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IN THE COUNTY COURT

Claim No: [Claim Number]

BETWEEN:

Vehicle Control Services Ltd

Claimant

- and -

[Defendant's Full Name]

Defendant

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DEFENCE

1. The Defendant denies liability for the claim and intends to defend it in full. The Defendant avers that the claim, as pleaded, fails to meet the requirements of CPR 16.4 and Practice Direction 16. The Particulars of Claim (PoC) are vague, lack clarity, and fail to provide the necessary information to enable the Defendant to properly plead a defence.

2. The PoC are insufficiently particularised and do not allow the Defendant to fully understand the case they are required to answer. Specifically:

(a) Failure to Provide the Contract: The Claimant has referred to a contract but has failed to detail it or attach it to the PoC, as required by CPR Practice Direction 16, paragraph 7.5. The Claimant is put to strict proof that the signage in place at the time of the alleged breaches complied with Paragraph 2(3) of Schedule 4 of the Protection of Freedoms Act 2012, which requires that adequate notice be given by the display of one or more notices that specify the sum as the charge for unauthorised parking and are sufficient to bring the charge to the notice of drivers who park vehicles on the relevant land.

(b) Failure to Identify Specific Contract Terms: The PoC do not state the exact wording of the clause (or clauses) of the terms and conditions of the alleged contract that the Claimant relies upon. This omission prevents the Defendant from understanding the basis of the claim.

(c) Failure to Specify the Breach: The PoC merely state "Parked Without Displaying a Valid Ticket/Permit." This is insufficient to explain which term of the alleged contract has been breached and how the Defendant is alleged to have done so.

(d) Failure to Identify the Location and Details of Alleged Breach: The PoC fail to specify with any particularity:

• The exact location of the alleged breach (stating "8 10 High Street" is generic and insufficient).
• The exact time and duration of the alleged parking event that led to the purported breach.

(e) Failure to Properly Set Out Interest Calculations: While the PoC refer to an 8% statutory interest rate under Section 69 of the County Courts Act 1984, they do not provide sufficient information to demonstrate how the total interest figure has been calculated. Each Parking Charge Notice (PCN) would have started accruing interest only after its "due date," which has not been disclosed in the PoC. The Claimant is put to strict proof of how interest for each individual PCN has been calculated from and to what date.

(f) Failure to Provide a Breakdown of the Claimed Amount: The PoC fail to detail:

• What proportion of the claimed amount relates to the parking charges.
• What proportion relates to alleged damages or other costs.

(g) Improper Use of Alternative Causes of Action: The PoC state that the Claimant is suing the Defendant either as the driver or as the keeper of the vehicle. This is contradictory and prejudicial, as the Claimant must know whether they are pursuing the Defendant in their capacity as the driver or the keeper. The Claimant should not be permitted to plead alternative causes of action, as it is for them to make their case clearly.

3. The Defendant respectfully requests the court to strike out the claim under CPR 3.4(2)(a) and (b) on the grounds that the PoC disclose no reasonable grounds for bringing the claim and are an abuse of process.

4. In the alternative, should the court not agree to strike out the claim for the CPR failures as listed, the Defendant has attached to this defence a copy of an order made at another court which the allocating judge ought to make at this stage so that the Defendant can then know and understand the case which he/she/it faces and can then respond properly to the claim.

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: