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Live cases legal advice => Private parking tickets => Topic started by: settop23 on March 08, 2026, 04:00:12 pm

Title: Re: Hearing set for parking charge by car park management services LTD
Post by: DWMB2 on March 25, 2026, 07:43:52 pm: The OP's case is over. I'm not sure why you're mentioning things that should have been in his defence when it is clear the one he submitted was successful.
Title: Re: Hearing set for parking charge by car park management services LTD
Post by: S.M on March 25, 2026, 07:25:15 pm: Quote from: DWMB2 on March 25, 2026, 11:12:02 am
The claim has been dismissed, the OP has won. No need to get into a technical discussion about Mazur if the judge agrees that the claimant has not proven their claim.

Shouldn't that be included in the defence? I'm thinking that we should make our case as strong as possible in case there's a judge that doesn't see eye to eye with us. At least with a technicality he/she won't be able to say no.
I'd also argue this needs to be the last line of defense.
Title: Re: Hearing set for parking charge by car park management services LTD
Post by: DWMB2 on March 25, 2026, 01:05:52 pm: Quote from: InterCity125 on March 25, 2026, 12:45:13 pm
1) No need for a massive 18 page Witness Statement when one or two pages will do - each point clearly and concisely set out and presented in a manner which makes very easy reading for the Judge in the short period of time running up to the hearing.
This is true of most correspondence, but I particularly agree when it comes to court. With how many cases there are in the County Court, it's best to work on the assumption that the judge will (at best) have skim-read any submissions. On that basis, make something that's easy to skim.
Title: Re: Hearing set for parking charge by car park management services LTD
Post by: InterCity125 on March 25, 2026, 12:45:13 pm: For me, this case clearly illustrates a number of 'simple things';

1) No need for a massive 18 page Witness Statement when one or two pages will do - each point clearly and concisely set out and presented in a manner which makes very easy reading for the Judge in the short period of time running up to the hearing.

2) Paralegals clearly lack the skill and application when presenting evidence in Court documents - in this instance so many doors were left open - it was only a matter of time before the Judge seized upon one of them.

3) In this particular case, the input of the group presented the Judge with at least five or six reasons to kick the claim into touch - in my opinion, the Judge simply chose the non-evidence of signage / vehicle position as he or she felt it was easiest to demonstrate and therefore the best method to wrap the hearing up quickly and efficiently.

Well done.
Title: Re: Hearing set for parking charge by car park management services LTD
Post by: DWMB2 on March 25, 2026, 11:12:02 am: The claim has been dismissed, the OP has won. No need to get into a technical discussion about Mazur if the judge agrees that the claimant has not proven their claim.
Title: Re: Hearing set for parking charge by car park management services LTD
Post by: S.M on March 25, 2026, 11:03:05 am: Quote from: DWMB2 on March 25, 2026, 10:47:50 am
Quote from: settop23 on March 25, 2026, 10:32:58 am
I am self employed so what proof would I need to provide to claim?
The time to ask would have been after the judge made clear their claim had failed - apologies, I completely forgot to mention this when advising on the hearing.

In this particular case as the witness statement was drafted by a paralegal couldn't the OP use the Mazur argument?
Wouldn't that dismiss the case entirely? (Sorry if that sounds as a noob)
Title: Re: Hearing set for parking charge by car park management services LTD
Post by: DWMB2 on March 25, 2026, 10:47:50 am: Quote from: settop23 on March 25, 2026, 10:32:58 am
I am self employed so what proof would I need to provide to claim?
The time to ask would have been after the judge made clear their claim had failed - apologies, I completely forgot to mention this when advising on the hearing.
Title: Re: Hearing set for parking charge by car park management services LTD
Post by: settop23 on March 25, 2026, 10:32:58 am: I did mention to the claimants side before we went in that I had to take the afternoon off work to attend (and pay an outrageous £12 to park for a couple of hours!)

Nothing was mentioned about a counterclaim or claiming for loss of earnings to attend. I am self employed so what proof would I need to provide to claim?
Title: Re: Hearing set for parking charge by car park management services LTD
Post by: DWMB2 on March 25, 2026, 10:18:32 am: Excellent news - thank you for the update, and well done - even when you're prepared, going to court for the first time can be nerve-wracking. Also good to see you got a good judge who did things the right way round - no need to hear from the defendant if the claimant can't prove their case to start with!

