UKCPS - Moorside Legal Parking Claim March 2026

Coupon-mad

URL of above article:

https://www.bbc.co.uk/news/articles/c99lezgpnk4o


Absolute entrapment zone with no double red lines and no Clearway repeater signs facing oncoming traffic on the roadway, so it isn't a properly signed no-stopping zone and no contractual agreement is possible.

Wonder how much money notoriously greedy ex-wheelclampers UKCPS have made from this chaotic mess of a site?

Xboxman02

Just a quick update as to my case, this week I have received a Notice of allocation to the small claims track & a court date has been set for 9th October 2026.

I am now in the process of following the guidance in the newbies thread re creation of the witness statement & preparation for court.

I would be grateful for some guidance on the statement, I have seen to wait until I have received the claimants statement if the timings allow & structure my defence to counter their claims, but with the help of online research I have made a start in preparation but will amend if time permits once I see the claimants witness statement.

Thanks in advance, I really do appreciate the support on here, I have gone through ups & downs in my confidence that I will successfully defend these allegations but remain hopeful.

Anything that I should significantly amend or include?

IN THE COUNTY COURT

Claim No: XXXXX

Between:

UKCPS LIMITED - Claimant

-and-

XXXXX - Defendant

WITNESS STATEMENT OF XXXX

I, XXXXX, of XXXXX I am the Defendant in these proceedings.

I make this witness statement in support of my Defence to the Claimant's claim for an alleged parking charge arising from an incident at Leeds City Station on 28 August 2025.

Unless otherwise stated, the matters set out in this statement are within my own knowledge and are true. Where I refer to information from another source, I identify that source.

A. INTRODUCTION

1. The Claimant seeks to recover £170, together with interest and court costs, alleging that my vehicle committed a contractual breach described as "No Stopping" at Leeds City Station, Leeds LS1 4DY on 28 August 2025.

2. I deny that I am liable for the sum claimed.

3. I accept that my vehicle became stationary briefly at the location shown in the Claimant's photographic evidence. I do not dispute the fact that the vehicle stopped. My evidence is that this was a very brief momentary stop while travelling through the station road system, for the purpose of dropping off a passenger.

4. The vehicle was not parked in a parking bay, was not abandoned, and I did not leave the vehicle.

5. I remained in the vehicle and the engine remained running. The vehicle was stationary for approximately 10 seconds before continuing its journey.

6. I therefore dispute that the Claimant has established that I entered into, understood or accepted a contractual term which made that momentary stop liable to a £100 parking charge, subsequently increased to the £170 now claimed.

B. THE LOCATION AND THE CIRCUMSTANCES

7. On 28 August 2025 I entered the Leeds Station area via Princes Square.

8. The relevant road layout is not a conventional private car park consisting of marked parking bays. It is a road system serving Leeds railway station, with traffic lanes, pedestrian crossings, road markings, traffic management measures and areas designated for dropping off and picking up passengers.

9. I refer to the aerial/site photograph at Exhibit IH-1, which shows the wider layout of the station.

10. I entered the area from the direction shown in Exhibit IH-1 and proceeded towards the station.

11. I stopped shortly after the zebra crossing at the location shown in the Claimant's photograph and my supporting photographs.

12. Importantly, the road surface at or immediately adjacent to the location is marked "DROP OFF".

13. I refer to Exhibit IH-2, which shows the road layout and the location of the alleged event.

14. The physical environment therefore gave the clear impression that this was part of the station's passenger drop-off arrangements rather than a conventional parking bay.

15. I stopped only momentarily to allow my passenger to leave the vehicle.

16. I did not switch off the engine.

17. I did not leave the vehicle.

18. I did not park the vehicle and remain there for any period of time.

19. After the passenger had left the vehicle, I continued driving.

C. THE STATION'S OWN SIGNAGE AND DROP-OFF ARRANGEMENTS

20. I have obtained photographs showing the signage at the approach to Leeds Station.

21. I refer to Exhibit IH-3.

22. The prominent blue Leeds Station sign expressly identifies a "Drop off point" and directs motorists towards that area.

23. The same sign separately identifies "Short Stay and Long Stay parking".

24. I refer to the enlarged version of this sign at Exhibit IH-4.

25. This distinction is important. The station signage itself differentiates between a drop-off point and parking.

26. I was following the road system towards the station and stopped briefly in circumstances consistent with the purpose of a drop-off facility.

27. I did not understand that a momentary stop in this location would constitute acceptance of a contractual £100 charge.

D. THE ROAD MARKINGS AND ABSENCE OF CLEAR STOPPING RESTRICTIONS

28. I refer to Exhibit IH-5, showing the area where the vehicle stopped.

29. At the relevant location there is no obvious conventional parking-bay arrangement. Instead, the road markings and layout form part of the station's traffic circulation system.

30. In particular, the road marking "DROP OFF" is visible in the vicinity of the alleged stopping location.

31. There are also pedestrian facilities, including a zebra crossing, immediately before the location.

32. I did not see a prominent sign immediately communicating to me that a momentary stop at that particular point would result in a £100 contractual charge.

33. Nor did I see a clear road marking at the point of stopping which communicated such a prohibition.

34. I recognise that the Claimant may now produce photographs of signs which it says were present elsewhere within the station complex.

35. However, the existence of a sign somewhere within the wider station complex does not, in my view, answer the question of whether the particular contractual prohibition relied upon by the Claimant was adequately communicated to a driver approaching and passing through this particular location.

E. THE CLAIMANT'S OWN DESCRIPTION OF THE INCIDENT

36. The Particulars of Claim state:

"The signage displayed at the site set out contractual terms and offered a contractual licence, which the Defendant accepted by parking."

37. The Particulars of Claim then state that the alleged breach was:

"No Stopping."

38. I consider there to be a significant distinction between these two matters.

39. I did not park the vehicle in the ordinary sense of that word. I briefly stopped while travelling through the road system to drop off a passenger.

40. The Claimant nevertheless relies upon the proposition that I accepted its contractual licence "by parking".

41. I do not accept that proposition.

42. The Claimant's response to my Defence also repeatedly describes the event as "parking". It states, for example:

"By entering and parking the vehicle on the Claimant's private land, the Defendant agreed to enter into a contract..."

43. The same response states:

"No motorists are permitted to park on the land at any time."

44. This does not identify the actual contractual term relied upon for the alleged No Stopping breach.

45. I respectfully ask the Court to consider the distinction between the Claimant's pleaded allegation of No Stopping and its repeated characterisation of the event as parking.

F. THE CLAIMANT MUST ESTABLISH THE CONTRACTUAL TERM RELIED UPON

46. I understand that the Claimant's case is contractual.

47. I understand that the Claimant therefore needs to establish what contractual terms were offered to me, where those terms were displayed, and that they were sufficiently communicated before or at the point at which the alleged contract was formed.

48. I am not in possession of the original Parking Charge Notice or the Notice to Keeper.

49. I have therefore not had an opportunity to examine the complete wording of the original contractual notice relied upon by the Claimant.

50. I have also not, at the time of preparing this statement, received the Claimant's full witness evidence or its complete signage evidence.

51. I therefore respectfully put the Claimant to strict proof of:

a. the precise contractual term prohibiting the conduct alleged;

b. the precise wording of the sign relied upon;

c. the location of that sign;

d. the direction from which the Defendant's vehicle approached;

e. the distance between the vehicle's approach route and the relevant sign;

f. the size, position and visibility of the relevant sign;

g. the signage actually in place on 28 August 2025;

h. the contractual basis for the £100 charge; and

i. the contractual and legal basis for the additional £70 now claimed.

G. THE IPC CODE OF PRACTICE

52. The Claimant has stated in its response to my Defence:

"The signage at this site fully complies with the IPC Code of Practice. Clear signs are displayed at the entrance and throughout the car park, making the terms and conditions visible and easy to understand for all motorists."

53. I understand that UKCPS operates under the International Parking Community (IPC) framework.

54. The Private Parking Sector Single Code of Practice applicable to private parking operators contains requirements concerning the visibility, legibility and clarity of signs and surface markings.

55. The Code requires signs and surface markings to be designed, applied and maintained so that they are visible, legible and unambiguous to drivers.

56. The Code also contains requirements concerning the positioning of signs and the opportunity for drivers to read and understand the terms.

57. I do not contend that a parking operator is required to make every sign visible from every possible position.

58. My point is narrower: the Claimant has asserted that its signage was clear and fully compliant, but it must establish this by reference to the actual signage, its location and the approach taken by the vehicle on 28 August 2025.

59. In particular, I respectfully invite the Court to consider whether a motorist travelling through the road system shown in my photographs could reasonably be expected to understand, before stopping, that a momentary stop at the location marked "DROP OFF" would amount to acceptance of a contractual £100 charge.

H. SPECIFIC ISSUE WITH A "NO STOPPING" CHARGE

60. I understand that the IPC Code contains specific provisions concerning enforcement of a prohibition on stopping.

61. I therefore ask the Claimant to produce the evidence upon which it relies to establish that the relevant No Stopping restriction was properly authorised and adequately signed at this particular location.

62. I do not ask the Court to assume that no such evidence exists. I simply say that the Claimant has asserted compliance and should produce the evidence necessary to substantiate that assertion.

I. THE STATION'S OWN DESCRIPTION OF ITS DROP-OFF FACILITIES

63. I have also examined the current information published by Network Rail concerning Leeds Station.

64. Network Rail expressly identifies a "Drop-off / Pick-up point" at Leeds Station and states that there is a drop-off and pick-up zone in Princes Square.

65. Network Rail's information also distinguishes that designated drop-off/pick-up zone from the parking provision and through road.

66. I do not rely upon the current Network Rail webpage as conclusive evidence of the exact contractual arrangement that applied on 28 August 2025.

67. I rely upon it as contextual evidence that drop-off and pick-up are an intended and recognised function of the Leeds Station traffic arrangements, and that the terminology used by the station itself distinguishes drop-off/pick-up from parking.

J. INDEPENDENT REPORTING CONCERNING THE SIGNAGE

68. I have also considered a BBC News report concerning the Leeds Station drop-off arrangements, published on 10 June 2026.

69. I do not rely upon that report as proof of exactly what signage was present on 28 August 2025.

70. I rely upon it as independent evidence concerning the continuing difficulty experienced by motorists and station users in understanding the arrangements at this location.

71. The report includes comments from motorists and station users concerning difficulties with the layout and visibility/clarity of the signage.

72. This is consistent with my own evidence that the station presents a complex traffic environment in which a motorist is required to navigate roads, pedestrian crossings, traffic management measures and competing signs and markings.

73. I refer to the BBC report at Exhibit IH-6.

K. THE PHOTOGRAPHIC EVIDENCE

74. The Claimant's photograph, which I understand was supplied with the original parking charge, shows my vehicle at the relevant location.

75. I refer to that photograph at Exhibit IH-7.

76. The photograph shows that the vehicle was positioned on the road rather than in a conventional parking bay.

77. It also shows the surrounding road layout and other vehicles using the area.

78. I accept that the photograph demonstrates that the vehicle was stationary.

79. It does not, by itself, establish that I had accepted a contractual prohibition against stopping at that location.

80. Nor does a photograph of the vehicle establish that the terms relied upon by the Claimant were adequately communicated to me before I stopped.

L. THE £170 CLAIM

81. The Particulars of Claim seek:

• £170 as the total parking charge;
• court fees and costs; and
• interest under section 69 of the County Courts Act 1984.

82. The Claimant's response to my Defence states that the original parking charge was increased by £70 and asserts that the £70 is permitted by the BPA and IPC Codes.

83. I understand that the relevant Code permits an additional sum of up to £70 in certain circumstances. I do not therefore suggest that the IPC Code simply prohibits an additional £70 in every case.

84. However, permission within an industry code to add a sum does not, by itself, establish that the Claimant has a contractual entitlement to recover that sum from me.

85. I therefore put the Claimant to proof of the contractual term which allegedly entitled it to add £70 to the original charge and the circumstances in which that term became binding upon me.

86. The Claimant's own response states that the £70 does not represent the cost of recovery but is instead intended to encourage early payment.

87. I respectfully ask the Court to consider whether the Claimant has established a contractual and legal basis for recovering that additional sum in the circumstances of this case.

M. CONSUMER RIGHTS ACT 2015

88. I understand that the Consumer Rights Act 2015 applies to consumer contracts and consumer notices and requires terms and notices to satisfy statutory requirements concerning fairness and transparency. The legislation includes specific provisions concerning fairness, transparency and the Court's consideration of fairness.

89. The Competition and Markets Authority guidance also explains that consumer terms and notices should be transparent, easy to understand and sufficiently prominent where they have a significant effect upon the consumer.

90. I respectfully submit that these principles are relevant when considering a purported contractual term which seeks to impose a £100 charge upon a motorist for a momentary stop in an area physically marked "DROP OFF".

N. PARKINGEYE v BEAVIS

91. I understand that the Claimant may rely upon the Supreme Court decision in ParkingEye Ltd v Beavis [2015] UKSC 67.

92. I do not dispute the general principle that a private parking charge can, in appropriate circumstances, be enforceable even where it does not represent the operator's actual financial loss.

93. However, I understand that the decision in Beavis turned in significant part upon the particular circumstances of that case, including the clear and prominent signage and the legitimate interests associated with the parking scheme. The Supreme Court's judgment records the importance of the contractual terms displayed on the signs.

94. My case is materially different on the facts.

95. I was not overstaying a permitted parking period.

96. I was not occupying a parking bay.

97. I was not leaving a vehicle parked while attending the station.

98. I was travelling through the station road system and briefly stopped to drop off a passenger.

99. The location was marked "DROP OFF", and the station's own signage identifies a drop-off point separately from parking.

100. Accordingly, the central issue in my case is whether the Claimant has established that a sufficiently clear and prominent contractual prohibition against stopping was communicated to me at the relevant point.

O. THE ABSENCE OF THE ORIGINAL NOTICE TO KEEPER

101. I have not retained, and currently do not have, the original Parking Charge Notice or Notice to Keeper.

102. I have therefore been unable to verify the precise wording, contractual terms, dates, statutory basis or other information contained within the original notice.

103. The Particulars of Claim state that I am liable as the driver and/or keeper and alternatively pursuant to Schedule 4 of the Protection of Freedoms Act 2012.

104. I ask the Claimant to establish the basis upon which it relies for keeper liability, if it seeks to rely upon it.

105. I do not ask the Court to infer that the Claimant cannot establish keeper liability merely because I do not presently have the Notice to Keeper. I simply ask that the Claimant produce the document upon which it relies.

P. LANDOWNER AUTHORITY

106. The Particulars of Claim state that:

"The Claimant has authority to operate the site and issue charges."

107. I have not been provided with the Claimant's contract or other evidence establishing its authority from the landowner.

108. I therefore put the Claimant to proof of its authority to:

a. operate at the precise location where my vehicle stopped;

b. impose the particular contractual terms relied upon;

c. issue parking charges for stopping at that location;

d. pursue those charges in its own name; and

e. recover the additional £70 now claimed.

Q. CONCLUSION

109. I accept that my vehicle stopped briefly at the location shown in the Claimant's photograph.

110. I do not accept that the Claimant has established that I entered into a contract imposing a £100 charge for doing so.

111. I do not accept that circumstances existed for a contractual offer, review and acceptance was provided.

112. The circumstances were a brief passenger drop-off, not conventional parking.

113. The vehicle remained occupied and the engine remained running.

114. The vehicle was not left unattended and did not occupy a parking bay.

115. The location was part of the station road system and the road surface itself was marked "DROP OFF".

116. The station's own signage distinguishes a drop-off point from parking.

117. I did not see a sufficiently prominent and unambiguous contractual notice at the relevant location informing me that this momentary stop was prohibited and would result in a £100 charge.

118. The Claimant has nevertheless repeatedly described the incident as "parking", despite pleading the alleged breach as "No Stopping".

