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Private parking tickets / Re: NtK - Euro Car Parks
« on: June 01, 2026, 12:16:03 pm »
No worries, thanks.
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Private parking tickets / Re: NtK - Euro Car Parks
« on: June 01, 2026, 12:03:51 pm »
Thanks. Does it matter that the solicitors in this case are DCB Legal though? Not Moorside.
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Private parking tickets / Re: NtK - Euro Car Parks
« on: June 01, 2026, 10:18:58 am »No.
Just the defence.
Don't overthink this.
That I am the named defendant and I deny any liability in this matter.
That the vehicle driver is not known to the Claimant and there is no legal requirement for me to identify the driver.
That the Claimant has provided no evidence as to who the driver was.
That the Claimant's Notice to Keeper does not comply with Protection of Freedoms Act (2012)(PoFA) and as such liability cannot be transferred myself.
That, in particular, the Claimant's Notice to Keeper does not meet the requirements of PoFA Schedule 4 Paragraph 9(2)(e) - the mandatory wording and two limbed legal choice required by the paragraph is not present on the Claimant's NtK and, as such, total compliance is not achieved.
That this means that there is no legal route to me being liable for the alleged debt.
Thanks. Appreciate the help. These things feel massively confusing!
Defence submitted. Should I expect the N180DQ via email next?
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Private parking tickets / Re: NtK - Euro Car Parks
« on: June 01, 2026, 08:48:02 am »I'd personally leave that out for the moment.
You will still have the chance to submit a witness statement if the matter progresses.
A defence which is short and to the point makes it clear that you know where you really stand.
This is very unlikely to progress to a hearing.
You are entering a defence purely to avoid a default judgement.
Thanks.
Would you include photos of signage and attatch the NtK at this stage?
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Private parking tickets / Re: NtK - Euro Car Parks
« on: June 01, 2026, 07:34:05 am »
Hi everyone, I need to submit this today or I miss my chance to defend.
Would you leave in the part where I've explained what happened to the driver on the day?
Thanks
Would you leave in the part where I've explained what happened to the driver on the day?
Thanks
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Private parking tickets / Re: NtK - Euro Car Parks
« on: May 25, 2026, 08:56:06 am »I would start with the non compliant PoFA element since this immediately disqualifies the claim.
Something along the lines of;
That I am the named defendant and I deny any liability in this matter.
That the vehicle driver is not known to the Claimant and there is no legal requirement for me to identify the driver.
That the Claimant has provided no evidence as to who the driver was.
That the Claimant's Notice to Keeper does not comply with Protection of Freedoms Act (2012)(PoFA) and as such liability cannot be transferred myself.
That, in particular, the Claimant's Notice to Keeper does not meet the requirements of PoFA Schedule 4 Paragraph 9(2)(e) - the mandatory wording and two limbed legal choice required by the paragraph is not present on the Claimant's NtK and, as such, total compliance is not achieved.
That this means that there is no legal route to me being liable for the alleged debt.
That's great, thanks.
So would you remove the part where I give an explanation as to what actually happened on the day with regards to the driver?
And then just go on to highlight my original reply to ECP which covers the other matters?
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Private parking tickets / Re: NtK - Euro Car Parks
« on: May 24, 2026, 11:06:52 pm »You’ve still got “bit PoFA compliant”
Appreciate it, but I've already amended that on my draft copy offline. I reposted the original defence from my previous post because I was hoping for a bit more in-depth advice beyond spell checking. But perhaps my defence is already fine! Thanks.
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Private parking tickets / Re: NtK - Euro Car Parks
« on: May 24, 2026, 11:05:28 pm »ECP NtKs fail to comply with paragraph 9(2)(e) full stop - I wouldn't specifically mention 9(2)(e)(i) - just say 9(2)(e).
That's really helpful, thanks. Is there anything else you'd change? Or am I overthinking this? Are they going to give up as soon as they receive any reaosnabt defence?
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Private parking tickets / Re: NtK - Euro Car Parks
« on: May 23, 2026, 10:21:48 am »
Please could someone cast their eye over the following defence before I submit it online? TIA.
The driver went to view a flat. The landlord told them to park behind building A and said that they were covered by a residents permit. The driver saw the ECP sign but due to how illegible it was and holding the honestly held belief that they were covered by a residents permit parked up, walked round to the flat and when they got no answer called the landlord. Turned out the landlord had given the driver the wrong address. He should have sent the driver to building B which is next door and has it's own car park. The driver left the car park after 14 minutes.