Did you get your costs for loss of earnings for attending (capped at £95)?
Title: Re: Hearing set for parking charge by car park management services LTD
Post by: settop23 on March 25, 2026, 10:04:13 am: I attended the hearing and arrived 30 mins early. The claimants representative was already there, it seemed to be somebody qualified and not the paralegal 'under supervision' from BW Legal.

We went into the court and the judge listened to the claimants argument first. The judge asked the claimant about the signage and where the signage was in relation to where the vehicle was parked - the claimant struggled to provide an answer and eventually admitted she did not have that information with her, only a seperate picture of the signage and pictures of my vehicle.

The judge then turned to me and told me 'Good news, as the claimant cannot prove their case it is dismissed!'

A great result and a huge thank you to DWMB2, Intercity and andy_foster for all the help - I certainly would not have been able to do it without you and I have learnt some things as opposed to blindly paying hundreds of pounds to line the pockets of chancers.
Title: Re: Hearing set for parking charge by car park management services LTD
Post by: DWMB2 on March 23, 2026, 03:10:00 pm: Quote from: settop23 on March 23, 2026, 02:35:34 pm
Any other pointers and tips would be appreciated as it is my first time attending court to defend a claim.
One thing to remember is to try and relax - the stakes are (comparatively) quite low, and whilst it's new to you, for the judge and the other side's representative, it's just another day at work. Remaining calm and sticking to the facts will make your case easier to follow. Don't flog a dead horse - if the judge clearly isn't buying one of your arguments, don't put his nose out of joint by trying to educate him on the law, feel free to move on to other points.

If it were me, as already noted, I'd probably have made the "prohibitive signage" point my main argument (which would probably mean I'd have put it higher in my WS than paragraph 14 out of 17, but that is your choice). PoFA is irrelevant if no contract existed in the first place, as there is no liability to transfer. If the judge has read the whole thing, he'll hopefully notice this.

Quote from: settop23 on March 23, 2026, 02:35:34 pm
If the other party does not turn up, will the case still be looked at or will I automatically win?
27.9 of the Civil Procedure Rules (https://www.justice.gov.uk/courts/procedure-rules/civil/rules/part27#27.9) is relevant here:

(2) If a claimant does not –

(a) attend the hearing; and

(b) give the notice referred to in paragraph (1),

the court may strike out the claim.
Title: Re: Hearing set for parking charge by car park management services LTD
Post by: settop23 on March 23, 2026, 02:35:34 pm: The case is listed for tommorow. Thank you for the advice so far, and I plan on taking 3 copies of everything, the claimants WS and evidence along with the VCS Ltd V Edward case.

As advised, I will mainly try to argue point 14 in my skeleton argument: that the signage at the location is prohibitive in nature and does not form a contract as there was no offer of valuable consideration.

Any other pointers and tips would be appreciated as it is my first time attending court to defend a claim. If the other party does not turn up, will the case still be looked at or will I automatically win?
Title: Re: Hearing set for parking charge by car park management services LTD
Post by: InterCity125 on March 17, 2026, 01:45:23 pm: I would download and print out three copies of VCS Ltd v Edward from the following location.

https://www.dropbox.com/scl/fi/w0k19zxzlpf9eumu68u7b/VCS-v-EDWARDS-Transcript.pdf?rlkey=5t2gilebrjx7g0d6jmy32lou4&e=2&dl=0

We are deliberately including this in case the Claimant attempts to claim that the keeper was the driver under reasonable assumption - also that there is no legal requirement for the Defendant to reveal who the driver was.
Title: Re: Hearing set for parking charge by car park management services LTD
Post by: DWMB2 on March 17, 2026, 11:34:04 am: I generally take 3 copies of anything I might wish to rely on/refer to during the hearing - your defence, witness statement etc.

One copy for you, one for the claimant's representative, and one for the judge. The other 2 parties should already have copies of everything, but if you have your own copies available, it hopefully prevents it being an issue if one party claims not to have a copy of something.

I would make sure you have a copy of the claimant's WS and particulars etc. so that you have them to hand as well.
Title: Re: Hearing set for parking charge by car park management services LTD
Post by: settop23 on March 17, 2026, 11:10:30 am: I have sent the PDF to the above emails today. I did not include any extra points as I think the points included already are sufficient

Should I take both my skeletoon argument and the evidence from the claimant with me to court? Is there any other advice as it is the first time I am attending court
Title: Re: Hearing set for parking charge by car park management services LTD
Post by: settop23 on March 16, 2026, 12:06:46 pm: I have amended the WS and included the points from Intercity, thank you again.

in your opinion DWMB2 and Andy, should I add anything about Mazur or anything else or is this okay to submit?

