Free Traffic Legal Advice

With an issue date of 24th July, you had until 4pm on Tuesday 12th August to either submit your defence or, if you submitted an AoS by that date and time, you would then have had until 4pm on Tuesday 26th August to submit your defence.

As you were able to submit the AoS, it is obvious they forgot about it and have not yet applied for the CCJ, so you should log back into your MCOL portal and submit the following as your defence, without delay, immediately:

Until very recently, we never advised using the MCOL to submit a defence. However, due to recent systemic failures within the CNBC, we feel that it is safer to now submit a short defence using MCOL as it is instantly submitted and entered into the "system". Whilst it will deny the use of some formatting or inclusion of transcripts etc. these can always be included with the Witness Statement (WS) later, if it ever progresses that far.

You will need to copy and paste it into the defence text box on MCOL. It has been checked to make sure that it will fit into the 122 lines limit.

Quote

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 adequately 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 16.7.3(1);

(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 submits that courts have previously struck out similar claims of their own initiative for failure to adequately comply with CPR 16.4, particularly where the Particulars of Claim failed to specify the contractual terms relied upon or explain the alleged breach with sufficient clarity.

5. In comparable cases involving modest sums, judges have found that requiring further case management steps would be disproportionate and contrary to the overriding objective. Accordingly, strike-out was deemed appropriate. 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 due to the Claimant’s failure to adequately comply with CPR 16.4, rather than permitting an amendment. The Defendant proposes that the following Order be made:

Draft Order:

Of the Court's own initiative and upon reading the particulars of claim and the defence.

AND the court being of the view that the particulars of claim do not adequately comply with CPR 16.4(1)(a) because: (a) they do not set out the exact wording of the clause (or clauses) of the terms and conditions of the contract which is (or are) relied on; and (b) they do not adequately set out the reason (or reasons) why the claimant asserts that the defendant was in breach of contract.

AND the claimant could have complied with CPR 16.4(1)(a) had it served separate detailed particulars of claim, as it could have done pursuant to CPR PD 7C.5.2(2), but chose not to do so.

AND upon the claim being for a very modest sum such that the court considers it disproportionate and not in accordance with the overriding objective to allot to this case any further share of the court's resources by ordering further particulars of claim and a further defence, each followed by further referrals to the judge for case management.

ORDER:

1. The claim is struck out.

2. Permission to either party to apply to set aside, vary or stay this order by application on notice, which must be filed at this Court not more than 5 days after service of this order, failing which no such application may be made.

Assuming they have not yet applied for a default CCJ and your defence is accepted, you should also go purchase a lottery ticket.

Somehow I have Submitted a Defence Online
Very Grateful to b789 for a Speedy and Worthy response.

anyone?

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defence particulars pasted in to the relevant text input field box on MCOL with 33 lines remaining.

defence submitted on 22 August 2025.

absolutely grateful to b789

are you originally from pepipoo or another forum / medium?

Thank you for your swift response.

What is the issue date of the claim?
Issue Date 22 JUL 2025

On what date did you submit the AoS and how did you submit it?
AoS submitted on 07/08/2025 via MCOL - Money Claim Online

Who is the Claimant?
G24 Limited

Once you have answered these questions, we can provide the advice you need to submit the defence.

I was thinking of sending them this:

I am writing to formally appeal the Penalty Charge Notice No. AF99076474 53J issued for an alleged violation of “failing to comply with a restriction on vehicles entering a pedestrian zone” on 2nd September 2024 at 15:27.

Upon review, I respectfully contest this PCN on the grounds that the restriction was issued under circumstances where no students or school-related pedestrian traffic would have been affected. To my understanding, the school in question was closed on this date, reportedly a staff training day. No children were present as it was in effect a non-term day, meaning there was no pedestrian activity warranting the enforcement of the zone restrictions.

Schools in the Redbridge area operate on different term calendars, and it is impractical to expect residents to track every school’s unique dates to comply with restrictions intended for student safety. This lack of alignment between term dates and traffic enforcement creates confusion and ambiguity for residents who wish to adhere to regulations but have limited access to accurate, comprehensive information regarding individual school schedules.

Given that the pedestrian zone restrictions serve primarily to protect students during active school days, enforcing the restriction when no students are present contradicts the spirit of the regulation. Therefore, I respectfully request the cancellation of this PCN, as there was no risk to pedestrian safety on this particular day.

Thank you for your attention to this matter, and I look forward to your favorable response.

Kind regards

Is this appeal written by ChatGPT?

@stamfordman could you please assist in the appeal? Running out of time I think

I believe you have until 31 October 2024 by 23:59 PM to submit your formal representations online. Otherwise submitted by letter 1st Class recorded delivery on 29 October 2024 by its collection time, from a postbox / post office, by Royal Mail Postie.

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Have you uploaded the original PCN and the Informal Challenge you submitted for other's to chime in?[/hr]

Quote from: regis on October 14, 2024, 02:53:52 am

[1] Is this the First ever instance OP has parked in Newham in an Event Day relevant Bay? and if NOT, how does OP usually receive notification of an Event Day in Newham?

Yes it is. I am not a resident of the borough.

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This must be included as additional ground in your formal rep. Additionally, request a discretionally cancellation since this is your first instance of receiving a PCN for this contravention code, Although, they may disregard it, causing a procedural impropriety.
[/hr]

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How would a non-resident of the borough know how to become notified of an Event Day, if upon the entry of the main junction of the road, usually a RPZ / CPZ signage is erected listing the Event day in force, there is no notification or mention of an Event Day in force? Would one drive aimlessly around a non familiar borough searching for signage wasting their limited time one has for their stated reason of visiting the borough? Would one call through to the borough on Sunday asking for assistance or rather search online to be told "The London Borough of Newham rely on information stated on the London Stadium website, which it has no control over and unfortunately this may not always show the full schedule of upcoming events. As a precaution all motorists should check the parking signs displayed at the relevant locations to see if an event is taking place’. The signs in place are updated prior to each event at the stadium" Should Newham desire to enforce an Event Day there must be Event Day in force notice, erected upon signage, that is nearby, adequate, clearly visible and legible, so motorists can be informed as per the duty of the local authority.[/hr]

I been recommended a person who deal with PCN for a small fee ... I realised how he works
https://imgur.com/a/bEA8Lzv

• So did the recommended person (for a small fee) complete (fill in) your Statutory Declaration for you OR did you after realising how the recommended person works, having used the recommended person's services previously, complete (fill in) the Statutory Declaration yourself by copying his statement?
  
• TEC has indeed given you the correct advice that you must send proof to TEC via email, with the Subject: UNPROCESSED FORMS (PCN NUMBER), enclosing your original email to TEC, enclosing the attached form, proving you had submitted the correctly completed form in time to TEC. Subsequently contact TEC via telephone to notify TEC of your email (unprocessed form) including the time and date.
• I've been in the exact same situation, as you, so I hope that satisfies your question?