The communications between the landlord and driver were by phone and the landlord is no longer contactable.
An appeal was submitted to the original NtK as follows:
I am the keeper of the vehicle and I dispute your 'parking charge'. I deny any liability or contractual agreement and I will be making a complaint about your predatory conduct to your client landowner.
As your Notice to Keeper (NtK) does not fully comply with ALL the requirements of PoFA 2012, you are unable to hold the keeper of the vehicle liable for the charge. Partial or even substantial compliance is not sufficient. There will be no admission as to who was driving and no inference or assumptions can be drawn. ECP 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. ECP have no hope at POPLA, so you are urged to save us both a complete waste of time and cancel the PCN.
PoFA paragraph 9(2)(e)(i) has not been complied with. The NtK did not specifically invite the Keeper to pay the charge.
In big bold writing on the front of the NtK it says that payment is to be made within 28 days of issue. Section 8.1.2(e) of the PPSCoP says that the recipient of a notice has 28 days from the date of receipt, not date of issue.
The ECP sign in the car park mentioned is bit PoFA compliant with paragraph 2(2) or 2(3) as they do not adequately bring the charge to the attention of the driver (Ref Beavis case).
I have asked ECP to provide proof that they have a valid contract flowing from the landowner that permits them to issue PCNs at the location. They have failed to do so.
The driver went to view a flat. The landlord told them to park behind building A and said that they were covered by a residents permit. The driver saw the ECP sign but due to how illegible it was and holding the honestly held belief that they were covered by a residents permit parked up, walked round to the flat and when they got no answer called the landlord. Turned out the landlord had given the driver the wrong address. He should have sent the driver to building B which is next door and has it's own car park. The driver left the car park after 14 minutes.
The communications between the landlord and driver were by phone and the landlord is no longer contactable.
An appeal was submitted to the original NtK as follows:
I am the keeper of the vehicle and I dispute your 'parking charge'. I deny any liability or contractual agreement and I will be making a complaint about your predatory conduct to your client landowner.
As your Notice to Keeper (NtK) does not fully comply with ALL the requirements of PoFA 2012, you are unable to hold the keeper of the vehicle liable for the charge. Partial or even substantial compliance is not sufficient. There will be no admission as to who was driving and no inference or assumptions can be drawn. ECP 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. ECP have no hope at POPLA, so you are urged to save us both a complete waste of time and cancel the PCN.
PoFA paragraph 9(2)(e)(i) has not been complied with. The NtK did not specifically invite the Keeper to pay the charge.
In big bold writing on the front of the NtK it says that payment is to be made within 28 days of issue. Section 8.1.2(e) of the PPSCoP says that the recipient of a notice has 28 days from the date of receipt, not date of issue.
The ECP sign in the car park mentioned is bit PoFA compliant with paragraph 2(2) or 2(3) as they do not adequately bring the charge to the attention of the driver (Ref Beavis case).
I have asked ECP to provide proof that they have a valid contract flowing from the landowner that permits them to issue PCNs at the location. They have failed to do so.
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Private parking tickets / Re: NtK - Euro Car Parks
« on: May 17, 2026, 08:07:42 pm »
Hi,
Apologiesnfor bumping this again, but having not had any advice on the defence I had written I've submitted an AOS to give me more time to get the defence checked.
Is anyone able to have a look over it please? It's just a few replies back. Thanks.
Apologiesnfor bumping this again, but having not had any advice on the defence I had written I've submitted an AOS to give me more time to get the defence checked.
Is anyone able to have a look over it please? It's just a few replies back. Thanks.
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Private parking tickets / Re: NtK - Euro Car Parks
« on: May 08, 2026, 03:28:08 pm »
Hi everyone,
Could someone please give me any feedback on my defence?
Thanks
Could someone please give me any feedback on my defence?
Thanks
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Private parking tickets / Re: NtK - Euro Car Parks
« on: May 05, 2026, 12:23:25 pm »You have “bit PoFA compliant”, do you mean “not PoFA compliant”?
Yes
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Private parking tickets / Re: NtK - Euro Car Parks
« on: May 05, 2026, 08:36:43 am »
Good morning, bumping this in the hope someone can have a look over my defence before I submit it online. Thanks.
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Private parking tickets / Re: NtK - Euro Car Parks
« on: May 02, 2026, 11:23:36 am »
Please could someone cast their eye over the following defence before I submit it online? TIA.
The driver went to view a flat. The landlord told them to park behind building A and said that they were covered by a residents permit. The driver saw the ECP sign but due to how illegible it was and holding the honestly held belief that they were covered by a residents permit parked up, walked round to the flat and when they got no answer called the landlord. Turned out the landlord had given the driver the wrong address. He should have sent the driver to building B which is next door and has it's own car park. The driver left the car park after 14 minutes.
The communications between the landlord and driver were by phone and the landlord is no longer contactable.
An appeal was submitted to the original NtK as follows:
I am the keeper of the vehicle and I dispute your 'parking charge'. I deny any liability or contractual agreement and I will be making a complaint about your predatory conduct to your client landowner.
As your Notice to Keeper (NtK) does not fully comply with ALL the requirements of PoFA 2012, you are unable to hold the keeper of the vehicle liable for the charge. Partial or even substantial compliance is not sufficient. There will be no admission as to who was driving and no inference or assumptions can be drawn. ECP 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. ECP have no hope at POPLA, so you are urged to save us both a complete waste of time and cancel the PCN.
PoFA paragraph 9(2)(e)(i) has not been complied with. The NtK did not specifically invite the Keeper to pay the charge.
In big bold writing on the front of the NtK it says that payment is to be made within 28 days of issue. Section 8.1.2(e) of the PPSCoP says that the recipient of a notice has 28 days from the date of receipt, not date of issue.
The ECP sign in the car park mentioned is bit PoFA compliant with paragraph 2(2) or 2(3) as they do not adequately bring the charge to the attention of the driver (Ref Beavis case).
I have asked ECP to provide proof that they have a valid contract flowing from the landowner that permits them to issue PCNs at the location. They have failed to do so.
I understand having read other threads that I now need to raise my defence via the money claim website. I've found a step by step guide in another thread which I'll use. Following that I'll probably receive an N180 DQ which I'll ignore and then fill out my own N180 DQ and email it to them. Is that correct?
I can't tell you how much all the support and advice on here is appreciated. I started to panic last night but having read the advice I'm staying calm and staying the course. Eff these guys.
The driver went to view a flat. The landlord told them to park behind building A and said that they were covered by a residents permit. The driver saw the ECP sign but due to how illegible it was and holding the honestly held belief that they were covered by a residents permit parked up, walked round to the flat and when they got no answer called the landlord. Turned out the landlord had given the driver the wrong address. He should have sent the driver to building B which is next door and has it's own car park. The driver left the car park after 14 minutes.
The communications between the landlord and driver were by phone and the landlord is no longer contactable.
An appeal was submitted to the original NtK as follows:
I am the keeper of the vehicle and I dispute your 'parking charge'. I deny any liability or contractual agreement and I will be making a complaint about your predatory conduct to your client landowner.
As your Notice to Keeper (NtK) does not fully comply with ALL the requirements of PoFA 2012, you are unable to hold the keeper of the vehicle liable for the charge. Partial or even substantial compliance is not sufficient. There will be no admission as to who was driving and no inference or assumptions can be drawn. ECP 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. ECP have no hope at POPLA, so you are urged to save us both a complete waste of time and cancel the PCN.
PoFA paragraph 9(2)(e)(i) has not been complied with. The NtK did not specifically invite the Keeper to pay the charge.
In big bold writing on the front of the NtK it says that payment is to be made within 28 days of issue. Section 8.1.2(e) of the PPSCoP says that the recipient of a notice has 28 days from the date of receipt, not date of issue.
The ECP sign in the car park mentioned is bit PoFA compliant with paragraph 2(2) or 2(3) as they do not adequately bring the charge to the attention of the driver (Ref Beavis case).
I have asked ECP to provide proof that they have a valid contract flowing from the landowner that permits them to issue PCNs at the location. They have failed to do so.
I understand having read other threads that I now need to raise my defence via the money claim website. I've found a step by step guide in another thread which I'll use. Following that I'll probably receive an N180 DQ which I'll ignore and then fill out my own N180 DQ and email it to them. Is that correct?
I can't tell you how much all the support and advice on here is appreciated. I started to panic last night but having read the advice I'm staying calm and staying the course. Eff these guys.
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