Did that seem to be better? I have not submitted anything to them as yet

Thanks

Is this defence sounding OK?

1) The Defendant is the registered keeper of vehicle registration DP67DWN. The Defendant has no reliable recollection of who was driving on the material date and does not admit being the driver. The Defendant puts the Claimant to strict proof of the identity of the driver or, alternatively, of compliance with the statutory requirements for transferring liability to the registered keeper under Schedule 4 of the Protection of Freedoms Act 2012 (“POFA”).
2) The allegation(s) are vague and liability is denied for the sum claimed, or at all. The delay between the alleged parking event on 22 March 2026 and the issue of proceedings on 16 September 2026 lies with the Claimant, making the retrieval of material evidence more difficult and potentially prejudicial to the Defendant. The Defendant has no reliable recollection of the events, including the identity of the driver, and cannot be expected to recall the details of a visit several months earlier. The Defendant admits only to being the registered keeper of the vehicle.
3) The Claimant is required to prove the contractual terms allegedly displayed at the site on the material date, including the maximum permitted stay, the circumstances in which a charge would become payable, and the adequacy and prominence of the signs. The Defendant does not admit that the Claimant’s signage created a sufficiently clear and enforceable contract on the terms alleged.
4) The Claimant is put to strict proof of its standing to bring this claim. It must establish that it had sufficient authority from the landowner or a person entitled to grant such authority to offer parking contracts, impose charges, and pursue those charges in its own name.
6) The Claimant appears to rely alternatively on the Defendant being the driver or the registered keeper. The Defendant does not admit being the driver. If the Claimant cannot prove driver liability, it must establish that every applicable condition of POFA Schedule 4 was satisfied before keeper liability can arise.
6) The Notice to Keeper was dated 26 March 2026 and the Defendant received it on 30 March 2026. The Defendant does not allege that the notice was delivered outside the 14-day period merely on the basis of those dates. However, the Claimant is required to prove compliance with all applicable requirements of POFA Schedule 4, including the prescribed contents of the notice, the relevant parking period, the creditor’s identity, and the statutory conditions for recovery from a keeper.
7) The Claimant’s Letter Before Claim dated 11 August 2026 demanded £170, described as including the parking charge and debt-recovery costs. The original Notice to Keeper stated a parking charge of £100, with a reduced amount of £60 for early payment. The Letter Before Claim does not, in the wording available to the Defendant, itemise the additional £70 or explain the contractual or legal basis on which it is said to be recoverable.
The Defendant disputes the recoverability of the additional £70. The Claimant is required to identify the legal basis for this sum, explain how it was calculated, and prove that it represents a recoverable liability rather than an additional charge duplicating costs already incorporated into the parking charge or the costs of pursuing litigation. The Defendant does not accept that the mere description “debt recovery costs” establishes entitlement to the sum.
9) The Defendant notes that the Particulars of Claim seek £175.96, in addition to a £35 court fee and £50 legal representative’s costs, giving a stated total of £260.96. The Claimant is required to provide a clear breakdown of the £175.96, including the principal sum, any additional charges, and the calculation and legal basis of the £5.96 interest component, if that is what the sum represents.
10) The Defendant does not admit that the Claimant is entitled to the interest claimed. The Claimant is required to identify the principal sum on which interest is sought, the applicable rate, the dates used, and the calculation relied upon, and to establish its entitlement under section 69 of the County Courts Act 1984.
11) The Defendant notes that the Particulars of Claim refer to a parking charge and damages. The Claimant is required to explain the legal basis of each head of claim and demonstrate that the total sought is not duplicative or an attempt to recover costs that are not otherwise recoverable.
12) The Defendant recognises that the Supreme Court considered the enforceability of a private parking charge in ParkingEye Ltd v Beavis [2015] UKSC 67. The Defendant does not accept that the decision establishes that every parking charge, or every additional sum appended to it, is automatically enforceable. The Claimant must establish the terms, circumstances and sums applicable to this particular claim.
13) The Defendant reserves the right to rely on relevant authorities concerning the adequacy of Particulars of Claim and the recovery of additional sums, including Civil Enforcement Ltd v Chan (County Court appeal, claim E7GM9W44) and CPMS v Akande (County Court appeal, claim K0DP5J30), to the extent applicable. The Defendant does not suggest that those decisions automatically determine this claim.
14) In light of the matters set out above, the Defendant denies that the Claimant has established an entitlement to the sums claimed. The Claimant is put to strict proof of its case.

Ok guys, finally managed to get up to the parking spot this weekend and today I got an official claim letter from HMRC so they do want my blood it seems, or at least, my money.

Firstly the parking sign


Particulars of claim


Should I share the CCJ details? Not sure what to redact, claim number and any personal details I suppose, very much in over my head as it's the first time I've got to this point so the form may have something on I'm not sure about that I need to redact but here are some details:

DCB Legal are the claimant
Amount claimed £175.96
Court Fee £35
Legal Representative's cost £50
Issue date 16th September
Must respond with 14 days of the day of service so I imagine that would be 30th September (so lost 6 days as I only received this today!)

Thanks all

Sure thing, sorry it's a little dark as it's late!

Yeh, I am not even sure where they would be, perhaps on another side of the post.

OP, if you are the registered keeper then, as their letter says, 'please wait for a further letter'.

IMO, rise above the minutiae pl, don't feel that everything they write must be countered, it doesn't. While you're waiting for this 'further letter', do you have photos or GSV of the signs at the site?

I've only got the pic of the sign I attached in the original post. Not sure what GSV is though?

Sure here is the attachment, the text I put in my previous post was the entirety of the email otherwise.

They have still not responded to my query about parking versus penalty charge. It's been 2 emails and almost 2 weeks now!