CEL in-house Court Claim

jefstudent

Hi Everyone,

I have received a money claim from Civil national business center.

Particulars of Claim,

Claim for money relating to a parking charge for breach of contract terms/conditions(TC) for parking in private car park (CP) managed by claimant. Drivers may only park pursuant to TCs of use displayed in CP and agreed upon enty/parking. ANPR camera or manual patrols monitor vehicles entering/exiting the CP and TC breaches. Charges of £170 claimed. Violation date: 3.11.23.

Time in:22:11 Timeout:22:40

Total debt and interest due: 204.06

I have already submitted the acknowledgement of service on 11th May and need your help filing a defense. Could you please confirm the following needs to be filed as defense to civil court.

***** Defence Draft ******

DEFENCE

The facts in this defence come from the defendants own and knowledge and honest belief

for reasonable grounds to defend the claim.

“Particulars of the Claim”

1. It is admitted that the defendant is the keeper of vehicle XYZ and has attended "Car Park At ABC ”, at some point in the past; however, the claimant has failed to specify a date or time of the incident in the PoC.

2. The defendant can confirm that PCN’s have been issued but cannot confirm if they were issued on the 3.11.23, as the claimant has failed to specify a PCN number this incident relates to in the PoC.

3. The defendant denies that they breached " the sign in the car park currently says 50 minutes restricted parking for customers and the entry and exit logs provided states that the car was there for 29 minutes. "

The entrance signage provided by the claimant is not visible for any customer entering the car park driving from the North side of Daisy Lane. 

Also, the entrance signage provided by the claimant does not state where the terms and conditions can be found regarding the contract between visitor and claimant. 

The facts outlined by the defendant above put the claimant in violation of the BPA Code Of practice version 8 2020.

The only entrance signage visible and adequate was completely separate and from Half Fish stating, “This Car park is for customers only”, XXX

Therefore, the defendant denies the claim of “breach of terms”; as the defendant could not agree to the contract or be deemed to agree set out by the claimant.

“And the claimant Claims”

1. The defendant admits the original PCN was £100, but not £170. The Claimant has added a spurious £70, for “damages”, the defendant believes there is no facts or evidence to suggest so.

2.The claimant has added in an “interest rate” which is clearly an attempt to seek more funds from the defendant

Gr1pr

Presumably its an in-house CEL court claim. ? No lawyers involved. ?

Its not a fine, it was an invoice from a private parking company, CEL

If yes, edit your thread title to something more suitable like

CEL in-house Court Claim

Post the Issue date from the top right of the claim form below

No breach pleaded in the POC, so bin your draft above and use the Chan and Akande defence template, in announcements near the top of the forum ( note, no S in the word Defence. )

jefstudent

Issue Date: 06 May 2026

thanks for the correction. it was autocorrected.

Gr1pr

Set your language to UK, not USA , LOL

Coupon-mad

Just use the Template Defence (specially linked in that thread) Chan & Akande version for CEL in-house claims, and don't post it here please as we really don't need to see or check it on threads!

🙂

jefstudent

thanks,

this template i found has 42 paragraphs along with whole table of content with exhibits. Do i need to amend this whole draft as per my situation and details from the following link (UK Parking Control Ltd (Claimant) V XXX XXX (Defendant) or just submit para 3 for now and submit the whole draft when case has been allocated to small claims court. Apologies if i m complicating it as it is not easy to find the thread. I have searched for defence template and the first page thread about newbie and this is what i could find. please advise.

https://forums.moneysavingexpert.com/discussion/comment/80516020/#Comment_80516020

Gr1pr

Do not use old out of date examples from over 9 months ago, especially do not use Witness Statements

Study the template defence in announcements near the top of the forum by coupon mad

No 2026 defence is more than 10 to 12 paragraphs

No exhibits are submitted with any defence

Coupon-mad

"this template i found has 42 paragraphs"

That's odd. We explained exactly where the Chan & Akande version for CEL in-house claims is linked, twice.

jefstudent

apologiesnfor that. its because there isn't any visible link to the "announcements" section and i have to then search by entering in search box and it brings up all the related threads. anyway i seem to have landed on @Coupon-mad comment with draft of defence which i am now working on.

Quick question. in POC, CEL mentions that entry : 22:11 and exit:22:40 which is exactly 29 minutes. I had my friend take the photo of the signage and it seems either they have changed it or it was still 50 minutes free in November 2023. Plus there is no light on top for anyone to actually see the signage. My question is can i mention that in the draft defence now or later when attending the court. Please see the signage attached in this comment

jefstudent

another photo of the signage and they are not well lit at 10pm in november nights. which can be easily missed.

Gr1pr

In regards to announcements, they are just 6 important threads, above this thread of yours, permanently at the top of this forum, always available, see the forum screenshot below , and click on them to read them