Free Traffic Legal Advice
Live cases legal advice => Private parking tickets => Topic started by: ArenJool on May 16, 2025, 10:32:21 pm
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Hello all.
Small update.
I received a request from the court to complete an N180 form. They want to move it to small claims track.
I have also received bw legal's n180 who do not want it moved to small claims track because they want to cross examine me (lol).
I will send my copy within the time limit using the following template:
Download your own here and fill it in on your computer. You sign it by simply typing your full name in the signature box.
https://assets.publishing.service.gov.uk/media/673341e779e9143625613543/N180_1124.pdf
Here are the answers to some of the less obvious questions:
• The name of the court is "Civil National Business Centre".
• To be completed by "Your full name" and you are the "Defendant".
• C1: "YES"
• D1: "NO". Reason: "I wish to question the Claimant about their evidence at a hearing in person and to expose omissions and any misleading or incorrect evidence or assertions.
Given the Claimant is a firm who complete cut & paste parking case paperwork for a living, having this case heard solely on papers would appear to put the Claimant at an unfair advantage, especially as they would no doubt prefer the Defendant not to have the opportunity to expose the issues in the Claimants template submissions or speak as the only true witness to events in question.."
• F1: Whichever is your nearest county court. Use this to find it:
What is the court name? - Find a Court or Tribunal - GOV.UK
Tell us if you know the court or tribunal name or address to find a court or tribunal in England or Wales
find-court-tribunal.service.gov.uk
• F3: "1".
• Sign the form by simply typing your full name for the signature.
When you have completed the form, attach it to a single email addressed to both disputeresolution@bwlegal.co.uk and enquiries@bwlegal.co.uk and CC in yourself. Make sure that the claim number is in the subject field of the email.
Please let me know if you want any of their N180 answers.
Thanks.
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Thanks.
Small update. I had an issue with the online portal so I ended up posting the defence to the court. the tech support couldn't help merge my two online accounts but offered an email address for defence (claimresponses.cnbc at justice.gov to help those in future).
Anyway, I received a letter today dated 29 June from the court stating they received my defence and it will be passed on to claimant and they will have 28 days from receipt of defence to confirm if they wish to proceed blah blah blah.
Thanks again.
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Brindley Estate Defence.
1. That liability for the debt is completely denied and that no money is owned by myself to the Claimant.
2. That it is acknowledged that I was the Registered Keeper of the vehicle in question at the material time.
3. That the vehicle driver is not known to the Claimant.
4. That the Claimant is therefore attempting to use Protection of Freedoms Act 2012 (PoFA) in order to invoke what is legally known as 'keeper liability' thereby moving liability from the unknown driver to myself (the keeper).
5. That, in this instance, the Claimant's Notice to Keeper (NtK) does not meet all the requirements of PoFA Schedule 4 Paragraph 9(2) and therefore keeper liability cannot be invoked.
6. That with the driver unknown and keeper liability unavailable, there is no legal route to liability in this matter.
7. That throughout this matter I have attempted to engage with the Claimant in order to establish exactly where they allege the driver parked in relation to their issued PCN NtK.
8. That on each occasion the Claimant has failed to reveal the precise location of the alleged contravention.
9. That the Particulars of Claim are so vague that it is impossible to tell exactly what they are claiming for and therefore this represents a 'skeleton defence'.
10. That an examination of Google Street View shows that the Claimant appears to manage a gated cap park off Alfred Road on the Brindley Estate.
11. That at the material time the driver would not be able to access this gated car park since the driver was not in possession of an 'electronic key fob' which would allow access.
12. That all other areas surrounding this location are either public roads or car parks managed by Westminster Council and therefore not relevant to the claim pleaded.
13. That liability for the debt is therefore denied.
You should be able to submit this through MCOL.
I cannot wait for their witness statement complete with their pitch-black photos!
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No problem.
We can come up with a short sharp defence.
Give me 48 hours.
Thanks.
Do you know exactly where the vehicle was stopped, out of interest?
I can't make head or tail of it from Google Street View.
