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The Claimant relies on an internal agreement between SIP Parking Ltd and SIP Car Parks (1) Ltd. Neither of these parties is the landowner, and no evidence has been provided to suggest that either holds a lease, licence, or other proprietary interest in the land at Nelson Street, Leicester.

The absence of any signed agreement with the landowner or a title register extract confirming ownership by the Claimant fatally undermines their ability to offer parking contracts or pursue enforcement. This is a fundamental requirement established in Vehicle Control Services v HMRC [2013] EWCA Civ 186.

It is telling that the Claimant—who bears the burden of proof—has not stated anywhere in their Particulars of Claim or witness statement that they are the freeholder or leaseholder of the land in question. Nor have they exhibited a contract with the actual landowner. The Court is invited to draw the reasonable inference that neither SIP Parking Ltd nor its related company has the requisite authority to pursue this claim.

IN THE COUNTY COURT LEICESTER

Claim No: [Claim Number]

BETWEEN:

SIP Parking Ltd
Claimant

- and -

[Defendant's Full Name]

Defendant

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WITNESS STATEMENT

1. I am the Defendant in this matter and the registered keeper and driver of the vehicle on the date in question. The facts stated in this witness statement are true to the best of my knowledge, belief, and recollection.

2. On 2 August 2022, I parked at Nelson Street, Leicester and paid for a 3-hour parking session using the method prescribed at the location. I made a genuine attempt to comply with the advertised terms of parking by paying for a substantial period in advance.

3. I left the site and returned later that day. Based on the times the Claimant has now disclosed, the total stay may have slightly exceeded the paid-for period. However, I acted in good faith and never intended to avoid payment.

4. Upon receiving a Parking Charge Notice (PCN), I recall submitting an appeal via the Claimant’s website explaining the situation. I believe I offered to cover any underpayment should there have been a minor overstay. I have searched but cannot locate a copy of that appeal or any response. Nonetheless, I acted promptly and in good faith.

5. The Claimant is SIP Parking Ltd, a company incorporated in England and Wales with company number 08456205, whose registered office is Peter House, Oxford Street, Manchester M1 5AN. The Claimant asserts that it has authority to manage the site and issue PCNs.

6. However, when I received the Claim Form, the Particulars of Claim (PoC) were extremely vague. They did not include a copy of the contract or PCN, did not state how or where I was said to have breached any terms, and did not make clear whether I was being pursued as driver or keeper. There was also no breakdown of the amount claimed or how it had been calculated.

7. As a result, I filed a defence focused on the Claimant’s failure to comply with CPR 16.4. I also submitted a draft order requesting that the court require the Claimant to provide further and better particulars. However, the court did not make such an order and instead allocated the matter to a hearing.

8. This course of action disadvantaged me significantly. The overriding objective under CPR 1.1 requires the court to deal with cases justly and fairly, ensuring that the parties are on an equal footing and that proceedings are conducted efficiently and proportionately. I submit that allowing the claim to proceed without requiring proper PoC was not consistent with those principles.

9. It was not until 9 April 2025, just two days before my own witness statement deadline, that I received the Claimant’s witness statement and exhibits. That was the first time I saw any evidence relating to the alleged contract, signage, and the basis for the sum claimed. Only then did I finally understand the legal and factual basis of the claim.

10. Due to the lateness and volume of material disclosed by the Claimant at that stage, I required time to properly review and respond. My own witness statement is therefore being filed one day after the court deadline, and I respectfully request that it be accepted in the interests of justice and in accordance with CPR 1.1.

11. The Claimant relies on a document titled “Parking Management Service Agreement,” stated to commence on 1 August 2018. However, the signature page of this document is undated, casting doubt on when it was executed, if at all. More significantly, the agreement is not between the Claimant and the leaseholder of the site. Instead, it is a purely internal arrangement between two separate and legally distinct companies:

• SIP Parking Ltd (Company No. 08456205), the Claimant; and
• SIP Car Parks (1) Ltd (Company No. 08482680), which is not the landowner or leaseholder.

12. The Land Registry title for the site—exhibited at XX-01—confirms that the leaseholder of the car park at Nelson Street, Leicester (postcode LE1 7BA), under title number LT504504, is SIP Car Parks Limited (Company No. 11244191). The lease was granted by Culsom (UK) Ltd and Sansom Enterprises (Midlands) Ltd, commencing on 23 March 2018 and expiring on 24 March 2028. Neither SIP Parking Ltd nor SIP Car Parks (1) Ltd is mentioned in the lease title.

13. It follows that the Claimant, SIP Parking Ltd (08456205), holds no proprietary interest in the land. Nor does SIP Car Parks (1) Ltd (08482680), the party named in the contract with the Claimant. The two entities are distinct from SIP Car Parks Limited (11244191), which is the actual leaseholder.

14. The Claimant has not produced any documentary evidence—such as a sublease, a licence to manage, or a formal agency agreement—granting it authority from SIP Car Parks Limited to operate the site or enforce parking terms in its own name. No such agreement has been exhibited.

15. This absence of evidence is crucial. It is well established that a party seeking to enforce a parking contract must either have a proprietary interest in the land or possess valid written authority from the landholder to do so. In Vehicle Control Services Ltd v HMRC [2013] EWCA Civ 186, the Court of Appeal held that a party without landowner authority cannot offer contracts or enforce them.

16. The Claimant attempts to circumvent this legal requirement by relying on a contract with SIP Car Parks (1) Ltd. However, this is legally ineffective. SIP Car Parks (1) Ltd is neither the landowner nor the leaseholder, and there is no evidence that it holds any assignable interest or authority from SIP Car Parks Limited.

