-
Hi,
As title, repeat entry within 2 hours. I successfully defended this before stating it was a different driver each time, but cannot find the template I used. Is there one available here?
Thank you for your help in advance. -
-
Please show both sides of the Notice to Keeper (NtK).
Any supposed contract is with a person, not with a lump of metal. -
-
Agreed, thanks for the reply. Pics below:
https://ibb.co/qMn12tKk
https://ibb.co/xtZsKhPt
https://ibb.co/nqbL9ymP
https://ibb.co/j7bkhBy
14 days are up tomorrow despite only receiving it on the weekend and it looks like an appeal can only be done by post. -
-
I have gone through this Notice to Keeper (NtK) carefully and there are several serious flaws that mean they cannot use the Protection of Freedoms Act 2012 (PoFA) to make you, as the registered keeper, liable.
First, the NtK never actually states the date of the alleged contravention in the wording of the letter. PoFA paragraph 9(2)(a) says that if they want to pursue the keeper, the notice must specify the vehicle, the relevant land and the period of parking to which the notice relates. That necessarily means the notice itself must tell you on what date and at what times the parking event is said to have taken place. On this NtK, the narrative part talks about an outstanding parking charge and an alleged contravention, but nowhere in that text does it state “on [date]” or give you a clear date of event. The only date you can find is in the small ANPR images at the bottom.
Looking more closely at those images, there does appear to be some date and time information on them, but the reproductions are so poor that any timestamp is effectively illegible. The date is barely readable, and the time data cannot be made out at all. PoFA does not require photographs to be included with an anti. A fully compliant NtK could in theory be a plain text letter. That means all the mandatory information in paragraph 9(2) has to be clearly set out in the wording of the notice itself. They cannot rely on low-quality, hard-to-read photographs to plug gaps where the required text is missing. Because the date of the contravention is not stated in the body of the notice, this NtK does not comply with 9(2)(a).
The same paragraph also requires the notice to specify the “period of parking”. That is supposed to be a clear span of time when the vehicle is said to have been parked, for example “from [time] to [time] on [date]”. What this NtK actually does is list some “entry” and “exit” times against the images, but again these are printed so badly that any time information on the pictures is not legible, and they never translate those into a plain statement of a parking period in the text. There is no sentence anywhere that says “the period of parking to which this notice relates is [date] [start time] to [end time]”. So even if you ignore the legibility issue, they have not actually told you in words what period of parking they are relying on. That is a second, separate failure of 9(2)(a).
Then there is PoFA paragraph 9(3). This says that the NtK must relate only to a single period of parking specified under sub-paragraph (2)(a). Here, the whole allegation is based on a “no return within x hours” rule, which by definition relies on two separate visits. Their own ANPR images show an initial in and out, and then a later in and out. Even if the timestamps were crystal clear, that would still mean they are not talking about one continuous parking event, but two separate ones with a gap in between. That is not what 9(3) allows if they want keeper liability. So the notice fails 9(3) as well, because it is trying to bundle multiple visits into one alleged contravention.
On top of the PoFA issues, there is a more basic contract point. Any alleged parking contract is between the operator and the human driver at the time, not with the car itself. The car is just a lump of metal; it cannot read signs or agree to anything. In this case, there were different drivers for each visit. That means, if any contract existed at all, there would have been one contract with Driver A for the first visit and another with Driver B for the second visit. A “no return within x hours” restriction only makes sense if it is the same driver coming back. It is not logical to say that Driver B is in breach simply because the vehicle they are using was previously driven by someone else earlier in the day. ANPR only shows a number plate passing a camera. It does not identify the driver at all, let alone prove that it was the same person on both visits.
Putting all of this together, the position for you as Keeper is very strong. The NtK fails 9(2)(a) because it does not clearly specify the date of contravention or any period of parking in the wording of the notice. It fails 9(3) because it relies on multiple visits instead of a single period of parking.
Because PoFA has not been complied with, they cannot transfer liability from the unknown drivers to you. If they cannot rely on PoFA, the claim goes nowhere unless they can actually prove who the driver was. There is no presumption and no right to “infer” that the keeper was driving just because their name is on the V5C. The burden stays on the operator at all times to identify the driver and show that that person personally agreed to, and then breached, a clear term. Persuasive case law confirms that simple keeper status is not enough, so in a non-PoFA case like this there is no lawful route to keeper liability and no scope for the court to guess or assume you were the driver.
