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IN THE COUNTY COURT AT ROMFORD

Claim No: [Claim Number]

BETWEEN:

Parking Control Management (UK) Ltd
Claimant

- and -

[Defendant's Full Name]

Defendant

---

AMENDED DEFENCE

1.The Defendant denies the claim in its entirety and asserts that no contract was formed and no debt is owed.

2. The claim was subject to an unless order dated 30 April 2025, requiring the Claimant to serve compliant particulars of claim by 4pm within 7 days of service. The Claimant served them late and did not apply for relief. The claim is therefore struck out automatically.

3. Without prejudice to the above, the Defendant responds as follows:

4. The further Particulars of Claim (PoC) embarrassingly fail to fully comply with CPR 16.4 due to the lack of contractual clarity and vague allegations.

5. The Defendant notes that the Claimant's Further Particulars of Claim include evidence and narrative commentary that more properly belongs in a witness statement. The purpose of particulars is to set out a concise statement of the facts relied on, not to present or argue the evidence. The Defendant reserves the right to object to the Claimant's reliance on this material at the witness statement stage, and invites the Court to give directions to exclude any duplication or procedural advantage the Claimant may seek to gain by conflating pleadings with evidential submissions.

6. The Notice to Driver (NtD) evidenced does not specify a period of parking, only a timestamp. This fails PoFA 7(2)(a), as confirmed in Brennan v Premier Parking Solutions (2023) [H6DP632H].

7. The Notice to Keeper (NtK) also fails PoFA 8(2)(a) for the same reason. The Claimant cannot rely on PoFA to pursue the Keeper.

8. Without a defined period of parking, there is no evidence that the vehicle remained beyond the minimum consideration period. No contract could have been formed.

9. The Claimant has failed to comply with CPR 16.4(1)(a). The Further Particulars of Claim do not contain a concise statement of the facts relied on. The only allegation is that the vehicle was "Parked within a restricted area", which is too vague. There is no explanation of how the area is "restricted" or what specific restriction was breached.

10. The facsimile sign evidenced states "No parking outside of the marked bays at anytime [sic]". There is no evidence the vehicle was parked outside of a marked bay or in breach of this or any other term.

11. The Claimant has not identified the driver. As the Notices were defective, there can be no Keeper liability. The Defendant puts the Claimant to strict proof.

12. The claim is for £204.22 but the initial charge was only £100. No explanation or calculation is given for the additional £104.22. There is no indication if this includes damages, debt recovery fees, interest or VAT. No breakdown has been provided.

13. The Claimant provides no evidence of where any sign was located in relation to the vehicle location. The single evidential photo of a sign gives no context, is unlit and was taken at night with flash.

14. The claim is poorly pleaded, disproportionate, and an abuse of process. The Defendant invites the court to dismiss it and to award costs if appropriate.

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:

[Your Full Name]
[Your Address]
[Postcode]

[Email Address – optional]
[Phone Number – optional]

Date: [Insert today's date]

To: The Court Manager

Romford County Court
2a Oaklands Avenue
Romford
RM1 4DP

Re: Claim No. [insert claim number]

Parking Control Management (UK) Ltd v [Your Full Name]

Unless Order dated 30 April 2025 – Request for Confirmation of Automatic Strike-Out

Dear Sir/Madam,

I write in respect of the above claim and the unless order issued by the court on 30 April 2025, which required the Claimant to file and serve a compliant Particulars of Claim by 4:00pm within 7 days of service of the order.

According to CPR 6.26, the order is deemed served on 2 May 2025, meaning the deadline for compliance expired at 4:00pm on Friday 9th May 2025. The Claimant’s further Particulars of Claim are dated 13 May 2025 and were served after this deadline. No application for relief from sanctions has been received or notified.

The order clearly stated that if the Claimant failed to comply, the claim would be struck out automatically and without further order.

Accordingly, I respectfully request that the court confirm that the claim stands as struck out in accordance with paragraph 2 of the order and that the court record will be updated accordingly.

Please confirm in writing whether the court has recorded this strike-out, or whether any further action is required.

Yours faithfully,

[Signature]

[Your Name]