17. Furthermore, entry 3 of the Land Registry title expressly states that the lease is subject to restrictions on alienation. This means that SIP Car Parks Limited cannot assign, sublet, or licence the land—or any rights under the lease—without the landlord’s consent. The Claimant has not produced any evidence that such consent was sought or granted, nor that any such delegation of authority was even attempted.

18. In light of the above, the Claimant lacks the legal capacity to offer parking contracts to motorists, to enforce any alleged terms, or to bring this claim in its own name. The alleged contract between the Claimant and the Defendant is therefore void, as the Claimant had no legal standing to enter into it. Any purported agreement is ultra vires and unenforceable.

19. Even if authority could somehow be inferred, the signage provided by the Claimant does not create a fair or transparent contract. The core parking charge is buried in dense text and is not prominent. The sign fails to meet the standard required under ParkingEye v Beavis [2015] UKSC 67, where the charge amount was large, prominent, and unambiguous.

20. It is not credible that I could have seen and understood the full terms, including any liability for a £100 charge, particularly in a short-stay car park where drivers are not expected to spend time reading large blocks of small print while under time pressure to pay and park. The alleged event occurred after dark, and the Claimant has not produced a single photograph showing the site in nighttime conditions.

21. The Claimant’s signage photographs are all taken in daylight and are of poor quality. The text is small, cluttered, and mostly unreadable even in ideal lighting conditions. None of the photographs are date-stamped or time-stamped. There is no evidence that they accurately reflect the signage present on the date of the alleged contravention or that they represent the visibility conditions as they were at the time.

22. Crucially, there is no entrance signage shown or referred to in the Parking Management Service Agreement, nor is any entrance sign visible in any of the images. This is a fundamental omission. Schedule 1 of the IPC Code of Practice (Version requires that “where a Car Park has a defined entrance, Operators should display entrance signs.” The Claimant has failed to comply with this basic requirement.

23. IPC Code of Practice Section 8.1 states: “The Operator must have clear signage located on the Private Land to confirm the Terms and Conditions in place.” Section 8.2 requires that the signage conform to the layout and presentation standards set out in Schedule 1. These include that signs must be clear, legible, and visible to motorists in the conditions in which enforcement occurs. Schedule 1 also requires that the text must be of an appropriate size and that signs used at night must be illuminated or otherwise made visible. The Claimant has not satisfied any of these requirements.

24. There is no evidence before the court that the signs were illuminated, nor that they were visible in darkness. No evidence has been produced of the lighting conditions in the car park, and the Claimant has provided no photographs showing visibility of the signage at night. It cannot be presumed that terms were effectively communicated, especially when all images are in daylight and of unreadable quality.

25. The Claimant seeks £100 for the alleged parking charge and a further £60 described variously as “debt damage,” “debt recovery,” or “enforcement” costs. There is no evidence that these additional sums were part of any contract I entered into, nor that they represent any genuine or incurred loss. At no point do the signs refer to a £60 surcharge being imposed in addition to the core charge.

26. Section 15.3 of the IPC Code of Practice permits a “reasonable sum” to be added to a parking charge once it becomes overdue, capped at £70 unless court proceedings have been initiated. However, the key requirement is that the added sum must be reasonable. The Claimant has provided no breakdown, no supporting documentation, and no explanation of how or why £60 is a reasonable or proportionate addition. It appears to be a pre-set figure imposed automatically, contrary to the requirements of the Code.

27. The £60 add-on is therefore arbitrary and unsupported. It is not referenced in the signage or PCN, nor has it been shown to relate to any specific loss or cost incurred. Its inclusion renders the claim unfair and potentially unlawful under the Consumer Rights Act 2015, which requires contract terms to be fair, transparent, and not cause a significant imbalance between the parties.

28 In addition to the above, the Claimant’s own documentation is inconsistent and contradictory in terms of the amount demanded. The original Parking Charge Notice dated 2 August 2022 refers to a charge of £100. However, a letter dated 8 September 2022 demands £115 without explanation. A further letter dated 26 September 2022 demands £125, composed of a £100 charge plus a £25 “overdue fee.” A letter dated 14 October 2022 then demands £160, comprising the £100 charge plus a £60 “overdue fee.” These amounts differ significantly without any contractual or evidential justification.

29. The Claimant has therefore variously demanded four different amounts for the same alleged contravention—£100, £115, £125, and £160—without consistency, explanation, or transparency. These discrepancies were not disclosed at the time and only became apparent through the contents of the Claimant’s witness statement.

30. The shifting and inconsistent presentation of the debt is both confusing and prejudicial. It has made it impossible for me to know what was actually being demanded or on what basis. The claim lacks clarity, fails to meet the standards required by CPR 16.4, and falls well short of the transparency obligations imposed by both consumer law and the IPC Code of Practice.

31. The court is respectfully invited to find that the additional £60 fee is not recoverable and that the cumulative failings in signage, evidence presentation, and procedural conduct cast serious doubt on the credibility and enforceability of the entire claim.

32. For the reasons set out above, I respectfully submit that the claim is entirely without merit. The Claimant has failed to demonstrate authority to operate at the site, has not produced reliable evidence of any contract being formed, and has pursued an incoherent and inconsistent claim based on unreadable signage and unjustified fees.

33. I invite the Court to dismiss the claim.


Statement of truth

I believe that the facts stated in this witness statement are true. I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth.

Signed:


Date: