At 75 minutes, the cost of the transcript will be quite highIf the cost is prohibitive but you still want something, you can (from memory) opt to just have the judgement transcribed.
Also, don't forget that you can introduce elements of 'humankind' and 'common sense' to your arguments - it doesn't have to be all legal talk.And anecdotally, it often isn't. Often, judges want to get to the meat and bones of the claim, rather than spending time picking apart technical minutiae.
The only thing I would say in terms of running order;Likewise - my point around order was more that if the judge launches straight in and starts picking apart another element of their case, let 'em.
I would definitely focus on the defective PoC to start with.
Does anyone know if member B789 is still active on this forum? He/she, amongst others, has been very helpful in my case (but appears not to have been active since 20/01/26) and I would appreciate an eye cast over my proposed WS before I submit it today if at all possible. Many thanks.
Is the judge likely to ask me who the driver was?In theory they shouldn't be doing the claimant's job for them. But, if they do ask, you must answer truthfully. Some people suggest various forms of wording about not being required to say etc. - in my view, the risk with such approaches is that you p*ss the judge off and come across as evasive, which isn't necessarily wise. Even less so when you have other valid defence points that don't rely on the driver's identity being unknown.
IN THE COUNTY COURT AT WORCESTERClaim No: [Claim Number]BETWEEN:
Vehicle Control Services Ltd
Claimant
- and -
[Defendant's Full Name]
Defendant
AMENDED DEFENCE pursuant to order of DJ Redmond dated 20th November 2025
This amended defence replaces the original defence pursuant to the court’s order.
1. The Defendant denies the claim in its entirety. The Defendant asserts that there is no liability to the Claimant and that no debt is owed. The claim is without merit and discloses no lawful cause of action.
2. The Particulars of Claim are inadequately pleaded. They do not identify the precise terms alleged to have been breached, fail to specify the contractual basis for the claim, and provide no clear calculation of the sum claimed.
3. The Claimant alleges the Defendant is liable either as the driver or, in the alternative, as the keeper under Schedule 4 of the Protection of Freedoms Act 2012. The Defendant is the registered keeper of the vehicle but has never admitted to being the driver. The Claimant has provided no evidence of driver identity.
4. The location in question is Bristol Airport, which is governed by statutory byelaws and therefore not classified as relevant land under Schedule 4 of the Protection of Freedoms Act 2012. Accordingly, the Claimant cannot rely on the provisions of PoFA to transfer liability from the unknown driver to the registered keeper.
5. The Defendant relies on the persuasive appellate authority in Vehicle Control Services Ltd v Edward (2023) [H0KF6C9C], in which HHJ Gargan held at paragraph 35.3 that no inference can be drawn from keeper status alone, and that the Claimant must prove on the balance of probabilities that the Defendant was the driver. No such evidence exists in this case.
6. The Claimant has failed to provide any proof that the Defendant was the driver. As keeper, the Defendant cannot be held liable under PoFA, and no alternative legal basis for keeper liability has been established.
7. The three PCNs relate to alleged incidents at 02:23, 02:31, and 02:36 on the same date. The Claimant has not provided any evidence showing where the vehicle was located in each instance, how long it was allegedly stationary, or whether any alleged stopping occurred in view of any signage. The Claimant’s photographs show only partial vehicle images in darkness and reveal no identifiable surroundings.
8. The Claimant relies on a site plan dated October 2019. The Defendant is aware that the Claimant entered into a new contract with a revised site plan on 17 March 2023. The outdated plan currently relied on is therefore no longer applicable and does not assist the court in understanding where the vehicle was in relation to signage or patrol zones.
9. The Claimant has issued three separate charges within a 13-minute window without establishing that the vehicle moved in and out of distinct zones or that each instance involved a fresh agreement or breach. In the absence of clear evidence, the issuing of multiple charges for what may be a single or continuous event amounts to double or triple recovery and an abuse of process.
10. The signs relied upon by the Claimant state that stopping is prohibited. These signs do not set out any contractual terms capable of acceptance. They are prohibitory in nature and do not constitute an offer.