The only logical place for the driver to be would be this (ungated) area. Thankfully google street view has pictures from inside:
https://www.google.co.uk/maps/@51.5210964,-0.1950577,3a,75y,240.39h,90t/data=!3m7!1e1!3m5!1ssmZkx3peCHfgunQrVRCfCA!2e0!6shttps:%2F%2Fstreetviewpixels-pa.googleapis.com%2Fv1%2Fthumbnail%3Fcb_client%3Dmaps_sv.tactile%26w%3D900%26h%3D600%26pitch%3D0%26panoid%3DsmZkx3peCHfgunQrVRCfCA%26yaw%3D240.38749423560967!7i16384!8i8192?ucbcb=1&entry=ttu&g_ep=EgoyMDI2MDYxMC4wIKXMDSoASAFQAw%3D%3D
Although the street view image seems to be from 2022, the signs match until at least July 2025. You can see the sign beside the DPD van to the left. There are no UK CPM signs or terms that a driver would have seen driving from harrow road -> Alfred road -> this area.
Thanks again.
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There's no way this will go to a hearing.
BW Legal aren't always ones for letting a poor case get in the way of turning up for a hearing. ;D
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The Claimant is refusing to identify the exact location.
As far as we have been able to work out, the Claimant appears to control the car park beyond the locked gates. But it was not possible for the driver to access this land since they have no way of opening the gate.
There's no way this will go to a hearing.
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Do you know exactly where the vehicle was stopped, out of interest?
I can't make head or tail of it from Google Street View.
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No problem.
We can come up with a short sharp defence.
Give me 48 hours.
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Could you post up the Claim Form covering only personal details and the password?
This is a nuts claim - I cannot see they have any chance of winning.
Hello again.
Thanks for your reply.
Here it is:
(https://i.postimg.cc/ygPTZHmJ/claim-form.jpg) (https://postimg.cc/ygPTZHmJ)
https://i.postimg.cc/ZnksXY0L/claim-form.jpg
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Could you post up the Claim Form covering only personal details and the password?
This is a nuts claim - I cannot see they have any chance of winning.
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Hello again.
I have an update.
I have received a Claim Form.
It is dated 02 June 2026
I understand I need to respond with an Acknowledgment of Service within 14 days of service of the claim (a claim is considered served on the fifth day after it is issued).
So I understand that I have to respond on the moneyclaim website with an AoS by 20th June.
I understand that I need to file a defence within 14 days of my AoS.
Can anyone please advise if my understanding is correct and also If I need to change the wording of my defense in my previous posts?
Thanks all.
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You could reply and ask them to specify EXACTLY where they claim the photos were taken.
To be honest, those pictures could have been taken on the main runway at Heathrow!
;) ;) ;)
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Thank you.
I didn't have access to my account but I saw your reply while logged out and posted a letter.
They have responded to state that they confirmed receipt but have evidence I was parked on their premises and posted the same two laughable photos :D
They stated that if I don't respond they'll go after me, the keeper.
I'll let you know if anything further turns up.
Much appreciated
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Do not use their forms - there is no need.
Just send a response which robustly denies any liability.
No need to mention PoFA at this stage.
Something along the lines of the following;
To whom it may concern,
I am the vehicle keeper - the driver is not known by your client.
I can confirm that I have received your Letter of Claim.
To be clear, I totally refute the allegation that any parking charge is owed to your client.
Having examined the evidence, it is clear that this parking charge has been issued in error as the vehicle driver has never entered your clients property.
Your client's property appears to be a gated car park which would not be accessible by the vehicle driver.
All other roads and car parks in the area are either council owned or public highways.
I am sorry that I am unable to help you further in this matter.
Best wishes,
xxxxxx xxxxxxxxx
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Found this...
https://www.google.com/maps/@51.52089,-0.1955034,3a,75y,27.4h,79.7t/data=!3m7!1e1!3m5!1sTXQzL2lswIDHCW8VASCOmQ!2e0!6shttps:%2F%2Fstreetviewpixels-pa.googleapis.com%2Fv1%2Fthumbnail%3Fcb_client%3Dmaps_sv.tactile%26w%3D900%26h%3D600%26pitch%3D10.299612302347839%26panoid%3DTXQzL2lswIDHCW8VASCOmQ%26yaw%3D27.40443371443549!7i16384!8i8192?entry=ttu&g_ep=EgoyMDI2MDEyOC4wIKXMDSoKLDEwMDc5MjA3MUgBUAM%3D
Thanks for that. I know where this sign is. It is just about at the end of Alfred road. To the right of the entrance of an electronically gated car park at the bottom left of this map of "Brindley Estate":
https://www.openstreetmap.org/way/728959897#map=18/51.521405/-0.194512.
There is an unobstructed road to the right of Polesworth house, which has no CPM signs, an unobstructed road to the left of Polesworth house, which also has no CPM signs, and an unobstructed road to the right of Oversley house, which has no CPM signs.
There is no way the driver could have entered the gated car park at the end of Alfred road without a fob.
It is not clear from the photo which car park the PCN is allocated for. This is important because there is no way the driver could have read any terms if they went into any of the accessible car parks.
Should the reply form be responded to with these details:
Filling box D stating that I (the keeper) never entered into any contract as no contract terms were displayed, and the Keeper cannot be liable because the PCN is not PoFA compliant.
Should I also fill box I asking for:
-a copy of the written contract for the debt and a full statement of the account
-a copy of the notice of assignment of the debt
-confirmation of where they think the car was parked by way of a map
-confirmation of where their camera is by way of map
-proof they have jurisdiction in that area
-confirmation of clearly displayed CPM terms in that area
Thanks in advance.
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Found this...
https://www.google.com/maps/@51.52089,-0.1955034,3a,75y,27.4h,79.7t/data=!3m7!1e1!3m5!1sTXQzL2lswIDHCW8VASCOmQ!2e0!6shttps:%2F%2Fstreetviewpixels-pa.googleapis.com%2Fv1%2Fthumbnail%3Fcb_client%3Dmaps_sv.tactile%26w%3D900%26h%3D600%26pitch%3D10.299612302347839%26panoid%3DTXQzL2lswIDHCW8VASCOmQ%26yaw%3D27.40443371443549!7i16384!8i8192?entry=ttu&g_ep=EgoyMDI2MDEyOC4wIKXMDSoKLDEwMDc5MjA3MUgBUAM%3D
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Alfred Road appears to be a highway maintained at public expense and the parking areas all appear to be council controlled.
The PCN does not appear to be PoFA compliant and there can never be any keeper liability.
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Hi all.
So I have an update.
A letter was mailed to me dated 16 January 2026.
It is a "Letter of Claim".
I have uploaded the images with the personal details removed. It states that I have until 15 February to reply.
The "Client" is named as "UK Car Park Management Limited", named on my page 1.
No signage at all mentioned UK Car Park Management Limited". The google maps link above shows what the signage stated. This is reconfirmed when I returned to the location in July 2025 and took a video.
I assume the best course of action is to complete the reply form, filling box D stating that I never entered into any contract as no contract terms were displayed.
Should I also fill box I asking for a copy of the written contract for the debt and a full statement of the account, and a copy of the notice of assignment of the debt?
Please let me know if there is anything better that I should do instead.
LOC1
(https://i.postimg.cc/CRGp8z1K/1.jpg) (https://postimg.cc/CRGp8z1K)
LOC2
(https://i.postimg.cc/w1XYN7v3/2.jpg) (https://postimg.cc/w1XYN7v3)
LOC3
(https://i.postimg.cc/87Rgvj55/3.jpg) (https://postimg.cc/87Rgvj55)
LOC4
(https://i.postimg.cc/cvRG3rHr/4.jpg) (https://postimg.cc/cvRG3rHr)
LOC5
(https://i.postimg.cc/18G1FftX/5.jpg) (https://postimg.cc/18G1FftX)
LOC6
(https://i.postimg.cc/68rxZy38/6.jpg) (https://postimg.cc/68rxZy38)
LOC7
(https://i.postimg.cc/cvRG3rHg/7.jpg) (https://postimg.cc/cvRG3rHg)
LOC8
(https://i.postimg.cc/Xrf65pJB/8.jpg) (https://postimg.cc/Xrf65pJB)
LOC9
(https://i.postimg.cc/Sn6b9JsM/9.jpg) (https://postimg.cc/Sn6b9JsM)
July sign
(https://i.postimg.cc/HrgXzhpV/July2025-sign.jpg) (https://postimg.cc/HrgXzhpV)
July sign
(https://i.postimg.cc/hXBTs5SX/July2025-Sign-2.jpg) (https://postimg.cc/hXBTs5SX)
May sign
(https://i.postimg.cc/3kTm1cKN/May2025-sign.jpg) (https://postimg.cc/3kTm1cKN)
PCN page 1
(https://i.postimg.cc/YvHYRspC/pcn1.jpg) (https://postimg.cc/YvHYRspC)
PCN page 2
(https://i.postimg.cc/G4CGK5cB/pcn2.jpg) (https://postimg.cc/G4CGK5cB)
Thanks!