I believe I need to save it as a PDF and email it to manchestercivil@justice.gov.uk and include the date & time of hearing and case number in the email? Do I need to include anything else. I will also send it to info@cpmsmanchester.com
Title: Re: Hearing set for parking charge by car park management services LTD
Post by: DWMB2 on March 16, 2026, 10:54:49 am: Quote from: andy_foster on March 16, 2026, 10:50:31 am
they are often very reluctant to tear up the draft and start again, or accept that their provisional decision was wrong.
This is a very good point - it's fairly common to hear of people who have gone to a hearing, and have come away (win or lose) having had almost nothing to say.
Title: Re: Hearing set for parking charge by car park management services LTD
Post by: andy_foster on March 16, 2026, 10:50:31 am: There are essentially 2 different points to consider.

Technically it is entirely appropriate to expand upon a point raised by the other party.

However, District Judges (including the more common Deputy District Judges) often like to make a provisional decision based on the papers, prior to the hearing, subject to minor tweaking for minor details likely to emerge during the hearing. Once they have their draft judgment, and have indicated where they are provisionally going, they are often very reluctant to tear up the draft and start again, or accept that their provisional decision was wrong.
Title: Re: Hearing set for parking charge by car park management services LTD
Post by: DWMB2 on March 16, 2026, 10:43:43 am: Quote from: InterCity125 on March 16, 2026, 07:28:01 am
In fact, there's some evidence in the Claimant's WS which could further help you at a hearing but that doesn't need to be revealed to the Court at this stage.
Be careful that any such arguments don't amount to new arguments that could be seen as an ambush in the eyes of the judge.
Title: Re: Hearing set for parking charge by car park management services LTD
Post by: InterCity125 on March 16, 2026, 07:28:01 am: I added point 17 which I think is relevant and not covered off in the Claimant's WS.

In fact, there's some evidence in the Claimant's WS which could further help you at a hearing but that doesn't need to be revealed to the Court at this stage.
Title: Re: Hearing set for parking charge by car park management services LTD
Post by: settop23 on March 16, 2026, 05:07:51 am: Thank you so much! I will amend it and the prohibitive signage now makes much more sense to me after your explanation Andy, so I am confident I will be able
To expand on this argument in court if needed

I will amend my WS and change it to a skeleton argument and submit it today. Is it sufficient to send it as a PDF via email to the court and the claimant, and include the case number in the subject?

The only point not included in the skeleton argument is that the claimant is using an unauthorised person as demonstrated in mazur. Is this a point you recommend I leave out for now and raise it at court? Will I have the option to do this if it is not in the skeleton argument?
Title: Re: Hearing set for parking charge by car park management services LTD
Post by: InterCity125 on March 15, 2026, 09:35:57 pm: Your defence was too brief and doesn't flow.

I've sexed it up a bit.

Your first two points are fine.

Feel free to use this if you feel it helps;

3. It is accepted that I was the Registered Keeper of the vehicle in question at the material time.

4. All my evidence is presented as the Registered Keeper.

5. The driver is not known to the Claimant and, as this is a contract dispute, I will not be providing any driver details since the law does not demand it.

6. That I will rely on the persuasive Appeal Court case of VCS Ltd v Edward if required in order to demonstrate that no assumption can be drawn from my refusal to provide driver details to the Claimant.

7. The Claimant specifies that they are relying on the Protection of Freedoms Act (2012) (PoFA) in order to transfer liability from the unknown driver to myself as they have not identified the driver.

8. That the Claimant is unable to use PoFA since their Notice to Keeper (NtK) has not complied with ALL relevant requirements of PoFA Schedule 4 Paragraph 9(2).

9. That in particular, their NtK is missing required mandatory wording from both Paragraph 9(2)(e) and Paragraph 9(2)(f).

10. That 9(2)(e) specifies that; "The notice MUST STATE that the creditor does not know both the name of the driver and a current address for service" - this mandatory wording is not present on the Claimants NtK and therefore they have not met the required level of compliance set out in the Act.

11. Additionally, that 9(2)(f) specifies that the NtK must, amongst other things, warn the keeper that the parking operator is required to meet all the applicable conditions under PoFA Schedule 4 in order to rely on PoFA - the wording which sets out this warning is absent from the parking operators NtK - once again, this is fatal to the Claimant's reliance of PoFA.