11. It is a fundamental principle of contract law that an offer must be capable of acceptance. A sign that says “No stopping” or threatens a charge for stopping is not inviting acceptance of terms but is instead forbidding an action. There can be no contract where there is no offer. The signs do not meet the requirements for contract formation and no valid agreement was ever created.
12. This position is supported by established persuasive authority including Jopson v Homeguard [2016] B9GF0A9E, where HHJ Harris QC confirmed that momentary stopping does not constitute parking, and that context is key. In that case, the court rejected liability where the alleged contravention involved a brief stop for a legitimate purpose. The Claimant in this case has provided no contextual detail and no evidence that any contractual terms were accepted.
13. The High Court in Ransomes v Anderson [2011] EWHC 1127 (QB) held that signage which merely prohibits an activity, rather than offering terms for compliance, cannot give rise to a contract. The signage relied on by the Claimant is of this nature — it imposes a prohibition against stopping and threatens a charge, but offers no service or terms that could be accepted. As such, it is incapable of creating a contractual relationship, and any charge claimed is a penalty, not a contractual debt.
14. The Claimant seeks £510, including £210 of unexplained add‑ons. These sums are not supported by contract or evidence. The Supreme Court in ParkingEye v Beavis [2015] UKSC 67 upheld a single parking charge as enforceable, but made no allowance for additional recovery fees. Such uplifts fall outside the ratio of Beavis and are penal in nature, contrary to the principles in Dunlop Pneumatic Tyre Co Ltd v New Garage [1915] AC 79. The Defendant therefore submits that the add‑ons are irrecoverable and that the claim is liable to strike‑out under CPR 3.4(2)(b).
15. The Defendant submitted a detailed response to the Claimant’s Letter of Claim, clearly explaining that there was no basis for pursuing the registered keeper, that the land is not relevant under PoFA, that the signage cannot create a contract, and that the claim was excessive and unreasonable. The Claimant ignored this and issued proceedings without addressing any of the issues raised. This is a breach of the Pre-Action Protocol for Debt Claims and further evidence of unreasonable conduct.
16. The Defendant invites the court to strike out the claim pursuant to CPR 3.4(2)(b) for failing to disclose a cause of action, or alternatively to enter summary judgment under CPR 24.2. The Defendant further asks the court to consider a costs order under CPR 27.14(2)(g) due to the Claimant’s unreasonable conduct.
Statement of truth
I believe that the facts stated in this Amended 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.
Signed:
Date:
Subject: Claim No: [insert claim number] – Amended Defence Pursuant to Court Order
To: civil.worcester.countycourt@justice.gov.uk
CC: info@dcblegal.co.uk
Dear Sir or Madam,
Please find attached the Defendant’s amended defence in this matter, filed pursuant to the Order of District Judge Redmond dated 20 November 2025. This has been served within the timeframe specified by the court.
Claim Number: [insert claim number]
Claimant: Vehicle Control Services Ltd
Defendant: [insert full name of defendant]
The amended defence has also been served on the Claimant’s legal representative, DCB Legal Ltd, by way of copy to this email.
Please confirm receipt by return.
Yours faithfully,
[Defendant’s full name]
[Address]
[Email address]
Subject: Claim [CLAIM NO] — urgent: identity and settlement authority of attendee at SCMS mediation on [DATE]
To: DCB Legal
Date: [DD Month YYYY]
Dear Sirs,
I write in relation to the SCMS mediation in the above claim held on [DATE]. During the mediation I asked the mediator to confirm, for the record, the full name, role/position and written authorisation to settle of the person attending on behalf of your client. The mediator was unable to provide these details.
For the avoidance of doubt and on an open basis (not without prejudice), please provide the following information within 7 days of this email:1. The full name and job title/role of the individual who acted for your client on the SCMS call on [DATE].
2. Whether that individual is an authorised person for the purposes of the Legal Services Act 2007 (i.e. a solicitor, regulated conveyancer or other authorised litigator), an exempt person, or an unregulated employee/paralegal. If an exempt person or unregulated employee/paralegal, state the legal basis for the exemption and identify the supervising authorised person.
3. Whether that individual had express written authority to negotiate and to bind the claimant to settlement, or whether any settlement decision required further approval; if the latter, state the mechanism and timescale for such approval.
