UKPC- no bay lines seen

Notwobbly

Hi,

The car was parked in a retail car park in London. UKPC claim that the car wasn't parked in the bay. The photos don't show any bay line being crossed but UKPC claim that the vehicle blocked such lines, so the photos don't show it. In the POPLA appeal, UKPC uploaded random photos of some other signs and also map of another car park to claim the bays were there. Very deceitful.

I went through the various appeals stages, and all rejected. I've receive a court claim from DCB, have already acknowledged service as the forum guide mentions.

I'm filling the MCOL defence, a bit detailed but within the 122 limit. It focuses on the sign being far and no photo evidence of crossing a line. Any tips or suggestions for this specific case? I need to submit it by Monday.

Thank you

Gr1pr

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

Post a redacted picture of the POC from the lower left of the claim form below after hiding the VRM details first

Adapt the 10 paragraph template defence in announcements, and post your proposed paragraphs 2 & 3 below

Notwobbly

Thank you for that. Issue date was 21 Sep 26 and I acknowledge service around 23 Sep but need to submit by Monday since I plan to be away after that. I've attached the form photo.

Thank you.

Notwobbly

Also, I received the final reminder so long after the actual parking, that I can't remember if any bay marking existed or even was crossed. Looking at the pictures, it doesn't show any crossing.

Gr1pr

I suggest that you start again by using the 10 paragraph template defence at the top of the forum, adapting paragraph 2 & 3 only , to suit

Please also note, the following characters are not allowed on MCOL. " < > " " " " , especially not the " in your own draft ( your paragraph 2 )

Post your proposed paragraphs 2. & 3 below after adapting them

Ps, your paragraph 1 can form the basis of the replacement paragraph 3

Notwobbly

Thank you. I've now generally adopted the 10 paragraphs.

Paragraph 3 is:

"It is neither admitted nor denied that any breach of contract, or contravention, occurred. The Claimant's own photographic evidence appears to show the vehicle parked wholly within marked bays, with no part shown crossing any boundary line and no evidence of obstruction. Any suggestion that the relevant bay line is merely obscured by the vehicle is speculation and does not discharge the burden of proof, which rests with the Claimant to prove a clear contravention with positive evidence. The Claimant's attendant could readily have photographed the empty bay once the vehicle departed or even whilst the vehicle was parked through a different angle to resolve this; no such photograph has been produced, and an adverse inference should be drawn from that omission. As such, there is no photograph showing any wheel or bodywork crossing a bay boundary. The Claimant's own evidence pack, including the site plan and aerial imagery relied upon (including that produced at the POPLA appeal stage), does not correspond to the actual site that contains the store Currys and where the vehicle was parked. The Claimant’s evidence pack depicts retail units and a layout that are not and were not present there. No date is provided for the aerial image, and it does not show the condition, clarity, or visibility of the bay markings on the date of the alleged event (09/11/2025). These aerial images do not demonstrate whether markings were clearly visible at ground level, nor whether they were worn, faded, or obscured at the time. Such images are therefore incapable of proving that a clear and enforceable bay boundary existed on the material date. "

I also edited para 4 to include that the signage UKPC relied on is quite far. And I edited para 8 to argue that I asked for proof of postage for NTK and they never provided it.

Gr1pr

Your paragraph 3 starts and ends with " which is not allowed on MCOL, so delete them , they are both unnecessary

As for paragraphs 4 & 8 , I hope that you used words like , the driver , or , the defendant, not I asked for proof of postage, because the words I , Me , My etc aren't in a defence statement, especially not I

Le_Kirk

With an issue date of 21/09/26 and having completed the AoS in a timely manner your defence deadline date is 4.00 p.m. on 26/10/26

Car1980

I'd counterclaim if they had submitted false photos at Popla. Claim your time appealing at Popla e.g. 4 hours @ £24 = £96.

DCB Legal will be terrified and pay up.

Don't use the word "fraud" but imply it.

Would cost you £35, which you would get back.