Free Traffic Legal Advice

It tells you.
You have to file a defence or Acknowledgement of Service by 29 June.
If you file an AoS you have until 13 July to file your defence.

Your defence would appear to be that the driver has not been identified and that the Notice to Keeper has been issued too late to transfer liability to the registered keeper. You are defending as the registered keeper, and you have not and will not identify the driver. You may want to post your draft defence here in advance of the deadline for comment and suggestions.

Do not use the long template/boilerplate response, which is increasingly being struck out by the courts for precisely that reason. Instead, you need to draft a defence which sticks to the Particulars of Claim (and, yes, it can say that they’re vague) and the specific points relevant to this particular case.
Concise is good.

I suggested this in another Smart Parking Claim.

There's a lot of Smart claims at the moment so someone must be instigating these robo-claims.

All easily defended as Smart PCNs were always out of time for PoFA.



I would start with something like;

1. It is acknowledged that I was the Registered Keeper of the vehicle at the material time.

2. The vehicle driver is not known to the Claimant and, as this is a contract dispute, I will not be identifying the driver under any circumstance as the law does not require it.

3. The Claimant appears to be relying on Protection of Freedoms Act (2012)(PoFA) in order to transfer liability from the unknown driver to myself.

4. In order to invoke 'keeper liability' using PoFA the Claimant must demonstrate that their Notice to Keeper (NtK) is compliant with Schedule 4 of PoFA - in this instance the NtK is not compliant as it was served well beyond the 14 day period required by the legislation.

5. As a result, with the driver unknown and no option of keeper liability, there is no legal route to liability in this matter.

6. Liability is therefore denied entirely.

Further defence points which the Court should be aware of;

7. (then add your further points being very careful not to imply that you were the driver)