Defence check - UK Parking Control Ltd

Coupon-mad · 21 September at 1:17PM

I like that bespoke defence as it does cover everything but I feel you should:

add a bit more to para 3 to point out that whilst a Blue Badge is just one indicator of disability need, it has no statutory application on private land, unlike the Equality Act 2010 which does, and the law would supersede contractual terms at the bay, if there were any;
add an extra para that avers that the Defendant believes there were, at the material time, no full t&cs signs at or immediately adjacent to the accessible bays. This omission not only breaches the mandatory requirements of the industry Code of Practice but means there was no contract capable of binding the Defendant to any relevant obligation or to pay any sum at all, in what was advertised at the entrance as a free retail car park;
add a point that the ticketing was predatory and unfair. The photos taken by UKPC's lurking operative were merely xx seconds apart and the Defendant reasonably believes that person must have observed him assisting the passenger with their wheelchair. As such, the Defendant requires the ticketer to provide a witness statement and to appear at the hearing. The Defendant wishes to cross-examine the ticket-issuer to explain what they observed, how they justify their hasty ticketing of a vehicle that was clearly being used to assist a disabled passenger into premises and to confirm to the court whether or not UKPC trained them in the Equality Act 2010 as it relates to Services and Public Functions, and whether they were also trained in the applicable Code of Practice.