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IN THE COUNTY COURT AT NOTTINGHAM

Claim No: [Claim Number]

BETWEEN:

I Park Services Ltd
Claimant

- and -

[Defendant's Full Name]

Defendant

---

AMENDED DEFENCE

Filed pursuant to the Order of District Judge Wylie dated 23 October 2025

1. The Defendant denies liability in its entirety. The Defendant asserts that no contract was formed, no parking occurred, and no parking charge is owed. The claim is misconceived, and the facts alleged are denied.

2. The Particulars of Claim (PoC), filed and signed by Sarah Ensall of DCB Legal Ltd, do not disclose a properly pleaded cause of action. Despite the court’s view that the PoC identify the location, time and date of the alleged contravention, they fail to specify:

(a) The contractual term alleged to have been breached;
(b) Whether the Defendant is pursued as driver, keeper, or both;
(c) The specific conduct said to give rise to liability;
(d) Any breakdown of the inflated sum claimed.

3. The Defendant denies breaching any term and puts the Claimant to strict proof of:

(i)The full, contemporaneous signage in place at the material time;
(ii) Its compliance with the IPC Code of Practice;
(iii) A valid contract formed by conduct;
(iv) The quantum claimed.

4. No parking occurred. The vehicle was on site for less than 2 minutes and 13 seconds, during which the driver attempted to locate a space but found none and exited. The Claimant’s evidence confirms this short duration. It is denied that the vehicle was parked or that a contract was accepted.

5. The Claimant failed to provide the mandatory consideration period. Section 13.1 of the IPC Code of Practice (Schedule 7, Table B.1) requires a minimum consideration period of 5 minutes at a Pay & Display car park. The Claimant issued a charge for a stay of less than half this time, in breach of the Code.

6. The Claimant unlawfully obtained the Defendant’s data from the DVLA. By failing to adhere to its Approved Operator Scheme Code of Practice, the Claimant has breached the KADOE contract and had no lawful basis under GDPR Article 6(1)(f) to process the Defendant’s personal data. The DVLA data was obtained unlawfully and must not be used to found a claim.

7. The Defendant is the registered keeper and has not identified the driver as there is no legal obligation to do so to an unregulated private parking firm. The Claimant is put to strict proof. The Claimant has failed to comply with the requirements of Schedule 4 to the Protection of Freedoms Act 2012 and cannot rely on keeper liability.

8. The Claimant is put to strict proof of landowner authority. The Defendant does not admit that the Claimant has legal standing to bring this claim in its own name. The Claimant has failed to produce any evidence of a contract with the lawful landowner or lessee granting them such rights.

9. The claim is tainted by procedural impropriety. The PoC are signed by Sarah Ensall of DCB Legal Ltd. The Defendant is aware that Ms Ensall is not an authorised person within the meaning of the Legal Services Act 2007, and therefore not permitted to conduct litigation. The claim is improperly issued, and the signature on the PoC is invalid. The Defendant reserves the right to refer to Mazur & Anor v Charles Russell Speechlys LLP [2025] EWHC 2341 (KB), where the High Court confirmed that unauthorised persons cannot conduct litigation, even under supervision.

10. The Defendant avers that the claim is predatory and abusive. It is an automated claim, issued with no attempt to review or consider the facts. The conduct of the Claimant and its legal representative is unreasonable and, if the claim proceeds to trial and is dismissed, the Defendant will seek a costs order under CPR 27.14(2)(g).

11. The Defendant respectfully invites the court to strike out the claim pursuant to CPR 3.4, or to dismiss it following trial.

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:


Date: