UKPC disabled parking PCN- 1 day to submit claim on MCOL!

Abi90

Hi all,

I'm new to this but grateful for all the support this forum has offered. I did get a solicitor to have a look at this for me as I have a newborn but I am not convinced by what they want to send especially as they told me it might be better to settle. This contradicts everything this form is about so I have lost confidence in them and want to submit my own appeal.

I have attached a copy of the PoC .

I parked in a disabled bay without a permit because I had a minor in the car I wanted to keep an eye on from inside the shop and I was picking up a collection that should have taken a minute. However, when I got there, there were no assistants to help, which delayed the whole process to 10-15mins leading to the ticket.

I am using the standard defence as per https://forums.moneysavingexpert.com/discussion/6108153/suggested-template-defence-to-adapt-for-all-parking-charge-cases-where-they-add-false-admin-costs/p1

amending paragraph 2 and 3, the rest will be attached without any amendments. Any help will be greatly appreciated!

WhatsApp Image 2026-02-28 at 21.34.01.jpeg

valley park signage edit.png

valley park signage main.jpg

. My amendments in bold.

but struggling with paragraph 3 especially as @sammyb1996 said a judge said their defence did not have adequate relevant facts.

" 2. The allegation(s) are vague and liability is denied for the sum claimed, or at all. The delay in bringing proceedings lies with the Claimant, making retrieving material evidence difficult, which is highly prejudicial. The Defendant has little knowledge of events, save as set out below and to admit that they were the lessee.

3. Representation was made to UKPC Ltd as the lessee stating the lack of adequate signage constituting a contract and asking for a copy of the alleged contract which has been breached however, this appeal was rejected with no provision of such contract.

Gr1pr

Your deadline is 4pm on Monday 2nd March

Your defence should refute the POC, so I suggest that you use paragraph 3 from the following thread

https://forums.moneysavingexpert.com/discussion/6629460/secure-parking-solutions/p4

https://forums.moneysavingexpert.com/discussion/6629460/secure-parking-solutions

Adapt the wording as required, Then change your paragraph 3 above to 4,, renumbering the rest from 5 onwards

PS, you are defending,, not appealing. !

Abi90

https://forums.moneysavingexpert.com/discussion/comment/81904182#Comment_81904182

Do you mean like this? My amendments in bold.

" 2. The allegation(s) are vague and liability is denied for the sum claimed, or at all. The delay in bringing proceedings lies with the Claimant, making retrieving material evidence difficult, which is highly prejudicial. The Defendant has little knowledge of events, save as set out below and to admit that they were the lessee.

3.  With reference to the Particulars of Claim, paragraph (1) is denied. The Defendant is not indebted to the Claimant. Paragraph (2) is denied. The Defendant does not accept that a contravention occurred 24th March 2025 as alleged. Paragraphs (3 and 4) are also denied as there was no breach of the terms on the signs( the contract) therefore, there was no parking “…In A Disabled Space Without Displaying A Valid Permit” .

4. Representation was made to UKPC Ltd as the lessee stating the lack of adequate signage constituting a contract and asking for a copy of the alleged contract which has been breached however, this appeal was rejected with no provision of such contract.

Gr1pr

Delete the last sentence in paragraph 3 above ( all of that bottom line

Abi90

https://forums.moneysavingexpert.com/discussion/comment/81904235#Comment_81904235

Thank you for all your help! This ok?

3. With reference to the Particulars of Claim, paragraph (1) is denied. The Defendant is not indebted to the Claimant. Paragraph (2) is denied. The Defendant does not accept that a contravention occurred 24th March 2025 as alleged. Paragraphs (3 and 4) are also denied as there was no breach of the terms on the signs( the contract).

Abi90

Also, if I am contesting there being a breach then I need to amen paragraphs 4-6 (on the original) but now my 5-7. suggestion for statements needing amendment in bold.

"4. 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 (absent in this case). 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.

5. DVLA keeper data is only supplied on the basis of prior written landowner authority. The Claimant (an agent) is put to strict proof of their standing to sue and the terms, scope and dates of the landowner agreement, including the contract, updates, schedules and a map of the site boundary set by the landowner (not an unverified Google Maps aerial view).

6. To impose a PC, as well as a breach, there must be: (i) a strong 'legitimate interest' extending beyond compensation for loss, and (ii) 'adequate notice' (prominence) of the PC and any relevant obligation(s). None of which have been demonstrated. This PC is a penalty arising as a result of a 'concealed pitfall or trap', poor signs and covert surveillance, thus it is fully distinguished from Beavis."

Coupon-mad

Can I ask why a parent with a child would park in an accessible bay for disabled people? You had no right to use it. Wider Parent & Child bays are just gimmicks by retailers (not a right) but disabled bays are there to comply with the law.

Parents cannot ever use those bays unless they have a disabled person with them or they are disabled themselves.

Right…don't do that again, learn from this mistake and never repeat it. And I say that constructively and as a mother of four myself.

The two similar-looking wider bays at retail parks are not similar in any way at all.

But now the good news, and this is the silver bullet that the solicitor didn't know because they aren't specialists like we are:

You'll never pay this because two wrongs don't make a right and thankfully for you, DCB Legal & UKPC's arrangement is to discontinue defended cases just before they have to pay the hearing fee.

In your case, it'll be discontinued by the Autumn, regardless of what you put in para 3.

Abi90

https://forums.moneysavingexpert.com/discussion/comment/81904277#Comment_81904277

Thank you. Trust me, I have learnt my lesson. This will be my first only only time of doing that.

If I understand you correctly then you mean I can submit this defence as is and the outcome should still be in my favour?

Coupon-mad

Not found in anyone's favour. As I said:

In your case, it'll be discontinued by the Autumn, regardless of what you put in para 3.

Abi90

https://forums.moneysavingexpert.com/discussion/comment/81904298#Comment_81904298

So if this drags on until September, it will be discontinued? I know this sounds repetitive, I'm just looking to clarify. Thanks again

Gr1pr

Correct, its their current M.O.

Nearly 800 similar discontinuations in the tally thread by Umkomaas, have a look

Personally, I would not be altering any other paragraphs in the template defence, just 2 & 3, add your new 4 and renumber the rest up to 11 ( don't overthink this. )

If it doesn't fit , delete the last paragraph