4. Confirm who within your firm or the claimant’s organisation holds the authority to approve any settlement or discontinuance and provide a contact name and position for that person.
Please be aware of the following:a) The giving of settlement terms and the taking of steps to discontinue or compromise claims are acts that, when done as part of an adversarial process, may amount to the conduct of litigation. If the person on your side who engaged in mediation was not an authorised person and was purporting to carry out acts that fall within the reserved activity of conducting litigation, that raises serious regulatory concerns.
b) If you do not confirm the identity and status of the individual who attended the mediation within 7 days I reserve the right to make a formal complaint to the Solicitors Regulation Authority (and any other relevant regulator) on the basis that an unauthorised person may have been put forward as your representative and may have acted in a way which crosses the boundary of conducting litigation.
c) I will also rely on your response (or failure to respond) when making any application or submissions to the court on costs as to whether your conduct amounted to unreasonable conduct which frustrated mediation (see CPR 27.14(2)(g)).
I have retained the SCMS confirmation note and a contemporaneous file note of the exchange for my records. I trust you understand the seriousness of this request and will respond promptly.
Yours faithfully,
[Your full name]
I am submitting this complaint about DCB Legal Ltd for serious breaches of the SRA Principles in the way they have conducted litigation against me.
DCB Legal issued a court claim despite having received a detailed response to their Letter of Claim, which clearly raised multiple legal objections and evidential challenges. They did not respond to or engage with any of the issues raised. They simply proceeded to issue a claim without explanation.
This is a direct breach of the Pre-Action Protocol for Debt Claims, which requires parties — especially professional representatives — to engage meaningfully and proportionately with pre-action correspondence. The PAPDC specifically requires a full and considered reply to any substantive issues raised. DCB Legal ignored that entirely.
Their failure to respond was not an oversight. They were explicitly warned that if they issued a claim without addressing the points raised, the matter would be referred to the SRA. They ignored that warning too.
Their conduct shows disregard for their obligations under the SRA Principles, including:• Principle 1: Upholding the rule of law and proper administration of justice
• Principle 4: Acting with honesty
• Principle 5: Acting with integrity
• Principle 7: Acting in the best interests of their client and not misusing the court process
This is not simply a civil dispute. It is a regulatory issue about the professional conduct of a firm that routinely issues claims without properly assessing the legal basis or responding to pre-action challenges. I ask that the SRA investigate whether this is part of a wider pattern and whether DCB Legal are complying with their professional duties.
IN THE COUNTY COURTClaim No: [Claim Number]BETWEEN:
Vehicle Control Services Ltd
Claimant
- and -
[Defendant's Full Name]
Defendant
DEFENCE
1. The Defendant denies the claim in its entirety. The Defendant asserts that there is no liability to the Claimant and that no debt is owed. The claim is without merit and does not adequately disclose any comprehensible cause of action.
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 adequately set out the reason (or reasons) why the claimant asserts the defendant has breached the contract (or contracts)
(d) The PoC do not state with sufficient particularity exactly where the breach occurred, the exact time when the breach occurred and how long it is alleged that the vehicle was parked before the parking charge was allegedly incurred;
(e) The PoC do not state precisely how the sum claimed is calculated, including the basis for any statutory interest, damages, or other charges;
(f) The PoC do not state what proportion of the claim is the parking charge and what proportion is damages;
(g) The PoC do not provide clarity on whether the Defendant is sued as the driver or the keeper of the vehicle, as the claimant cannot plead alternative causes of action without specificity.
4. The Defendant attaches to this defence a copy of a draft order approved by a district judge at another court. The court struck out the claim of its own initiative after determining that the Particulars of Claim failed to comply with CPR 16.4. The judge noted that the claimant had failed to:(i) Set out the exact wording of the clause (or clauses) of the terms and conditions relied upon;
(ii) Adequately explain the reasons why the defendant was allegedly in breach of contract;
(iii) Provide separate, detailed Particulars of Claim as permitted under CPR PD 7C.5.2(2).
(iv) The court further observed that, given the modest sum claimed, requiring further case management steps would be disproportionate and contrary to the overriding objective. Accordingly, the judge struck out the claim outright rather than permitting an amendment.
