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1. I am the Defendant in this claim and the registered keeper of the vehicle with registration number [VRM]. I make this witness statement from my own knowledge and belief in support of my defence to the claim brought by G24 Ltd (“the Claimant”).2. I deny that any sum is owed to the Claimant. No contract was agreed between the driver and the Claimant at the material time, and in any event the Particulars of Claim (“PoC”) are so sparse and lacking in detail that they fail to comply with CPR 16.4. The claim is defective and should be struck out.3. The claim arises from a Parking Charge Notice (“PCN”) issued by the Claimant in respect of a visit to the car park serving Sports Direct at [location] on [date in April 2020] during the first Covid-19 lockdown. A copy of the original PCN is at Exhibit A1.4. At that time, the Sports Direct store itself was closed due to lockdown, but the car park was left open and accessible. No signs were erected to indicate that the car park was closed or that no parking was permitted.5. I was not the only insured and potential driver of the vehicle at the time. The alleged event took place more than five years ago. I am unable, with any certainty, to say who was driving on that specific date, and in any event I am under no obligation to identify the driver. My defence is therefore advanced on the basis that I am the registered keeper only.6. The Claimant’s PoC are extremely brief and fail to set out a clear cause of action. They do not state the specific contractual term or terms said to have been breached, whether the Claimant’s case is that the driver breached terms or that a sum is owed as consideration for parking, the precise conduct alleged, or any contractual or statutory basis for the additional sums claimed beyond the original PCN amount.7. As a litigant in person, I have been left guessing as to the legal and factual basis of the claim. The lack of particularity has made it difficult to understand and respond to the case against me, which is precisely what CPR 16.4 is intended to prevent.8. My defence invited the Court to strike out the claim on the basis that the PoC fail to comply with CPR 16.4 and do not disclose a properly pleaded cause of action. I rely on that position and ask the Court to adopt a similar approach to that taken by other judges who have struck out near-identical parking claims for the same reason.9. Even leaving the defective PoC to one side, the basic factual position on signage is clear and supported by contemporaneous photographs taken in April 2020.10. The car park has at least two vehicular entrances. The entry image used on the PCN (Exhibit A1) shows that the vehicle entered via the [describe entrance]. At the material time, there was no G24 entrance sign at this entrance setting out any terms and conditions or basis upon which parking was offered or restricted.11. Exhibit A2 is a photograph I took in April 2020 of the exact entrance shown on the PCN entry image. It demonstrates that there was no signage at that entrance informing drivers that the car park was managed by G24, that any parking charge applied, or that there were conditions of parking.12. In the absence of any sign at the point of entry, no contractual offer from the Claimant could have been communicated to a driver entering the car park by that route. A driver cannot be bound by terms which were not brought to their attention at or before the point of alleged acceptance.13. The Claimant has subsequently asserted, in correspondence, that the signage at the site stated that the permitted parking time was “0 minutes”. That assertion is untrue and is contradicted by my contemporaneous photographs of the signage that actually existed in 2020.14. Within the car park there were several different signs which were inconsistent with each other as to the maximum permitted parking time.15. Exhibit A3 is a photograph of one of the internal signs, taken in April 2020. It states that the maximum stay is 60 minutes.16. Exhibit A4 is a photograph of another internal sign within the same car park, taken at the same time. It states that the maximum stay is 120 minutes.17. These two signs were in the same car park, both purporting to set out the contractual terms. One sets a 60-minute maximum stay, the other 120 minutes. This is confusing, contradictory, and incapable of forming a clear and certain contract.18. None of the signs in 2020 stated that the permitted parking time was “0 minutes” or that parking was prohibited entirely because the store was closed. The Claimant’s later suggestion that the allowed time was 0 minutes is inconsistent with the photographic evidence of their own signage.19. Exhibit A5 is a photograph of the separate sign located at the other car park entrance (not used by the vehicle). That sign merely indicated that ANPR was in operation and that terms and conditions could be viewed inside the car park. It did not itself set out any parking terms or charges and did not say that parking time was 0 minutes.20. Taking the signage as a whole, there was no entrance sign at the entrance actually used, the other entrance sign was only an ANPR warning and not a contractual offer, and the internal signs contradicted each other and did not state 0 minutes. In these circumstances, it is impossible to identify any clear and unambiguous set of terms that could found a contract between the Claimant and the driver.21. The alleged parking event occurred during the initial Covid-19 lockdown in April 2020. The Sports Direct store was shut to customers. Nevertheless, the Claimant and/or the landowner chose to leave the car park open and did not erect any special signage to indicate that parking was prohibited or that “0 minutes” were allowed due to the store closure.22. A reasonable driver entering an open retail car park with no entrance terms and contradictory internal signs would not understand that they were at immediate risk of a punitive parking charge simply for being on site.23. The original PCN in April 2020 was sent to my previous address. I had moved in [March 2020] and had notified the DVLA of my change of address, but it appears there may have been delay in updating their records due to the national disruption at that time.24. After the original PCN there was a long period of silence, followed by debt recovery letters beginning around December 2024 and then the Letter of Claim in March 2025. I responded to the Letter of Claim as the registered keeper, disputed the debt, and confirmed my correct current address.25. The Claimant has therefore always had access to my correct address, yet waited nearly six years to issue a court claim in respect of a minor alleged parking matter arising from unclear signage during lockdown.26. The Claimant has not produced any fully compliant Notice to Keeper under Schedule 4 of the Protection of Freedoms Act 2012, nor have they clearly pleaded reliance on that legislation in their PoC.27. In the absence of proper pleadings and proof that the statutory conditions are met, there is no basis for holding me, as the registered keeper, liable for any sum even if a driver had entered into a contract, which is denied.28. For the reasons set out above, the Claimant’s Particulars of Claim fail to comply with CPR 16.4 and do not disclose a clear cause of action, and on the facts no clear and enforceable contract was formed with any driver due to the absence of an entrance sign at the route used, the contradictory internal signage, and the lack of any sign specifying “0 minutes” or a prohibition on parking.29. I respectfully invite the Court to strike out or dismiss the claim. If the claim is not struck out before the hearing, I will ask the Court to have regard to the Claimant’s defective pleadings and misleading assertions about the signage when considering the merits and any issue of costs.