119. I respectfully submit that the Claimant must prove the contractual basis for the alleged liability rather than relying upon the mere existence of signs somewhere within the wider station complex.

120. For those reasons, and subject to the Claimant establishing the matters put to strict proof above, I respectfully invite the Court to dismiss the claim.

121. If the Claimant's evidence subsequently establishes that the alleged signage or contractual arrangements were materially different from those presently apparent from the evidence available to me, I reserve the right to address that evidence as permitted by the Court.

STATEMENT OF TRUTH

I believe that the facts stated in this witness statement are true. I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth.

Signed: ___________________________

XXXXXXX

Date: ___________________________

Exhibit	Evidence
IH-1	Aerial overview of Leeds Station showing route into Princes Square and stopping location
IH-2	Station/road overview showing the stopping location
IH-3	Photograph of Leeds Station entrance signage
IH-4	Enlarged photograph of the "Drop off point" / parking sign
IH-5	Photograph of the stopping location showing road markings and surrounding signage
IH-6	BBC News article concerning Leeds Station drop-off/signage
IH-7	UKCPS photograph of alleged breach
IH-8	Network Rail information concerning Leeds Station drop-off/pick-up arrangements
IH-9	Particulars of Claim
IH-10	Moorside Legal response to Defence

Gr1pr

Edit Out your name above

When is the hearing fee deadline date. ?

When is the WS deadline date. ?

Bear in mind that Moorside Legal are likely to discontinue the case

Xboxman02

Thanks for the heads up on that @Gr1pr

I thought I had redacted all the personal stuff, clearly missed that one 😶

The hearing fee deadline date is set as 18th September, the letter suggests that is paid by the claimant, so I have nothing to do here, is that correct?

The WS date is set as having "arrived by 4pm 21 calendar days before the hearing" so I calculate that to also be 18th September, which is the same as the hearing fee date.

Looking at the guidance it appears that I have to send the statement to the court at The Courthouse, 1 Oxford Row, Leeds, LS1 3BG, addressed to the Court Manager & quoting the claim number, do I send that recorded delivery, or is there an eMail address that can be used I wonder?

Thanks

Gr1pr

If they are the same deadline, then ensure that you get it in just before the hearing fee deadline, IF they have not sent you an N279 discontinuation document by email

Your WS should be under 50 pages, saved as a pdf and emailed to both Moorside Legal and to the court too ( so email these days. )

BTW, There Is no such service as "recorded delivery " , lol. !

Coupon-mad

The WS sounds a bit too repetitive and reads like it was written by the hand of AI. It is too much 'story and opinion'.

I did only skim-read but saw:

• none of the usual exhibits recommended in the NEWBIES thread post 2 for WS stage;
• no mention of HHJ Moloney's judgment in Beavis and it's not one of your exhibits unless I missed it;
• no mention (that I saw) of a lack of double red lines and repeater signs and no link to the Henry Greenslade POPLA Annual Report about what a no-stopping zone must look like;
• no mention of what looks like illegal covert surveillance (because the camera is not overt or prominent and there's (probably?) no GDPR entrance sign about surveillance and how data will be used & why;
• no costs assessment?

This bit needs removing as you were the driver so none of this matters:

"103. The Particulars of Claim state that I am liable as the driver and/or keeper and alternatively pursuant to Schedule 4 of the Protection of Freedoms Act 2012.

104. I ask the Claimant to establish the basis upon which it relies for keeper liability, if it seeks to rely upon it.

105. I do not ask the Court to infer that the Claimant cannot establish keeper liability merely because I do not presently have the Notice to Keeper. I simply ask that the Claimant produce the document upon which it relies."

And if you had this sentence in your defence, which I see you were planning to put, at that point:

"3. Upon discussing the situation with the driver, the defendant was told: "

…it's extremely odd to now write a witness statement as driver. Should have chosen one stance or the other.

Xboxman02

Thanks @Coupon-mad

I appreciate any feedback that will help strengthen the case.

The newbies thread does state that the witness statement is "your story & evidence" maybe I took that too literally (Im totally new to this kind of thing 😜)

I will run back through in line with your feedback & make some edits.

I will include my costs assessment but didnt figure it relevant here but thanks for the reminder to include it with the submission.

I was the driver, but just figured anything that adds to the complexity & effort for the claimant is a good thing as could influence their decision to discontinue.

1505grandad

"61. I therefore ask the Claimant to produce the evidence upon which it relies to establish that the relevant No Stopping restriction was properly authorised and adequately signed at this particular location."

A suggestion - perhaps continue the above sentence with:-

and that "common sense was applied to the circumstances" in accordance with the NOTE relating to para F2.3 of The ppssCoP.

FYI the above is stated in:-

https://www.britishparking.co.uk/write/Documents/AOS/Sector%20Code%20Templates/sectorsingleCodeofPracticeVersion1.1130426-2.pdf

Xboxman02

Thank you @1505grandad I have added a note & link to that in #61.

Thank you @Coupon-mad re

And if you had this sentence in your defence, which I see you were planning to put, at that point:

"3. Upon discussing the situation with the driver, the defendant was told: "

…it's extremely odd to now write a witness statement as driver. Should have chosen one stance or the other.

Excellent point, I did include that in the defence as suggested in one of your earlier posts, so I will defo update that, as a man who gets advice but takes no notice is no better off than a man who has no advice 😆

I was the driver so should I just remove the mentioned sections or should I reword the WS to be from the perspective as not to identify myself as the driver best I can.

With respect to the usual exhibits;

(a) a copy of the Beavis case sign as a comparison to show how awful the small print sign was in yours case (see Google images - it's yellow and black) - I didnt have a sign image to compare against, however I have been back to the station today almost 1 full year after the alleged offence & there is a small unilluminated sign (which I dont think was present at the time of my original visit) but that has no T&C information on it & its almost totally illegible from while in the car driving, should I include this & the Beavis sign?

(b) photos proving the scarce/illegible small print signs & a view showing the lack of entrance signs, etc. and maybe a video of how it looks from a car? Get a passenger to hold a camera or phone to prove the lack of signs in similar light conditions. - I now have an image, the square on the left is where I stopped, there is now a sign but its small & does have any T&Cs, do I include that?

(c). If the Claim form did not specify the term breached, include the strike out orders shown here in a link to CEL v Chan and similar case 'strike out' Judgments from all over the English courts: - It did state the breach as no stopping so N/A

(d) if you are relying on a 'no keeper liability' argument, include a URL to Schedule 4 of the POFA and also exhibit the transcripts of Excel v Smith and VCS v Edward (search the forum!). - Its not central to my defence, but will search & find something

(e) a copy of your lease or tenancy agreement if this is an 'own space' dispute where YOU have primacy of contract. - N/A

(f) other case transcripts that support your defence, e.g. if arguing that this is a residential space where the tenant/leaseholder has already been granted the right to park or unload, you need Jopson v HomeGuard (appeal) and PACE v Mr N, etc. - N/A

(g) the IPC or BPA Code of practice, where it supports your case (e.g. grace periods); - I will include this to support #60 along with the POPLA annual report re what a no stopping area should look like, which years report is the most appropriate to reference?

(h) Pay & Display ticket, if the driver paid. DON'T argue 'no loss'-N/A

(i) paras 98, 193 and 198 from Parking Eye v Beavis copied & pasted onto a single sheet. - Found it & will add.

I will add the updated WS once I have had chance to rework & add the additional elements to it.

Thanks again all.

Xboxman02

ANOTHER ONE BITES THE DUST!!!!

Letter of discontinuance from Moorside Legal this morning…

I am relieved being totally honest, its a bit of a stress having never done anything like this before, trying to prepare for everything & following an unfamiliar process with its complexities of language & protocol, but I am glad I held firm & for the guidance on the forum.

The private car parking scam is disgusting behaviour, that someone can just claim something from you on no genuine grounds & then put you through everything that follows & then just walk away with no repercussions..

I do wonder why they allowed the WS packs to be sent & then cancelled, do they do it just to cause people stress & anxiety as nothing is gained from cancelling afterwards Vs before?

Thanks to @Coupon-mad in particular & everyone else who helped along the way 😁