In terms of how I would use this, your initial appeal to the operator should only be in your capacity as registered keeper. You are not legally obliged to say who was driving and you decline to identify the drivers. You simply point out that the NtK is not compliant with PoFA because it does not state the date of the alleged contravention or any period of parking in the text, and because it is based on multiple visits rather than a single parking event. You make it clear that you, as Keeper, are not liable and will not be naming the driver. If they reject that, which is likely, you then appeal to the IAS, for what it’s worth and then ignore the inevitable stream of debt collector letters, as those companies have no extra powers and are not a party to any alleged contract.
If scammer were ever foolish enough to issue a county court claim, the defence would be straightforward. You would state that you are the Keeper and that each visit was made by a different driver, that the claimant cannot rely on PoFA because of the 9(2)(a) and 9(3) failures, and that in the absence of PoFA they must prove the identity of the driver, which they cannot do. You would also explain that there were different drivers for each visit, so any “no return” allegation is incoherent. That gives a judge a very clear and simple route to dismiss any claim.
For now, simply appeal only as the Keeper as follows:QuoteSubject: Appeal against PCN [PCN NUMBER] – Vehicle [VRM]
This is an appeal from the registered keeper of the vehicle. It is made strictly in that capacity. The operator is put on notice that there is no obligation to identify the driver and no such information will be provided.
The starting point is that any alleged parking contract is formed, if at all, between the operator and a human being who is said to have read and accepted the terms on a sign. Contracts are not formed with lumps of metal or registration numbers.
In this case there were two separate visits and a different driver for each visit. At most there would be one contract with the first driver on visit one and a completely separate contract with the second driver on visit two. A “no return within X hours” term that purports to treat the vehicle as the contracting party is legally incoherent. It attempts to bind a later driver to whatever the earlier driver supposedly did, which is nonsense in contract law.
ANPR simply records a plate passing a camera. It does not and cannot identify who was driving, and it certainly does not prove that the same person drove on both visits. Without a proven contracting party and a proven breach by that individual, there is no enforceable contract and nothing owed to the operator.
On top of that, the Notice to Keeper is fundamentally non-compliant with the Protection of Freedoms Act 2012 Schedule 4 and cannot create keeper liability. Paragraph 9(2)(a) requires the notice to specify the vehicle, the relevant land and the period of parking to which the notice relates. That necessarily includes a clear date and span of time of the alleged parking event, set out in the wording of the notice itself.
This NtK does not state any date of contravention or date of event anywhere in its narrative text. It rambles about an “alleged contravention” and an “outstanding parking charge” but never actually says on what date this is alleged to have occurred. That alone is a failure of 9(2)(a).
The operator appears to be trying to plug that hole with a handful of tiny, low-quality ANPR stills dumped at the bottom of the page. Even on a generous reading, any purported date and time in those images is barely legible; the timestamp information is effectively unreadable. More importantly, PoFA does not require photographs at all. A fully compliant NtK could be plain text. That means all the mandatory information in paragraph 9 must be present and clear in the text of the notice. Hiding critical details in fuzzy pictures does not satisfy the statute. The notice as served simply does not tell the keeper, in plain words, when the alleged event took place.
The same paragraph 9(2)(a) also demands that the notice specify the “period of parking”. This NtK never does that either. The operator scatters some “entry” and “exit” times around, but does not translate them into any clear period of parking in the body of the notice.
There is no statement such as “the period of parking to which this notice relates is [date] from [time] to [time]”. A few half-readable timestamps, some of which cannot even be deciphered, is not a “period of parking” within the meaning of PoFA. That is a second and separate breach of 9(2)(a).
Paragraph 9(3) then requires that the notice must relate only to a single period of parking specified under 9(2)(a). Here the entire allegation is built on a supposed “no return” rule, which by definition relies on at least two visits.
The operator’s own images show an initial in/out and a later in/out. That is not one continuous stay, it is two distinct parking events with a gap between them. Even if the operator had properly specified a period of parking in the text (which they have not), this still could not satisfy 9(3), because the notice is not tied to a single period of parking at all. PoFA Schedule 4 simply does not support this kind of “no return” construct. The statutory conditions for keeper liability are not met.
Because the NtK fails 9(2)(a) and 9(3), the operator has no lawful route to transfer liability from an unknown driver to the keeper. The burden remains entirely on the operator to identify the driver and to prove that that person actually agreed to, and then breached, a specific term. There is no presumption and no entitlement to infer that the keeper must have been the driver merely because their name appears on the V5C.
