Multiple CEL PCNs, need help writing defence

fluffyginger123

Hi all,

Thank you for all of the information on the newbies thread. I recently received the claim form relating to a PCN brought by Civil Enforcement Limited. Issue date 17 July. I submitted my AoS on 26 July. I believe this sets the hard deadline for my defence of 18 August.

Summary to date:

I have been receiving LBAs from CEL relating to four PCNs, all dating to October 2024 for parking at Hartham Leisure Centre car park. This all got slightly confusing because it was just after I moved house but before I updated things with the DVLA, meaning I never received some of the initial letters. So I'm not sure exactly what the initial correspondence was. Anyway, I'm getting all the letters now and have confirmed my address with them.

The reason this feels relevant here is that the CEL documentation refers to 'incidents' on four separate dates, but with only two unique PCN numbers, which seems like an error on their end:

• 14 and 22 October = same PCN number
• 10 and 20 October = same PCN number

Obviously they are trying to claim £170 for each (+ fees on the claim form).

Each time, it was because apparently I did not input my car registration details on the screen inside the leisure centre. I can't remember exactly but I think they mentioned this in their earlier letters. Tese 'incidents' were just after I started going to the leisure centre (I can confirm I was a paying member), so maybe it took me a few trips to realise I needed to register my car, but I can't really remember. I have previously sent letters to CEL explaining this, and the discrepancy with the PCN numbers (probably wrong of me, but before I found this thread).

So now I have received the claim form relating to just one of the PCNs (14 October), with the standard generic CEL PoC - i.e. it doesn't say anything about not inputting car registration details on the terminal in the leisure centre, it just says "Parked in breach of the terms notified on the signage at the car park".

I've tried contacting the leisure centre but had no luck.

Questions:

My main concern about this is if I respond to it as a standalone single PCN I might then get 3 more claims for the other PCNs. Then if I lose, that's over £1,000 to pay, which I don't have.

So, firstly, how do I deal with the multiple PCNs? Do I mention that this claim shares a PCN number with another 'incident'? Or do I just have to treat it in isolation and hope the others don't come through?

Secondly, should I still use the standard defence template with CEL vs Chan and CPMS vs Akande, meaning I don't say anything about the requirement to input registration details on the indoor terminal, even though I have mentioned (possibly admitted forgetting to do?) this in my letters to them? Obviously the grievance is that I was already paying to be a member there and want to get that in the defence, but I'm not sure that's the right thing here.

Thank you in advance!

Gr1pr

Deal with whats in front of you

Deal with any other similar cases under estoppel, Henderson vs Henderson, all the outstanding invoices should have been in the single claim

Use the Chan and Akande defence template, as is

Le_Kirk

With an issue date of 17/07/26 and having completed the AoS in a timely manner your defence deadline date is 4.00 p.m. on 19/08/26

Coupon-mad

Show us the POC.

Is it a DCB Legal claim for CEL?

fluffyginger123

Here's the PoC. The claim form lists CEL as the claimant and address, no mention of DCBL. My last letter from DCBL was March 2025 'notice of debt recovery' and 'notice of intended legal action' (I have these for two of the PCNs including the one related to the current claim, but not for the 'duplicate' 20th and 22nd Oct PCNs). More recently I've just been getting LBAs directly from CEL and have an LBA for each of the four dates

Gr1pr

No breach pleaded, use the Chan and Akande defence template

Castle

There's a PC Ref still showing.

Coupon-mad

Search the forum for Leagrave and copy that CEL defence from last week.

fluffyginger123

Thanks so much for the help. I found the Leagrave thread and I'm planning to use almost the same defence, just with a few changes because I can't currently find the NTK relating to this PCN:

• In point 2: keeping the phrase "The delay in bringing proceedings lies with the Claimant, making retrieving material evidence difficult, which is highly prejudicial" (22 months ago now!)
• And in point 2 admitting "and driver" because I believe I have essentially admitted this in earlier 'reply forms' to CEL. I'm wondering if I should also remove the phrase about having "little knowledge of events" because I have also previously mentioned some specifics of the 'breach' in reply forms to CEL, stating "Any requirement to input vehicle registration details on a terminal inside the leisure centre was not sufficiently or clearly signposted at the time of the alleged incident. This requirement was later remedied by the installation of prominent signage near the registration terminal within a few months of this alleged incident, which supports that the original signage was inadequate." - so I just want to write point 2 in a way that avoids them being able to use this against me to show that in reality I do know the specifics even if they didn't specify them in the POC.
• Changing 10.1.2 to just refer to the POC, not the NTK: "10.1.2. The same criticism - a failure to provide material information - can also be made of the POC, which fails to describe the circumstances in which the requirement to pay the parking charges arose or to particularise the alleged breach."

Coupon-mad

All sounds great!