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This is still at the Letter of Claim stage so it is not necessary to provide a forensic defence at this stage.

We are simply jumping through the hoops so to speak.

You could reply acknowledging the LoC but firmly rebutting the claim that any money is owed.

The reply should be made as registered keeper and no admission of who was driving should be made.

A short rebuttal relating to the non-formation of contract would be pertinent to this particular situation.

They will progress this anyway - it's a game to them - but we know how to play too.

Draft letter: 

Dear Sir or Madam,

I write as the registered keeper of the vehicle in question to acknowledge receipt of your Letter of Claim dated 27/02/2026.

I firmly rebut the assertion that any sum is owed to your client, Link Parking, and put you on notice that this claim will be defended in full should proceedings be issued.

No Contract Was Formed

For a parking charge to be enforceable, a binding contract must exist between the motorist and the parking operator. A contract requires an offer, acceptance, and consideration. That essential requirement is not met in this case, for the following reasons.

First, on the date in question the car park contained no signage, or no adequate signage, visible to a motorist upon entering the site. There were no pay stations present. In the absence of clear, legible signage at the point of entry, no offer capable of acceptance was communicated to the driver.

Second, and critically, even if signage had been present in adequate numbers, it is submitted that the signs relied upon by your client operate as an absolute prohibition on parking, not as an offer of parking upon stated terms. English contract law does not permit a "forbidding contract": a sign that says in effect "no parking" cannot simultaneously constitute a contractual offer of parking at a specified charge. Such a construction is a legal nullity. Without a valid offer there can be no acceptance, and without acceptance there is no contract. Accordingly, no liability arises.

This argument has been upheld in the county court, including in UKPC v Masterson, where a judge dismissed the operator's claim on analogous grounds. I reserve the right to rely on this and any other relevant authority at trial.


Registered Keeper Position

This letter is written in my capacity as registered keeper of the vehicle. No admission is made as to the identity of the driver at the time of the alleged contravention, and nothing in this letter should be construed as such an admission.

I invite your client to discontinue this matter immediately and confirm in writing that no further action will be taken. Should proceedings be issued, I will defend the claim robustly and will seek recovery of my reasonable costs.

So can I ask whose name is on the LBC, the reminder notice and the original NtK? Is it the keeper or was the driver nominated by the keeper - meaning that the parking operator re-issued the PCN in the drivers name?

So the vehicle was borrowed at the time and I didn't want any letter's sent to the registered keeper. So when I appealed I stated that I was the driver at the time...

I'm aware from earlier in this post that this was a mistake and now complicates matters, but I genuinely believed when I first appealed through the IAS that I would be successful because of the obvious lack of / appropriate signage.

So, once you were nominated as the driver, did the parking operator re-issue the PCN in your name?

@DWMB2

@jfollows

Is anyone intimately familiar with the exact rules when a keeper nominates a driver in respect to a NtK issued PCN.

Does the Parking Operator have to re-issue the PCN in the nominated drivers own name?

Just checking this case for a potential procedural error.

Hello there,

Weary of needing to send a response before the 29th March expiry date set on the Letter of Claim.

What will be the best course of action please?

Hello there,

Is it possible if any of the members who have previously helped on this thread (or any member) could offer some advice please?

I'm going to send a letter to BW Legal before the 29th March LOC deadline and would feel reassured if anyone could guide me on this.

I haven't contacted BW legal since the first letter I received back in November and had taken advice from the forum not to reply to BW Legal or post on here until I received the LOC.

If any of the hero members @DWMB2 @InterCity125 @Jackisback123 @jfollows @b789 who have contributed could let me know what route I should take next - I would greatly appreciate your kind help.

Thank you!