Persuasive case law confirms that keeper status alone is incapable of discharging that burden. In a non-PoFA situation such as this there is no legitimate route to keeper liability and no scope for any court to guess or assume who was driving.
Against that background, the operator’s attempt to present this NtK as if Schedule 4 somehow applies is not just wrong, it is misleading. The Private Parking Single Code of Practice (including clause 8.1.1(d)) makes it clear that operators must not misstate the effect of PoFA or suggest that the keeper is liable where the statutory conditions are not satisfied. That is exactly what is happening here. The operator has accessed and processed keeper data obtained from the DVLA on the back of a legally defective notice, then tried to dress it up as if keeper liability were engaged.
This behaviour strays into the territory of unfair commercial practices under the new Digital Markets, Competition and Consumers Act 2024. The operator has failed to provide clear, legible, material information about the date and period of the alleged parking, misrepresented the legal position on keeper liability and sought to pressure payment on the back of unreadable “evidence” that cannot cure statutory defects.
Those are classic examples of misleading actions and misleading omissions. If this charge is not cancelled, a formal set of complaints will be raised with the DVLA, the ICO and the Competition and Markets Authority, specifically referencing misuse of keeper data, misrepresentation of PoFA, non-compliance with the Private Parking Single Code of Practice and potential breaches of the DMCC Act.
In short: there is no valid contract, no compliant NtK, no keeper liability and no evidence capable of identifying or binding any driver. The only correct outcome is cancellation of this speculative invoice. -
-
Many, many thanks, this is superb. I will print and drop it in their PO Box later this evening.
-
-
You don't have to print anything. Just either submit it through their online appeals webform or email it to them.
If you insist on using snail mail, then you simply post it first call and obtain a free proof of posting certificate from any post office. DO NOT use registered/tracked service. -
-
No online appeal available, on the back it states only by post.
-
-
Googling "ParkDirectUK appeal" yielded the following - https://parkdirectuk.zatappeal.com/
-
-
Reply below, enlarged images were provided, however it is not possible to identify anyone in the vehicle due to the poor quality:
Thank you for your appeal received on x regarding the above detailed Parking Charge Notice.
We have reviewed the case and considered the comments that you have made. Our records show that
this notice was correctly issued as your vehicle was parked in a way which breaches the Terms and
Conditions of Parking.
The warning signs at the retail park advises that parking is permitted for a maximum stay of 2 hours for
the Retail units, with a no return period for 2 hours. Your vehicle parked on site between 13:57:22 until
14:30:39 and returned at 16:28:16 until 16:54:04. As your vehicle entered site and parked during the
no return period, your vehicle was parked in direct breach of the advertised terms of parking.
Kindly be advised, the signage clearly states, “Additional parking charges apply for each 24-hour period,
or part thereof, that the vehicle remains in breach or if it returns at any time.” As your vehicle returned
within the two-hour no-return period, the PCN was issued correctly and will be upheld.
The signs make it clear that if the terms and conditions are breached, that a Charge of £100 will be
levied if vehicles park outside of the Terms and Conditions displayed. It is the motorist's responsibility to
ensure that they return to their vehicle and remove it from the car park before the maximum period of
parking permitted expires and does not return to park within the no return period, as you did return
within the no return period, you became liable for the Charge advertised.
All of our warning signs prominently displayed a customer service telephone number which you could
have called in the event of any uncertainty when parking on site and had you called the number upon
your arrival, you would have been advised which steps to take in order to avoid receiving a PCN. We
must remind you that it is the driver's responsibility to ensure that the parking restrictions in force are
actively observed and adhered to when parking on PRIVATE PROPERTY and we would advise that you
do so in the future in order to prevent any further PCNs being issued. Regrettably, we can only cancel a
PCN if it was issued incorrectly of if the contravention did not occur and are unable to do so based on
the grounds of your appeal.
Unfortunately on this occasion, we have upheld the PCN as it was issued correctly. We have now
extended the discounted payment period by 14 days to allow you time to pay the discounted settlement
amount. Please now make payment of £60 to reach us by x or £100 to reach us by
x. We must advise you that once the discounted settlement rate passes it will not be offered
again. You now have a number of options; 1.Pay the parking charge notice. Payment can be made
online at www.parkdirectuk.com or by calling the automated payment line on 020237739587.
2. You may also make an appeal to the Independent Appeals Service (IAS) on the following website
www.theias.org quoting the Parking Charge Notice number and the Vehicle Registration number within
28 days from the date of this letter. If you opt for independent arbitration of your case, you will lose the
opportunity to pay the lower amount and £100.00 will be payable in the event your appeal is rejected.