12. That no 'period of parking' is either stated or demonstrated by the operators NtK - A single timestamp is not 'a period of parking'.

13. That the Claimant's failure to invoke keeper liability is immediately fatal to this claim since there is now legal route by which the Claimant can hold me liable.

14. Additionally, having examined the evidence, I would draw the Court's attention to the fact that the signage (used at the location) is purely prohibitive in nature and makes no offer of contract which can be accepted by the driver - therefore any suggestion of contract is firmly denied.

15. That the signage used at the site is not adequate - the Claimant has provided no viable plan which demonstrates where their alleged signage was placed in relation to the vehicle in question and their photographs of the vehicle show no signage in the locality.

16. That the Claimant's evidence does not demonstrate anything more than a brief stop - this was not parking.

17. That the Claimant's evidence does not demonstrate that the operator's Code of Conduct required "Period of Consideration" has been correctly applied in this instance - The Code requires that drivers are afforded at least 5 minutes in order to locate signage and examine contractual options - nothing in the Claimant's evidence demonstrates that the vehicle was present for longer than any consideration period and therefore, not withstanding my previous points, the Claimant is not able to demonstrate that a parking contract was formed.
Title: Re: Hearing set for parking charge by car park management services LTD
Post by: andy_foster on March 15, 2026, 08:42:45 pm: IMHO it is bad form to include legal argument in a witness statement. However everyone, particularly the parking companies and their lawyers, does that, so don't expect any criticism on that point by anyone other than me. IMHO (again) the proper way to clarify the defence submitted is though a skeleton argument.

Generally, once your defence has been submitted, you cannot amend your defence or add new points to it (as opposed to explaining or expanding upon the legal points already submitted) without the permission of the court. Whilst the rules in the small claims track are often applied more loosely (it is intended largely for litigants in person, and the cost of legal representation is generally not recoverable unless the other party is deemed to have behaved particularly unreasonably), it would seem prudent to nominally request permission in whatever form (or title) or legal argument you are submitting , and to explain that as stated in your original defence, it was not practicable to advance a meaningful defence as the PoC were inadequate and did not disclose any cause of action. Now that C has clarified their position in that the claim is purportedly brought under contract, despite the facts of the case seeming not to support this, you are now have a slightly less nebulous flawed claim to defend.

For a contract to be formed there has to be an offer of valuable consideration. That does not have to be the right to park. The issue is that there was no offer of any valuable consideration, communicated by the sign, or othwerwise and therefore no contract could be formed by any deemed acceptance. The offer of consideration that one might expect from a sign communicating an offer capable of forming a contract by acceptance by performance would be the right to park, but the fact that there was no offer of a right to park is not what defeats any claim of contractual liability, it is the lack of *any* valuable consideration being offered to the driver.

This is your case, not ours, but I would suggest that your understanding of the phrase "front and centre" differs from mine and DWMB2's. What you do with that information has no financial effect on myself or DWMB2.

As regards the "rules" of the small claims track. Perhaps the most important is "never ambush a District Judge" (regardless of whether the court has required or even invited disclosure of skeleton arguments (and regardless of whether the author of such skeleton arguments has written "Skeleton Argument" or "Witless Statement" at the top of the page.
Title: Re: Hearing set for parking charge by car park management services LTD
Post by: InterCity125 on March 15, 2026, 08:18:25 pm: Quote from: settop23 on March 15, 2026, 03:05:22 pm

There are 3 pictures of the vehicle provided in the evidence, and the timetstamp is at the bottom left in yellow. They are difficult to see but i believe 2 of them show the vehicle parked at 14:40 and the other at 14:41.

I'm not sure that these 'timestamps' will be that visible on the physical documents which the Judge will have in front of him on the day.

Also, please read this;

https://www.ftla.uk/private-parking-tickets/why-the-recent-high-court-appellate-case-of-mazur-is-very-relevant-to-all-cases-/

Your case is clearly being 'conducted' by an 'unauthorised person'.
Title: Re: Hearing set for parking charge by car park management services LTD
Post by: settop23 on March 15, 2026, 03:05:22 pm: Thank you all for this valuable insight and taking the time to look through the evidence.

I have prepared a draft copy of this witness statement. I have not provided one before, please let me know if it is okay.

There are 3 pictures of the vehicle provided in the evidence, and the timetstamp is at the bottom left in yellow. They are difficult to see but i believe 2 of them show the vehicle parked at 14:40 and the other at 14:41.