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On private land, unless the car is being loaded and/or unloaded, then it is considered parked if stationary for more than 5 minutes in a car park with less than 500 spaces or 10 minutes if more than 500 spaces.
This is because they are required to give the driver that time to seek out, read and decide whether they want to be bound by the terms of parking or leave. Any PCN issued for a period of parking less than those times cannot prove that any contract was formed with the driver.
So, if you were stationary for longer than the minimum consideration period, then as far as they are concerned, the driver had agreed to the terms and conditions.
Unless the PCN issued is fully compliant with all the requirements of PoFA 2012, then they can hold the Keepr liable if they don't know the drivers details.
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Thanks for your response.
The photo of the sign you have showed us does not appear to be a sign belonging to CPM. How the car park area is delineated could be important.
One possibility I can think of, is that the car park is for residents of the block it is adjacent to, but only if they register their details with Westminster City Council (given the "vehicle not registered" comment on the PCN). The bays do not seem to be allocated to individual flats and are all unmarked except for the one disabled bay stating for "LL14".
The GSV views are too old to be of any value. We would need to see the current signage, preferably under the same lighting conditions at the time of the alleged contravention.
I agree the GSV views are 3 years old but I promise that it accurately reflects what is shown today. I can't get any photos of that area until mid June.
For any contract to have been made, there must have been an entrance sign that clearly informs the driver that they are entering private land and that parking terms and conditions apply. Once on the land, there must be sufficient signs that adequately bring to the attention of the driver what the terms of parking are.
The only sign mentioned on entrance is the one provided in the opening post, and matches the GSV views.
Did you park in a bay marked as for the use of people with a disability? If so, there should be a sign with all the parking terms and conditions that can be read by the driver without having to leave the vehicle. Is that the case?
The car was stopped, while still occupied, in an unmarked bay for 10 minutes. Not in a bay marked as for the use of people with a disability. I'm unsure if the agreed definition for what a "parked" car includes whether or not the car is occupied, and if there is any time limit, and if the car must be locked or not.
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Blue and white badges are not relevant to private land. Whist the operator may request that a relevant badge be displayed if utilising disabled access bays, they have no relevance otherwise.
The photo of the sign you have showed us does not appear to be a sign belonging to CPM. How the car park area is delineated could be important.
The GSV views are too old to be of any value. We would need to see the current signage, preferably under the same lighting conditions at the time of the alleged contravention.
For any contract to have been made, there must have been an entrance sign that clearly informs the driver that they are entering private land and that parking terms and conditions apply. Once on the land, there must be sufficient signs that adequately bring to the attention of the driver what the terms of parking are.
Did you park in a bay marked as for the use of people with a disability? If so, there should be a sign with all the parking terms and conditions that can be read by the driver without having to leave the vehicle. Is that the case?
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Any advice please?
Thanks in advance.
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Hello.
I hope you're all well.
I am the registered keeper. I have just noticed this PCN. I have not been on top of my mail as I am juggling a few court cases fighting false allegations. When I try to log on to appeal, it states that the case has been moved to their legal team.
The driver and passenger drove into this parking area. one of them left the car to check to see if the Westminster white disabled badge was valid in this car park. The car was never vacant. 10 minutes of searching did not get a solid answer so the car left the area.
The only signs inside only state "OVS permit holders only". It is not clear that this area is one of the exclusions mentioned of the white badge page (It is not clear that this is a WCC estate): https://www.westminster.gov.uk/parking/disabled-parking/where-you-can-park-disabled-badge
Google maps link:
https://maps.app.goo.gl/1aPdZ5FexUQowPFQ6
Can this be successfully fought please?
Thanks.
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