Please note that the IAS is unable to waive a parking charge notice due to mitigating circumstances and
a decision will be based solely on the facts and evidence. You may appeal on any ground which
undermines the lawfulness of the charge or which otherwise affects the suggestion that you are liable
for it. Please note that if you opt for the IAS appeals process, all evidence collected relating to this case
will be submitted to the IAS. We would like to advise you that we do not enter into multiple appeals and
we will not enter into any further correspondence in relation to this appeal. If you choose to send us
another appeal, we are afraid that we are unable to log or answer it. -
-
That rejection is exactly the garbage we expected – a template that completely ignores every legal point and just re-asserts “you breached our terms, pay us”.
Let’s strip it down and then I’ll give you a tight appeal you can use for the kangaroo court that is the IAS.
1. What their response actually does
– It does not address PoFA at all. Zero engagement with 9(2)(a) or 9(3).
– It baldly asserts “your vehicle was parked in breach” and then treats the vehicle as if it is the contracting party.
– It repeats the “no return” spiel and quotes some wording about “if it returns at any time” as if that magically answers your statutory and contractual points.
– It relies entirely on “our records show” and the ANPR times, without dealing with the fact that:
• They’ve never specified a period of parking in the NtK wording; and
• The NtK doesn’t state the date of contravention in the body text.
In other words, they have not rebutted a single one of the keeper-liability arguments or the contract analysis you set out. They’ve just confirmed that the only thing they understand is “car in, car out, money please”.
2. Contractual failure they are trying to gloss over
They double down on the fiction that a “vehicle” can be liable and that a “no return” term somehow binds anything and anyone that happens to be driving that plate.
Your key contract points (none of which they have touched):
– Any alleged contract is with a person, not with the metal.
– There were two visits and different drivers for each visit.
• At most, contract 1 with driver A on visit 1;
• Contract 2 with driver B on visit 2.
– A “no return within 2 hours” term aimed at “the vehicle” is legally meaningless where the contracting parties are different on each occasion. Driver B cannot be in breach of something that depends on what driver A did two hours earlier.
– ANPR evidences only plate movements, not identity, not continuity of contracting party.
So even if signage was crystal clear (which you’ve not conceded), their own narrative cannot produce a coherent contract and breach against any particular person.
3. Keeper liability still dead
Nothing in their reply cures the PoFA defects:
– They still haven’t produced any NtK wording that specifies:
• the date of the alleged contravention; and
• a single, clear “period of parking” as required by 9(2)(a).
– Their entire case still hinges on two visits, which is incompatible with 9(3)’s requirement that a NtK “must relate only to a single period of parking”.
They remain in non-PoFA territory, so there is still no lawful route to keeper liability. That hasn’t changed at all.
4. DMCC/unfair practice angle
Their letter adds a few more hooks for the DMCC complaint later:
– They assert liability on the back of a non-compliant NtK.
– They suggest only “mitigation” could excuse payment, ignoring the fact that the entire statutory framework for keeper liability simply doesn’t apply.
– They wave the “discount” and “we’ve extended it for you” carrot to pressure payment, while failing to provide clear, legible, material information and while misrepresenting the legal position about who can be liable.
All of that feeds the unfair commercial practices/misleading actions narrative you can take to the CMA, DVLA and ICO if they don’t slink away.
5. Use the following as your IAS appealQuoteAppeal against Parking Charge Notice [PCN NUMBER] – Vehicle [VRM]
1. Status of the appellant and absence of any admission as to driver
This appeal is submitted by the registered keeper of the above vehicle. The appellant relies on their statutory status as keeper only. No admission is made as to the identity of the driver on any occasion, and no driver will be identified. The operator is put to strict proof as to the identity of any alleged contracting party.
2. Fundamental contractual incoherence: “no return” construct, multiple visits and different drivers
The operator’s own case is based upon automatic number plate recognition (ANPR) showing two discrete visits separated by an interval, and upon signage which is said to impose a “maximum stay of 2 hours” with a “no return period of 2 hours” and an additional provision that “additional parking charges apply for each 24-hour period, or part thereof, that the vehicle remains in breach or if it returns at any time”.
As a matter of elementary contract law, any parking contract is formed, if at all, between the operator (or its principal) and a natural person, namely the driver who is alleged to have read and accepted the terms upon entry and by remaining parked. Contracts are not formed with a chattel such as a vehicle or with a registration mark. It follows that for each visit there can only be a contract with the driver on that visit.