Do I email the WS to the court and to the claimants email?

https://ibb.co/G4ZHQKF9
https://ibb.co/VcqqVC98
https://ibb.co/Kc4mVzSs
Title: Re: Hearing set for parking charge by car park management services LTD
Post by: DWMB2 on March 14, 2026, 02:24:10 pm: I would agree on the prohibitive signage point, and ideally you want this issue front and centre.
Title: Re: Hearing set for parking charge by car park management services LTD
Post by: andy_foster on March 14, 2026, 02:02:01 pm: The most obvious issue (IMHO) is that the signs are entirely prohibitive.
In Beavis ParkingEye offered the right to park, in exchange for a promise from the driver, and the Supreme Court held that a contact had been formed (not that anybody asked them).

Broadly speaking, a promise (deemed or actual) is only enforceable at law if it forms part of a contract - which requires an offer of consideration acceptance (often by performance), and consideration (whether at the time, or in the form of a promise) from the party accepting the offer.

Regardless of how clear the signs are, you cannot form a contract without offering something. It would take a particularly motivated District Judge and much violence against the English language to find that the signs prohibiting parking were actually making an offer of a right to park in exchange for a promise to pay a parking charge.
Title: Re: Hearing set for parking charge by car park management services LTD
Post by: InterCity125 on March 14, 2026, 12:05:50 pm: @DWMB2
Also just noticed that the WS is prepared by a paralegal 'under supervision' - this is contra to Mazur??

https://ibb.co/JjwsCFX4
Title: Re: Hearing set for parking charge by car park management services LTD
Post by: InterCity125 on March 14, 2026, 11:48:13 am: Had a very quick scan through the evidence pack and noted the following;

NtK is not compliant as it omits mandatory wording from Schedule 4 9(2)(f) of PoFA.

The relevant term is as follows;

THE NOTICE MUST warn the keeper that if, after the period of 28 days beginning with the day after that on which the notice is given—

(i)the amount of the unpaid parking charges specified under paragraph (d) has not been paid in full, and

(ii)the creditor does not know both the name of the driver and a current address for service for the driver,

the creditor will (if all the applicable conditions under this Schedule are met) have the right to recover from the keeper so much of that amount as remains unpaid;

The legislation requires that the keeper be warned that the parking operators NtK is required to comply with all conditions of the schedule in order for the parking operator to rely on PoFA to transfer liability to the keeper.

The sentence in bold above is never stated on the NtK and therefore the NtK is not compliant since THE NOTICE MUST contain this warning.

Secondly, the 'period of parking' is dubious - it's a single timestamp and not a 'period' - that's a possible PoFA point but; how does the Claimant intend to prove any parking took place? (verses a temporary stop)

Thirdly, (just noticed) the NtK does not include the mandatory wording required by 9(2)(e) - THE NOTICE MUST STATE that the creditor does not know both the name of the driver and a current address for service for the driver

Further point - I've just gone through all evidence and there is absolutely nothing which demonstrates the period of time the driver was stationary - not even the pictures are timestamped - I would save this point for Court rather than the WS - put something very loose in the WS which does not draw specific attention to this point just in case they go to full hearing.

I would only submit a skeleton defence anyway. Their WS is only skeleton so I don't see a problem in that respect.
Title: Re: Hearing set for parking charge by car park management services LTD
Post by: DWMB2 on March 14, 2026, 08:33:49 am: If you can draft something up by the weekend you can try and submit on the Monday. Very much not ideal, but litigants in person are afforded somewhat more leeway in some cases, so worth a go.
Title: Re: Hearing set for parking charge by car park management services LTD
Post by: settop23 on March 13, 2026, 02:31:01 pm: Hello

Any advice regarding this? If i have messed up by not submitted WS, is there any point in attending court, or can I arrange to pay the balance on a monthly basis?
Title: Re: Hearing set for parking charge by car park management services LTD
Post by: settop23 on March 10, 2026, 12:22:05 pm: Hello

Thank you for the help, and I must apologise the defence I submitted was done in a rush and taken from another case I posted. I hope it does not affect my chances.

