage.
4. There were no visible road markings or yellow lines at the location where I stopped. My vehicle's hazard lights were switched on to indicate that we were temporarily stopped to facilitate the unloading of passengers.
5. At no point did I see any clearly visible signage stating that stopping outside the hotel entrance to drop off passengers was prohibited or subject to a specific time restriction.
6. I had no intention of parking my vehicle or occupying a parking space. I was simply facilitating the safe arrival of my family at the hotel.

2. The need to assist my disabled mother-in-law and family

1. My mother-in-law was travelling with us in my father-in-law's vehicle. She is disabled and suffers from a traumatic brain injury which leaves her unsteady on her feet and with significant mobility difficulties.
2. I personally assisted my mother-in-law out of XXXX XXXX's vehicle and helped her walk safely into the hotel entrance, where she was able to sit down.
3. This assistance was necessary because of her disability. She could not simply get out of the vehicle and walk independently into the hotel without assistance.
4. My wife was approximately five months pregnant at the time, and we also had our four-year-old son with us.
5. I therefore had to coordinate the safe unloading and movement of a disabled passenger, my pregnant wife and our young child, together with all our collective family luggage.
6. My father-in-law went into the hotel lobby to join the very large queue at reception to check us in.
7. While he waited in this queue, I concentrated on ensuring that everyone was safely inside the hotel entrance hall and that our belongings were unloaded.
8. The hotel was particularly busy, and the check-in process took time. Once we finally received our room keys, I first helped my disabled mother-in-law safely to her room.
9. I then transported the remainder of our family luggage to the rooms before leaving the Travelodge and its grounds.
10. Only after completing these necessary tasks did I depart for a separate long-stay parking facility some distance away, where I intended to leave my vehicle for the duration of our stay.
11. This sequence of events demonstrates that my presence at the hotel entrance was entirely connected with the safe unloading and check-in of my family, rather than parking for convenience or using the hotel facilities without authorisation.

3. The distinction between stopping to unload passengers and parking

1. I respectfully submit that the circumstances of this incident must be distinguished from a motorist simply parking their vehicle and leaving it unattended for their own convenience.
2. I stopped temporarily outside the hotel entrance to facilitate the safe unloading of passengers and luggage.
3. I draw the Court's attention to the Ministry of Housing, Communities and Local Government's Private Parking Code of Practice, published on 20 October 2026.
4. Paragraph 2.17 of the Code defines parked/parking as:

"An instance of a vehicle being caused by the driver to remain stationary other than in the course of driving (excluding instances where the driver has stopped temporarily to enable passengers to leave or enter the vehicle not including drop-off zones such as those at airports in scope of the Code or other facilities designed for dropping off and picking up passengers)."

1. Paragraph 2.22 defines the parking period as:

"The length of time that a vehicle has been parked, i.e. left stationary otherwise than in the course of driving, after any relevant consideration period has expired (excluding instances where the driver has stopped temporarily to enable passengers to leave or enter the vehicle not including drop-off zones such as those at airports in scope of the Code or other facilities designed for dropping off and picking up passengers)."

1. I recognise that this Code was published shortly before this hearing and is due to come into force on 11 November 2026. I therefore rely on it as relevant government guidance, rather than suggesting that it was already in force at the time of the incident.
2. I respectfully invite the Court to consider the distinction recognised by these definitions when determining whether my temporary stopping to assist passengers constituted parking within the meaning of the Claimant's alleged contractual terms.

4. Equality Act 2010 and the requirement to consider reasonable adjustments

1. A central aspect of this case is the presence of my disabled mother-in-law, who suffers from a traumatic brain injury and significant mobility difficulties.
2. Her condition meant that she required physical assistance to leave the vehicle and walk safely into the hotel.
3. I draw the Court's attention to Section 20 of the Equality Act 2010, which establishes the duty to make reasonable adjustments in the circumstances specified by the Act.
4. I also refer to Section 29(7) of the Equality Act 2010, which confirms that the reasonable-adjustments duty applies to service providers.
5. The Claimant, as a private parking operator providing parking services, must have regard to its obligations under the Equality Act where those obligations apply.
6. I further draw attention to section 4 of the newly published MHCLG Private Parking Code of Practice, which addresses accessible parking and recognises that people with limited physical mobility may reasonably require additional time.
7. In these circumstances, a rigid application of a time restriction without properly considering the additional time required to assist a disabled passenger raises a serious question as to whether reasonable adjustments were appropriately considered.
8. I was not seeking any special advantage. I was simply ensuring that my disabled mother-in-law could safely leave a vehicle and enter the hotel.
9. I respectfully submit that the Claimant should have considered the disability-related circumstances rather than applying an inflexible time restriction without regard to the additional assistance required.

5. Inadequate signage and lack of a clear contractual agreement

1. We arrived at approximately 10:19pm, after dark. I did not see any clearly visible signs explaining that stopping outside the hotel entrance to unload passengers was subject to a 15-minute restriction.
2. Having subsequently revisited the location using Google Earth, I have identified what appears to be one small parking sign positioned around the curved entrance to the car park.
3. This sign is easily missed, particularly by someone arriving after dark and concentrating on safely bringing their family to the hotel entrance.
4. The next set of parking signs appears to be positioned on the wall of the main hotel building, beyond the hotel entrance.
5. These signs cannot be seen from the location where I stopped to unload my family.
6. I will provide photographic and Google Earth screenshots showing the positioning of these signs, together with the exact location outside the hotel entrance where I stopped.
7. These images demonstrate that the signage was not sufficiently prominent or visible from the location where the alleged parking activity took place.
8. Crucially, the alleged 15-minute grace period was not clearly communicated to me. I had no knowledge of a clearly displayed term stating that a temporary passenger drop-off outside the hotel entrance was restricted to 15 minutes.
9. I had no knowledge of entering into any contractual agreement with Horizon Parking Limited in relation to the temporary unloading of my family.
10. I respectfully put the Claimant to strict proof that its signage was sufficiently prominent, legible and positioned to bring the alleged contractual terms to the attention of a reasonable motorist arriving at night.
11. I also invite the Court to consider whether the Claimant can demonstrate that any contractual terms were adequately communicated and accepted before alleging that a contract had been formed.

6. Subsequent telephone conversation with Travelodge

1. After receiving the parking charge notice from Horizon Parking Limited, I telephoned Travelodge Gatwick to establish what had happened and to understand the parking arrangements.
2. During that telephone conversation, I was informed that there was a 15-minute grace period.
3. Having reviewed the vehicle entry and exit times, we established that the vehicle had exceeded this 15-minute period by just 1 minute and 47 seconds when it exited the grounds.
4. This was the first time I became aware of the alleged 15-minute restriction and its application to our visit.
5. The fact that I subsequently telephoned Travelodge to investigate the matter demonstrates that I was acting in good faith and trying to understand the basis of the charge.
6. The alleged additional time was not the result of deliberately remaining parked or ignoring any clearly communicated parking conditions. It arose from the practical time required to safely assist my disabled mother-in-law, my pregnant wife and our young child, together with the necessary unloading of our luggage and completion of the hotel check-in process.

7. The alleged overstay was minimal and arose from exceptional circumstances

1. The Claimant alleges that the vehicle exceeded the stated 15-minute period by just 1 minute and 47 seconds.
2. This very short additional period arose directly from the exceptional circumstances described in this statement.
3. It would have been entirely inappropriate to rush my disabled mother-in-law, who is unsteady on her feet following a traumatic brain injury, simply to comply with an inflexible time restriction.
4. My priority was the safety and welfare of my family, including a disabled passenger, a five-month-pregnant passenger and a four-year-old child.
5. I respectfully ask the Court to consider the actual circumstances of this incident rather than treating the alleged additional 1 minute and 47 seconds as an ordinary or deliberate breach of parking conditions.

8. Conclusion

1. I respectfully submit that this parking charge should not have been pursued.
2. I did not park in a designated parking bay. I temporarily stopped directly outside the hotel entrance, with my hazard lights on, to safely unload my family.
3. I was assisting a disabled passenger with significant mobility difficulties, a pregnant passenger and a young child, while also managing the unloading of our collective luggage.
4. The signage was not sufficiently visible or clear, particularly given that we arrived after dark. The alleged 15-minute restriction was not brought clearly to my attention.
5. The alleged additional time was only 1 minute and 47 seconds and arose from genuine and necessary family circumstances.
6. I respectfully ask the Court to consider the distinction between temporary passenger assistance and parking, the Claimant's obligations under the Equality Act 2010, the relevant MHCLG guidance, the inadequacy of the signage and the absence of any properly communicated contractual agreement.
7. For all these reasons, I respectfully request that the Court dismisses the Claimant's claim.

STATEMENT OF TRUTH

I believe that the facts stated in this witness statement are true.

Signed: ______________________________

Name: [YOUR FULL NAME]

Date: ______________________________

Coupon-mad

Remove 'in my father-in-law's vehicle'.

You can't say "I will provide images" - NO - they must be attached as numbered exhibits now. Like Gladstones did, only with your initials.

You will know about numbered exhibits because I provide a whole long list of suggested evidence in the NEWBIES thread. You don't seem to have used any of the recommended exhibits yet?

You haven't got HHJ Moloney's transcript. You haven't attacked the added £70 or the rogue added tenner that doesn't match the PCN sum on the signs.

You haven't torn into Gladstones' WS and pointed the above issues out.

Or pointed out that their own photo images show it was pitch black that night with no signs at the kerb, and in close-up they've only produced stock signs in daylight or mock-up drawings of a sign. That's not evidence.

You haven't questioned landowner authority (even though it's a point in your defence) or attacked the landowner document produced in their bundle (look at dates, who signed it, and is it heavily redacted)? Pull it apart if it's covering up detail.

You don't seem to have attached any evidence of your MiL's disability.

There's no point your father in law attending the hearing unless he also does a WS as well.

You need images of the hotel in the dark if you can get them tonight (if not, Google images).

Your statement of truth is five years out of date so we think you used AI. There was no need to do that…AI always does a poor job with parking WS and gets the SoT wrong.

Just copy the style of the WS by @JackR1

Coupon-mad

"JackR1 has detailed all sorts from other cases."

Yes. Because they win cases, but you've missed them all out - why?

Le_Kirk

Does your WS reflect what you wrote in your defence? Does it back up and support what you wrote?