PCN from NCP - company car - wrong reg used to pay

Coupon-mad

No. Just bin your AI versions.

That is not 'polished' and you certainly don't talk about them reducing it to £20. Even worse "the Defendant made multiple attempts to pay the charge via the Claimant’s online portal."

ABSOLUTELY NOT. 😮

That's practically admitting liability!

Use the Template Defence.

ChirpyChicken

As above what you did was a waste of time sorry just use template defence

UpITA

Thank you. Appreciate your help. This defence was largely based on this comment/thread:
https://forums.moneysavingexpert.com/discussion/comment/81596949/#Comment_81596949

I will redo it using the full template + specific facts in paragraph 3 as advised. When I have a draft, I will post it here.

Le_Kirk

Good, just show us the amended paragraph #2 and your version of paragraph #3; we don't need to check @Coupon-mad's homework.

UpITA

Here is the updated defence:

2. It is admitted that the Defendant was the driver of vehicle XYZ at ABC car park on dd/mm/2025. The allegation that the vehicle was “parked without payment” is denied.

3. The Defendant paid the parking tariff using the Claimant’s phone application. The issue arose solely because the application retained an old vehicle registration number, which was inadvertently selected. Payment was nonetheless made for the parking event.

4. On dd/mm/2025 the Defendant appealed, explaining the keying error and providing proof of payment. On dd/mm/2025 the Claimant acknowledged both the payment and the keying error, yet declined to cancel the charge. Having acknowledged the payment in the appeal response, the Claimant’s subsequent pursuit of a claim pleaded as non‑payment and inflated to £170 is inconsistent, unsupported, and unreasonable.

5. It is neither admitted nor denied that a term was breached but to form a contract, there must be an offer, acceptance, and valuable consideration; none was provided in exchange for the alleged £170 parking charge. The Consumer Rights Act 2015 (s71) mandates a 'test of fairness' duty on Courts and sets a high bar for prominence of terms and 'consumer notices'. Paying regard to Sch2 (examples 6, 10, 14 & 18), also s62 and the duties of fair, open dealing/good faith, the Defendant notes that this Claimant reportedly uses unclear (unfair) terms/notices. On the limited information given, this case looks no different. The Claimant is put to strict proof with contemporaneous photographs.

Paragraph 4 of the template (#5 above) is slightly amended (bold text) since I actually paid the parking tariff, so claiming consideration was absent might appear as an inconsistency. I also wasn't sure whether saying "it is neither admitted nor denied…" while denying the allegation elsewhere is acceptable, but I didn't change it. Please advise if these amendments are acceptable or if further amendments are needed.

Paragraphs 1 and 5-10 of the template are copied as is, with just updated numbering. The whole thing fits into the MCOL system.

Coupon-mad

I would remove this because I don't think you did 'select' it. Apps just default to it:

"which was inadvertently selected."

The rest is fine but I wouldn't add that bit in bold to para 5 because it doesn't make sense. Consideration means something valuable passing between both parties and has nothing to do with the £170 charge.