I have also just checked through the documents and the papers i receieved from the court on 05 February state witness statements must be submitted by 05 march

I have uploaded the evidence :

https://ibb.co/JjwsCFX4
https://ibb.co/qLJ77tKx
https://ibb.co/YTcDPXKG
https://ibb.co/C39KRyqM
https://ibb.co/fVB7PktL
https://ibb.co/S77xW79V
https://ibb.co/C30K585h
https://ibb.co/W4Rw87vP
https://ibb.co/yc4ZSdYn
https://ibb.co/3mvd0hmS
https://ibb.co/1Yp9SxrL
https://ibb.co/s9pWSvZm
https://ibb.co/W42vSHDq
https://ibb.co/9ky7pkF9
https://ibb.co/wNkw4q1t
https://ibb.co/sdPbH0FJ
https://ibb.co/Wv68GFRq
https://ibb.co/0RsSkP16

If you guys think I have a good chance of winning this at court, please do advise the best way to proceed
Title: Re: Hearing set for parking charge by car park management services LTD
Post by: DWMB2 on March 09, 2026, 04:15:30 pm: Quote from: settop23 on March 08, 2026, 04:00:12 pm
(g) The PoC states that the Claimant is suing the defendant as the
driver or the keeper.
Do they? As far as I can see they don't state in what capacity they're seeking to hold you liable.

Quote
There is also a skeleton argument and a witness statement from a paralegal at BW.
We need to see this. What is your deadline for submitting Witness Statements?
Title: Re: Hearing set for parking charge by car park management services LTD
Post by: InterCity125 on March 09, 2026, 04:14:49 pm: Please show us everything in the evidence pack including the skeleton and the WS.

Do they show the back of the NtK?
Title: Re: Hearing set for parking charge by car park management services LTD
Post by: settop23 on March 09, 2026, 03:10:44 pm: Thanks for the reply.

I do not have the original NTK, and have not appealed or engaged with the company in any way - except from the AoS and defence submitted on Mcol.

I have enclosed the evidence which they have sent in a pack, i believe it includes the original Ntk. There is also a skeleton argument and a witness statement from a paralegal at BW.

https://ibb.co/qFm4LFPm
https://ibb.co/vvgcL21n
https://ibb.co/rjgQd3j
https://ibb.co/YTBCWbDw
Title: Re: Hearing set for parking charge by car park management services LTD
Post by: InterCity125 on March 08, 2026, 08:05:38 pm: Do you have the original NtK?

Did you make any appeal?

Has the driver ever been revealed to the parking operator?

Please post up their evidence.
Title: Hearing set for parking charge by car park management services LTD
Post by: settop23 on March 08, 2026, 04:00:12 pm: Hello

I receieved a claim form on in May 2025, and submitted an AOS and defence in July. By December 2025, the claim was transferred to my local court as per the DQ.

Please find here the claim form : https://ibb.co/1GppqjKK

The defence I submitted is at the bottom of this message. Unfortunately I don't believe I seeked legal advice on here for this specific case and filed a defence which I had previously used for a similar case.

the case is now listed for a hearing at the end of this month. BW legal have sent their defence to my defence accross this week, and it mainly states that interest is not charged and quotes the signage that they rely upon which states no parking at any time.

I am the RK of the vehicle. The date of the parking is December 2024. I believe the driver of the vehicle parked there only for a short time (less than 5 minutes) and once they realised they did not have permission to park there they moved the car.

Any help with this would be appreciated

1. The Defendant denies any liability for this claim.

2. There is a lack of precise detail in the Particulars of Claim
(PoC) in respect of the factual and legal allegations made against
the Defendant such that the PoC do not comply with CPR 16.4.

3. The Defendant is unable to plead properly to the PoC because:
(a) The contract referred to is not detailed or attached to the
PoC in accordance with CPR PD 16(7.5);

(b) The PoC do not state the exact wording of the clause (or
clauses) of the terms and conditions of the contract (or
contracts) which is/are relied on;

(c) The PoC do not state with sufficient particularity the exact
time when the breaches occurred and how long it is alleged that
the vehicle was parked before the parking charges were allegedly
incurred;

(e) The PoC do not state exactly how the claim for statutory
interest is calculated;

(f) The PoC do not state what proportion of the claim are the
parking charges and what proportion is damages;

(g) The PoC states that the Claimant is suing the defendant as the
driver or the keeper. The claimant obviously knows whether the
defendant is being sued as the driver or the keeper and should not
be permitted to plead alternative causes of action.

4. The Defendant has attached to this defence a copy of an order
made at another court which the allocating judge ought to make at
this stage so that the Defendant can then know and understand the
case which he/she/it faces and can then respond properly to the
claim.

Statement of truth

I believe that the facts stated in this Defence 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.