UKCPS invoice - started court claims

codan84

So, my wife went to a Dental Surgery (NHS) a while ago. There's a private parking there with bays allocated to specific businesses, operated by UKCPS. The signage is hard to see but it is there, fair enough. The thing is - all bays for the Dental Surgery were taken, so she parked in another bay. the bay she parked in was allocated to a takeaway that at the time was closed, did not have any customers or anyone parked in their bays. she occupied a bay for that business for about 30 minutes, no other bays for that particular business were occupied nor anyone needed any of these bays (business was closed, it was ~9am). So - she did not inconvenience anyone nor stopped anyone from using this car park.

Then few days later - "invoice" from UKCPS. I responded right away disputing it on the above grounds (we did not inconvenience anyone, stopped the car park from operating efficiently nor caused loss of revenue to any businesses on the property), dispute denied (obviously). Went to IAS but obviously they said invoice is "lawful" because there is signage, and that's all they do - they do not apply "common sense".

Last contact from their "solicitors" (Trace Debt Recovery) was 10 September 2025, just another letter to scare me into paying. I disputed with them too, never left a letter unanswered.

Today - Claim form from a Court. BUT - no Letter of Claim / Letter Before Claim! So I filled in online AoS. I ticked that I dispute the whole claim. But where do I take it from here? What should I fill in in my defense? How do I let the Court know that the claimant did not follow proper Pre-Action Protocol?

My defense is - yes there might have been signage, but if the claimant argues the rules are there "for efficient parking usage", then their claim is void, as my wife's parking did not disrupt the usage of the parking.

I'd appreciate any advise, especially if someone went through this already.

Nellymoser

Is the claim form in your name?

Post picture of the claim form redact all personal info your name address, reg no, claim ref no and password.

Give date AOS completed.

Look at the first two posts in the Template defence thread pinned at top of page 1.

codan84

Yes the claim is in my name, as a registered keeper.

AOS completed on 20/03/2026.

I will read what you have advised.

Also, might be worth adding - businesses on the premises started putting hand-written notes on their door reminding people to park in allocated bays. This indicates to me that:

1. this is a systematic issue
2. signage is clearly not obvious enough (it is small and only in 3 places, I'd expect each bay to be marked with business name it is allocated to)
3. parking operator is not doing anything to improve the situation, just handing out tickets

Coupon-mad

Have you still got the UKCPS PCN they posted last year? Show us both sides.

Here's the Claim form without your name:

codan84

I do have the original letter, I kept all correspondence I got from them, just in case.

Coupon-mad

OK I was just checking if there was an extra defence point to add about lack of keeper liability but that is compliant.

So, just use the Template Defence with para 2 edited at the end to say the Defendant was the registered keeper but not the driver.

And para 3 should respond to the accusation and talk about the tiny signs and lack of delineation of spaces within the shared car park and lack of clarity about which bays were for which customers. And that the Defendant disputed the charge throughout and never left a letter unanswered, only to be met with template AI fob-off replies.

Car1980

No entrance signage, no signage near the numbered bays, no clear demarcation between the businesses. Tiny, apologetic sign on the wall on the right. Totally inadequate to form a contract.

Classic entrapment site. You could make this setup crystal clear, but that would result in no profit for UKCPS.

Castle

The Claimant is claiming interest from 13th May 2025 even though the NTK is dated 22nd April and was not deemed received until 24th April. Therefore, they have transferred Keeper Liability 10 days early.

Coupon-mad

https://forums.moneysavingexpert.com/discussion/comment/81932363#Comment_81932363

Good point.

tbu271

The name and address of site on the NTK isn't even correct. Upper Warrengate Car Park is next door!

codan84

Should I be pointing all of these out in my point 3 of defense?