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1. The Defendant was at all material times the registered keeper of the vehicle. The Defendant declines to identify the driver and the Claimant is put to strict proof of the driver’s identity.

2. The Particulars of Claim are sparse. They merely assert PoFA keeper liability (“notice has been given to the registered keeper, making them liable”) without pleading facts showing compliance with Schedule 4, which is denied and the Claimant is put to strict proof.

3. It is denied that the Claimant has complied with PoFA Schedule 4. The Claimant is put to strict proof that any Notice to Keeper was served within the prescribed timescales, specified a period of parking (not merely ANPR times), contained all mandatory wording and was otherwise fully compliant, failing which the Defendant as keeper has no liability.

4. The Claimant’s own documentation, including the “Parking Charge Information” letter, relies solely on ANPR timestamps showing the vehicle entering Welcome Break Corley (North) services at 16:36:04 and exiting at 18:52:19 on 4 August 2025, a total of 2 hours 16 minutes “on site”. ANPR cameras record only the times a vehicle passes the cameras, not any actual period of parking.

5. It is denied that the Claimant has established any breach of contract. Time spent:

(i) driving from the ANPR camera to a parking bay on arrival; and
(ii) later manoeuvring out of the bay, driving within the site and queuing or waiting to exit,
is not “parking” and cannot properly be counted as part of any “period of parking” for PoFA or contractual purposes. The Claimant is put to strict proof of the actual period, if any, during which the vehicle was parked in a marked bay.

6. The Claimant alleges a two-hour maximum stay with a ~16 minute overstay based only on ANPR times. The Defendant denies that any proven period of parking exceeded two hours plus the minimum 10-minute exit grace required by the Private Parking Single Code of Practice and puts the Claimant to strict proof that, after deducting non-parking arrival/departure time and grace, any driver was in breach of any term.

7. The Defendant is informed and believes that any driver used the services car park solely for a short rest due to tiredness on a long motorway journey, remaining in the vehicle throughout. Motorway service areas exist to facilitate such safety‑critical rest breaks. Penalising a brief, safety‑related rest based only on ANPR “time on site”, ignoring non‑parking time and grace, is unfair and not transparent to the average consumer. Any alleged term imposing a three‑figure penalty for a brief rest break is unfair under the Consumer Rights Act 2015 and not binding.

8. It is further denied that the Claimant’s signage at Welcome Break Corley (North) was sufficiently prominent, legible or clear to form any contract incorporating the alleged two‑hour limit, any requirement to pay a tariff thereafter, or any obligation to pay a three‑figure charge. The Claimant is put to strict proof of the terms displayed at the entrance and at the location where the vehicle was parked, their prominence and legibility, and contemporaneous landowner authority including any agreed maximum stay and grace periods.

9. As to quantum, Schedule 4 paragraph 4(5) PoFA limits any keeper liability to the amount specified on the Notice to Keeper, believed to be £100. The Claimant nevertheless claims £130, so the extra £30, not specified on the NtK or signage, is an invented add-on amounting to impermissible double recovery, unsupported by ParkingEye v Beavis and contrary to PoFA 4(5); the Defendant denies that any sum above £100 (if due at all) is recoverable.

10. The Defendant denies that any sum is owed to the Claimant, whether by the Defendant as keeper or by any driver, and puts the Claimant to strict proof of every element of its cause of action, including driver identity (if pursued), contractual terms, any alleged breach, full PoFA compliance, and the principal sum and all add-ons.

11. The Defendant reserves the right to seek costs under CPR 27.14(2)(g) for unreasonable conduct if the Claimant persists with a claim that is legally hopeless.