3. Claim Form UK parking patrol office limited / BW Legal PCN
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Claim Form UK parking patrol office limited / BW Legal PCN
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Hi,

I'm helping a neighbour with a private PCN that has advanced to a N1SDT claim form. He had ignored all letters received and discarded them. He does not even recall being parked in the place in question as he is away on work very frequently and his car is in use by other family members.

The claim form issue date is 18th of May and I helped him file an acknowledgement of service on 3rd of June. We need to file the defence. Is there a specific defence template and draft order for Uk Parking Patrol Office?

Also the claim form states

"D is liable driver, or keeper per Sch. 4 PoFA2012. C also claims £70.00 contractual recovery costs as set out in its terms and conditions and the ATA Code of Practice."

Im guessing thats not correct as the keeper is not liable.

For some reason I'm having trouble uploading the paperwork, will try and use another phone to do it shortly.

thanks.
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Re: Claim Form UK parking patrol office limited / BW Legal PCN
« Reply #1 on: »
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Im guessing thats not correct as the keeper is not liable.
How have you reached that conclusion without sight of the original parking charge notice?

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Is there a specific defence template and draft order for Uk Parking Patrol Office?
I would recommend against a template defence. Some of the ones previously suggested on here are fairly frequently being struck out on the basis that they do not properly respond to the claim.
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Re: Claim Form UK parking patrol office limited / BW Legal PCN
« Reply #2 on: »
Sorry regarding the liability I phrased it incorrectly. I meant they have not identified the defendant as the driver or keeper in the PoC. Am I mistaken?

Are you saying this a lost cause and and think he should just pay up?

Many thanks for your input.
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Re: Claim Form UK parking patrol office limited / BW Legal PCN
« Reply #3 on: »
Quote from: Moaya on June 18, 2026, 10:58:06 pm

Are you saying this a lost cause and and think he should just pay up?



No, nobody said that. Quite the opposite in fact.

If you could post up the original PCN and the Claim Form then we can advise.

Obviously redact only personal info and password.
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Re: Claim Form UK parking patrol office limited / BW Legal PCN
« Reply #4 on: »
He only has the claim form which I will link below. He doesn't have any of the original PCNs.

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Re: Claim Form UK parking patrol office limited / BW Legal PCN
« Reply #5 on: »
So 22 June deadline for a defence.

If a Subject Access Request had been sent to the car park operator, the original PCN could have been obtained. But it’s too late now. Wisdom of hindsight - don’t ignore and throw away.

Any defence needs to be specific to the claim, in particular to the Particulars of Claim which are the usual rubbish. “Parked causing an obstruction”.

PoFA 2012 can be used to transfer liability to the registered keeper, but without the original PCN we can’t tell whether or not this was done properly. If it was, the keeper is now liable regardless of who the driver was.
« Last Edit: June 19, 2026, 12:54:13 pm by jfollows »
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Re: Claim Form UK parking patrol office limited / BW Legal PCN
« Reply #6 on: »
I've told him numerous times not to throw things away, he was under the impression that you should still ignore private parking letters. He almost threw away the claim form before I stopped him and told him he needs to take it seriously.

As far as I can see this company rarely takes matters to county court.

At this point do I just advise to take it on the chin and pay up or is there anything he can do. I get the feeling he would rather prolong the whole process for them rather than pay up these cowboys.

thanks
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Re: Claim Form UK parking patrol office limited / BW Legal PCN
« Reply #7 on: »
Quote from: Moaya on June 19, 2026, 06:25:52 pm


As far as I can see this company rarely takes matters to county court.

They already have done.
Whether or not they discontinue before paying the court fee remains to be seen.
They hope that your friend throws the claim form away because then they will apply for and obtain a judgement in default against your friend.

The deadline for response, either by filing an Acknowledgement of Service or a defence was 8 June.
If an AoS was filed by 8 June, the deadline for filing a defence is 22 June.

If the 8 June deadline was missed, there may already be a default judgement against the defendant. But you say above that AoS was filed.

Either file a defence or pay up! But the defence really needs needs to be specific to this case and its circumstances. Not some boilerplate generic stuff. The keeper is liable if the Protection of Freedoms Act 2012 has been correctly applied to transfer liability from the unknown driver to the registered keeper.

Without the original PCN it’s hard to conclude whether or not this process was correctly followed.

In the absence of this I would suggest you stop wasting your time and tell your friend to stop throwing important things away.
« Last Edit: June 19, 2026, 07:41:23 pm by jfollows »
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Re: Claim Form UK parking patrol office limited / BW Legal PCN
« Reply #8 on: »
So we need to enter a skeleton defence which broadly defends the claim.

I have found a previous UK Parking Patrol NtK from earlier this year so we will assume that the wording was similar.


Skeleton defence;


1. That the claim is denied in its entirety and no money is owed by myself to the Claimant.

2. That it is acknowledged that I was the Registered Keeper of the vehicle at the material time.

3. That the driver of the vehicle is not known to the Claimant and there is no legal requirement for a vehicle keeper to provide that information to the Claimant and, as such, I will not be providing that information under any circumstance.

4. That the Claimant is attempting to invoke what is known as 'keeper liability' via the use of Protection of Freedoms Act 2012 (PoFA).

5. That in order to invoke keeper liability under PoFA the Claimant's Notice to Keeper (NtK) is required to meet a very strict set of conditions which are set out in Schedule 4 Paragraph 9(2) of the Act.

6. That in this instance the Claimant's NtK fails to meet numerous requirements under Schedule 4 Paragraph 9(2) of PoFA and therefore keeper liability is not available to the Claimant.

7. That with the driver unknown and no keeper liability available, there is no legal route to liability in this matter.

8. That the claim is therefore denied in its entirety.


Submit the above through MCOL adding all the other procedural details required.




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