Hi dedicated team,
I prepared this draft with the help of AI. Could you please go through and help me in this matter? Please let me know if you require more information.
Let me tell you a little bit background. In November 2025 I parked in private land where I paid I believe. In May 2026 I received a letter from DCB legal that I didn’t pay. They said me to pay £175. Once I receive letter, I emailed them and told that I just received letter now first time. They said that they sent letter in previous address. I emailed them I believe I have already paid parking charges. I requested them to check cash transactions on that specific time and date but they didn’t provide me that details. They only provided car entry and exit time. Now I received a letter from court. For which I prepared draft.
DEFENCE DOCUMENT (STRENGTHENED)
IN THE COUNTY COURT
Claim No: [INSERT YOUR CLAIM NUMBER HERE]
BETWEEN:
[INSERT CLAIMANT'S NAME — e.g., the parking company]
Claimant
- and -
[YOUR FULL NAME]
Defendant
DEFENCE
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1. Introduction
1.1 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.
1.2 The Defendant is unable to plead fully to the Particulars of Claim because they lack precise detail in respect of the factual and legal allegations made. The Particulars of Claim do not comply with CPR 16.4 and PD 16, as they fail to state the exact wording of the contractual terms relied upon, the precise nature of the alleged breach, and how the sum claimed is calculated. The Defendant invites the Court to strike out or require the Claimant to amend the Particulars of Claim pursuant to CPR 3.4.
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2. Failure to Comply with the Protection of Freedoms Act 2012 ("POFA")
2.1 The Defendant avers that the Claimant has failed to comply with the requirements of Schedule 4 of the Protection of Freedoms Act 2012 and is therefore unable to rely on keeper liability.
2.2 In particular, the Claimant failed to serve a compliant Notice to Keeper on the Defendant at the Defendant's current address. The Notice to Keeper was sent to a previous address at which the Defendant no longer resided, and the Defendant never received it.
2.3 The Claimant is put to strict proof that a compliant Notice to Keeper was properly served in accordance with the statutory time limits and content requirements set out in POFA.
2.4 In the absence of a compliant Notice to Keeper, the Claimant cannot hold the Defendant liable as the keeper of the vehicle. The Claimant has not identified the driver, and the Defendant is not obliged to do so.
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3. The Defendant's Genuine Belief That Payment Was Made
3.1 The Defendant's genuine recollection is that a cash payment was made for parking on the date in question.
3.2 The Defendant is a law-abiding individual who has never intentionally avoided a parking charge. The sum involved was no more than £3–£5. It is inherently improbable that the Defendant would risk court proceedings, debt collection, and a potential County Court Judgment over such a trivial sum.
3.3 The Defendant disputes the allegation that no payment was made.
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4. The ANPR Evidence Does Not Prove Non-Payment
4.1 The ANPR images relied upon by the Claimant show only the times of entry and exit to the site. They do not establish whether a cash payment was made during the period of parking.
4.2 The Defendant has repeatedly requested that the Claimant review its payment machine records for the relevant date and time, including cash transactions and any payments that may not have been correctly matched to a vehicle registration due to a keying error or other discrepancy.
4.3 The Claimant has failed to provide this evidence, despite the Defendant's reasonable and repeated requests. The Claimant is put to strict proof that no payment was made.
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5. Breach of the Pre-Action Protocol for Debt Claims
5.1 The Defendant avers that the Claimant has failed to comply with the Pre-Action Protocol for Debt Claims.
5.2 The Defendant made a reasonable request for the Claimant to review its payment machine records, including cash transactions and potential keying errors, prior to the issuance of proceedings.
5.3 The Claimant failed to provide this information, despite the Protocol requiring parties to exchange sufficient information and disclose documents to understand each other's position.
5.4 This refusal deprived the Defendant of the opportunity to resolve the matter without litigation and is a matter the Defendant will invite the Court to consider when assessing costs.
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6. Other Matters Put to Strict Proof
6.1 The Claimant is put to strict proof of all elements of its claim, including but not limited to:
(a) the existence of a valid contract formed between the Claimant and the driver;
(b) the adequacy and prominence of the signage at the site;
(c) the Claimant's authority to operate and litigate at the site;
(d) the lawfulness of any added sums claimed beyond the original parking charge.
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7. Conclusion
7.1 For the reasons set out above, the Defendant respectfully invites the Court to dismiss the claim in its entirety.
7.2 The Defendant further invites the Court to consider the Claimant's failure to comply with the Pre-Action Protocol when assessing the appropriate order for costs.
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STATEMENT OF TRUTH
I believe that the facts stated in this Defence 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: [TYPE YOUR FULL NAME]
Date: [INSERT DATE]