5. The Defendant submits that the same reasoning applies in this case and invites the court to adopt a similar approach by striking out the claim for the Claimant’s failure to comply with CPR 16.4.
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.
Signed:
Date:
[Date]
DCB Legal Ltd
Direct House
Greenwood Drive
Manor Park
Runcorn
WA7 1UG
By email only: info@dcblegal.co.uk
Subject: Response to your email dated [insert date] – VCS / [Reference Number(s)] – Keeper Liability Not Applicable
Dear Sir/Madam,
I write further to your email dated [insert date], and must express astonishment at the level of misunderstanding and procedural ineptitude it contains. I respond purely for the benefit of the court, should this charade ever be escalated to litigation.
Let me be clear: I am the registered keeper, and at no stage have I identified the driver. Yet, despite my prior explanation—and the fact that the location in question is Bristol Airport, land subject to statutory control under byelaws—you persist in attempting to argue that I am liable as the keeper under the Protection of Freedoms Act 2012 (PoFA). Your failure to grasp such a fundamental legal point is, frankly, embarrassing.
1. Airport Land Is Not “Relevant Land” – Keeper Liability Is Irrelevant
For avoidance of any further confusion (which appears chronic), land governed by airport byelaws is excluded from the definition of “relevant land” under Paragraph 3 of Schedule 4 to the Protection of Freedoms Act 2012 (PoFA).
You cannot hold a keeper liable.
There is no grey area. This is basic statutory interpretation—something one would reasonably expect a litigation firm to understand before threatening court action. Yet here we are, with your firm still insinuating that liability passes to the keeper, as if PoFA applies where it manifestly does not.
The Keeper is under no legal obligation to identify the driver to your client, an unregulated private parking company. Moreover, there can be no presumption or inference that the Keeper was the driver, as already confirmed in persuasive appellate case law—including your own client’s loss in Vehicle Control Services Ltd v Edward (2023) [HOKF6C9C]. To continue suggesting otherwise demonstrates either wilful ignorance or a staggering level of incompetence.
2. Misrepresentation of the Law – Baseless ‘Balance of Probabilities’ Argument
Your assertion that I am liable “on the balance of probabilities” because I did not name the driver is both legally baseless and intellectually lazy.
As already explained above, PoFA does not apply to airport land. In such cases, where there is no statutory mechanism for transferring liability from driver to keeper, your client must prove as a matter of fact that I was the driver. There is no legal presumption, and the Keeper is under no obligation to assist a private firm by naming the driver.
Your reliance on inference in the absence of evidence is a misrepresentation of the applicable legal test. In the persuasive appellate case of Vehicle Control Services Ltd v Edward (2023) [HOKF6C9C], HHJ Gargan made clear at paragraph 35.3:“It is consistent with the appropriate probability analysis whereby simply because somebody is a registered keeper, it does not mean on balance of probability they were driving on this occasion, because one simply cannot tell.”
The judge was unambiguous: unless the Claimant can clearly and specifically evidence that the defendant was the driver, no such inference can be drawn.
Your continued reliance on this flawed reasoning is not only legally incorrect—it is professionally embarrassing. To attempt to manufacture liability through inference where none exists, and in direct contradiction to established and persuasive appellate authority, falls well below the standards expected of regulated legal practitioners.
Should you persist in advancing this fiction, I will bring it to the court’s attention and will include it in my formal complaint to the Solicitors Regulation Authority, highlighting your firm’s apparent willingness to misstate the law and pursue claims without proper legal foundation.
3. DVLA Data Misuse – Formal Complaints Imminent
Your client obtained my keeper data via the DVLA’s KADOE contract, which strictly prohibits use of that data where PoFA is not applicable and where the keeper cannot be held liable.
Continued use of that data in pursuit of an unenforceable claim is not only unlawful but in breach of the KADOE contract and the UK GDPR.
Should this baseless pursuit continue, I will not hesitate to escalate matters to:
The DVLA, for breach of the KADOE terms; and
The Information Commissioner’s Office, for unlawful processing of personal data.
4. Fake Add-Ons – Abuse of Process
Your attempt to inflate the claim with three separate £70 “debt recovery” charges is equally absurd. The added sums represent no genuine loss, nor are they contractually agreed.
This exact conduct was condemned by the courts in Britannia Parking v Semark-Jullien (2020), where such practices were found to be an abuse of process. Adding these sums not only displays a complete lack of legal rigour, but if a claim is issued including them, I will seek summary judgment or strike-out, and pursue costs under CPR 27.14(2)(g) for unreasonable conduct.
5. Pre-Action Protocol – Your Response Is Woefully Non-Compliant
Despite my reasoned and structured response, your firm has simply repeated your client’s unmeritorious position and cherry-picked which questions you deemed “proportionate.” That is not how the Pre-Action Protocol works.
Paragraph 6(a) of the Protocol requires a full and considered reply to every substantive point raised. Your approach—consisting largely of automated bluster and evidence you believe supports your client—falls well short of what the court will expect.
6. Final Position
Let me be crystal clear: any further attempt to pursue me, as the keeper, for a purported contravention on non-relevant land, will be taken as evidence of:• A deliberate abuse of process;
• A flagrant misuse of DVLA data; and
• A breach of the SRA Principles, notably:• Principle 1: Upholding the rule of law
• Principle 4: Acting with honesty
• Principle 5: Acting with integrity
• Principle 7: Acting in the best interests of each client
Should your firm be foolish enough to escalate this to court, I will include this and all previous correspondence in my witness statement, and will formally request that the court issue a finding of unreasonable behaviour against your client, and against you as their representatives.
I strongly suggest that you now take competent legal advice before humiliating yourselves and your client further.
Yours faithfully,
[Your Name]
Registered Keeper – Not Liable
[Your Name]
[Your Address]
DCB Legal Ltd
Direct House
Greenwood Drive
Manor Park
Runcorn
WA7 1UG
[Date]
By email: info@dcblegal.co.uk
Subject: Response to Letter of Claim – Disputed Debt
Dear Sir/Madam,
I acknowledge receipt of your Letter of Claim dated 27 February 2025 regarding an alleged debt of £510.00 on behalf of your client, Vehicle Control Services Limited (VCS). I dispute this claim in its entirety, both on substantive and procedural grounds. Accordingly, I require full and detailed clarification before any further action is taken. Failure to provide the required information will be considered a breach of the Pre-Action Protocol for Debt Claims (PAP) and may be cited in any subsequent proceedings.
1. Pre-Action Protocol Non-Compliance
Your Letter of Claim fails to comply with the requirements of the Pre-Action Protocol for Debt Claims (PAP) in the following ways:No Clear Breakdown of the Debt (£510.00)
The LoC fails to itemise the charges beyond stating a lump sum amount.
I require a full breakdown showing:- The original Parking Charge(s) amount.
- Any alleged additional fees, including "debt recovery costs" or "legal fees."
- Justification for any additional costs beyond the original PCN amount.
- Explanation of how such fees comply with the Supreme Court ruling in ParkingEye v Beavis [2015] UKSC 67.Failure to Provide Key Evidence
Your letter does not include any documentary evidence to substantiate the claim, such as:- A copy of the original Parking Charge Notice(s) (PCNs).
- Photographic or ANPR evidence showing the alleged contravention, including timestamped images of entry and exit.
- A full copy of the terms and conditions allegedly breached, including the signage that the claimant is relying on that formed the contract with the driver, as displayed at the time of the alleged contravention.
- Evidence that VCS has the authority to issue parking charges at the location in question.
- Proof that the alleged sum reflects actual loss or liquidated damages enforceable under contract law.No Demonstration of Keeper Liability Under PoFA 2012
- If your client seeks to rely on the Protection of Freedoms Act 2012 (PoFA) Schedule 4, strict compliance is required.
- I request confirmation that the Notice to Keeper (NtK) sent complies with PoFA 2012, Schedule 4, Paragraph 9, including:- Clear invitation for the keeper to pay the charge.
- Delivery within the statutory timeframe.
- The inclusion of mandatory wording as per PoFA 9(2)(e)(i).
- If no such compliance exists, VCS has no basis for holding me liable as keeper.Potential Abuse of Process – Unreasonable Additional Costs
- The addition of any ‘debt recovery costs’ beyond the original PCN is likely unrecoverable and may constitute an abuse of process.
- In Britannia Parking v Semark-Jullien (2020), the courts ruled that adding a flat £60 debt recovery fee was an abuse of process and struck out the claim.
- If this claim proceeds with added fees, I will seek to have them struck out and will request costs for unreasonable behaviour.
2. Demand for Further Disclosure
To facilitate a meaningful response and comply with the Overriding Objective under CPR 1.1, I request the following within 30 days:- A full breakdown of the claimed sum, showing any debt collection or legal fees.
- A copy of the original Parking Charge Notice(s) (PCNs).
- Timestamped ANPR or photographic evidence of the alleged contravention.
- Copies of the signage in place at the material time, including the full contractual terms.
- Evidence of landowner authority, showing VCS has the right to issue PCNs at the site.
- Clarification on whether the claim is pursued under contract law or trespass.
- If alleging Keeper Liability, confirmation that all PoFA 2012 requirements have been met.
If you fail to provide the above, I will draw this to the court’s attention as a failure to engage in pre-action conduct, potentially seeking an adverse costs order.
3. Next Steps & Potential Complaint
If you fail to provide the requested information or continue to pursue an unmeritorious claim:- I will formally complain to the Solicitors Regulation Authority (SRA) regarding potential breaches of SRA Code of Conduct (Principles 1, 4, 5 & 7) regarding misleading demands for payment.
- I will escalate a complaint to the DVLA for breach of the Keeper at Date of Event (KADOE) contract, as VCS’s misuse of DVLA data warrants investigation and potential sanctions.
- If you issue a claim without addressing these issues, I will request summary judgment or strike-out for failure to follow the PAP.
- If the claim proceeds, I will seek full costs under CPR 27.14(2)(g) for unreasonable behaviour.
4. No Admission of Liability & Right to Seek Further Advice
This letter should not be construed as an admission of any liability. I reserve the right to seek independent legal advice, and if necessary, to counterclaim for unreasonable conduct.
Please confirm receipt of this letter and provide a full response within 30 days.
Yours faithfully,
[Your Name]
[Your Address]
[Email Address]
It is important we highlight that we will continue to pursue this matter on the reasonable assumption that you were the driver of the vehicle on the date in question until information/evidence to the contrary is provided.
Dear Sir/Madam,
Your latest response does little more than confirm your ongoing reliance on the absurd "assumption" that I, as the registered keeper, was the driver. I’m not sure whether to be astonished or amused by this continued strategy, especially considering your firm’s humiliating thrashing in VCS v Edward (2023) [H0KF6C9C] — a claim which has now become persuasive case law. It seems VCS has learned nothing from that ruling, which confirmed that assumptions, without evidence, are worthless in court.
Let me make this clear: it is not my responsibility to disprove your assumptions. The burden of proof is entirely on VCS to provide evidence that I was the driver. As it stands, you have none. If VCS are so confident in their flawed assumption, I invite VCS to put their money where their mouth is and take this to court. It will be interesting to see how far this ridiculous argument gets you — particularly when your own firm’s failed appeal serves as a warning of what happens when you pursue spurious claims based on assumptions.
If you do not cancel this PCN, I am more than prepared to see it through to the inevitable conclusion. It would be an amusing exercise to watch this baseless claim fall apart under scrutiny.
Yours faithfully,
[Your Name]
Registered Keeper
I am the registered keeper. VCS cannot hold a registered keeper liable for any alleged contravention on land that is under statutory control. As a matter of fact and law, VCS will be well aware that they cannot use the PoFA provisions because BRISTOL Airport is not 'relevant land'.
If Bristol Airports landowners wanted to hold owners or keepers liable under Airport Byelaws, that would be within the landowner's gift and another matter entirely. However, not only is that not pleaded, it is also not legally possible because VCS is not the Airport owner and your 'parking charge' is not and never attempts to be a penalty. It is created for VCS’s own profit (as opposed to a byelaws penalty that goes to the public purse) and VCS has relied on contract law allegations of breach against the driver only.
The registered keeper cannot be presumed or inferred to have been the driver, nor pursued under some twisted interpretation of the law of agency. Your NTK can only hold the driver liable. So you are urged to save us both a complete waste of time and cancel the PCN.