On the facts of this case, there were two separate visits and different drivers on each occasion. It is therefore impossible, as a matter of privity and personal obligation, for the driver on the later visit to be bound by any supposed “no return” restriction that depends upon the conduct of a different individual on an earlier visit. A term expressed as binding “the vehicle” is legally incoherent; it purports to ascribe continuing contractual obligations to a physical object that cannot read, consent or perform. The operator’s attempt to found liability upon a “no return” restriction that is triggered by the actions of a different driver is, with respect, misconceived and unenforceable.
Even if the signage were otherwise adequate (which is not conceded), the operator has failed, on any rational analysis, to demonstrate that any particular person entered into, and then personally breached, a contractual term. The operator’s own evidence therefore fails at the most basic level of contract formation and breach.
3. Non-compliance with the Protection of Freedoms Act 2012, Schedule 4
If the operator wishes to pursue the registered keeper rather than a proven driver, it must comply strictly with the conditions of Schedule 4 to the Protection of Freedoms Act 2012 (“PoFA”). It is trite law that Schedule 4 is a self-contained code, conferring a limited right to recover unpaid parking charges from keepers only when its conditions are met. Non-compliance is fatal to any claim against the keeper.
The Notice to Keeper (“NtK”) in this case is defective and does not comply with PoFA, in particular paragraphs 9(2)(a) and 9(3).
3.1 Failure to specify the date and period of parking – PoFA paragraph 9(2)(a)
Paragraph 9(2)(a) requires the NtK to “specify the vehicle, the relevant land on which it was parked and the period of parking to which the notice relates”.
The NtK in this case fails to specify, in its narrative text, the date of the alleged contravention. The wording refers in general terms to an alleged contravention and an outstanding charge, but nowhere in the body of the notice is the date on which that contravention is said to have occurred actually stated.
Nor does the NtK specify any “period of parking” in the sense required by PoFA. The operator merely scatters “entry” and “exit” times on the document, some of which appear only in very low-quality ANPR stills. These times are, in material part, illegible due to poor reproduction and in any event are never translated into a stated period in the wording of the notice. There is no clear statement such as “the period of parking to which this notice relates is [date] from [time] to [time]”. A list of timestamps, particularly when reproduced in such poor quality that they cannot sensibly be read, does not satisfy the statutory requirement to “specify...the period of parking”.
It is important to note that PoFA does not require an operator to provide photographs at all. A fully compliant NtK could be issued entirely in text. It necessarily follows that all mandatory information required by paragraph 9(2) must be present and clear in the wording of the notice itself. Optional, low-resolution images cannot be relied upon to “cure” omissions in the statutory text. The NtK’s failure to state, in words, the date and period of the alleged parking event is a plain breach of paragraph 9(2)(a).
3.2 Contravention of PoFA paragraph 9(3): notice must relate to a single period of parking
Paragraph 9(3) provides that the NtK “must relate only to a single period of parking specified under sub-paragraph (2)(a)”.
The operator’s own case, as set out in its rejection letter, is that the charge arises from a “no return” restriction, with two visits recorded some hours apart. By definition, a “no return within 2 hours” allegation depends upon at least two separate periods of parking. The operator’s ANPR evidence shows an initial arrival and departure and a later arrival and departure. That is not “a single period of parking”; it is two distinct parking events separated by an interval.
It follows that, even if the NtK had specified a period of parking (which it has not), it still could not comply with paragraph 9(3), because the notice is predicated upon multiple periods, not a single one. PoFA Schedule 4 is drafted to apply to a single parking event; it does not extend keeper liability to “no return” scenarios based on composite ANPR records.
Given these breaches of paragraphs 9(2)(a) and 9(3), the operator cannot, as a matter of law, recover this charge from the registered keeper.
4. Keeper liability and the burden of proof
In circumstances where PoFA is not complied with, there is no statutory transfer of liability from driver to keeper. The operator must then establish, on orthodox principles, the identity of the driver and the alleged breach by that person. There is no presumption in law that the registered keeper was the driver, nor any entitlement to infer this merely from the DVLA record. Persuasive County Court authority (for example, Vehicle Control Services Ltd v Edward [2023]) confirms that keeper status does not justify an inference that the keeper was the driver. The burden remains upon the operator throughout to prove, on evidence, that a particular individual was driving and that that individual is contractually liable.
In this case, the operator relies solely upon ANPR captures of a registration mark and has adduced no evidence as to the identity of any driver, let alone continuity of driver between visits. In fact, as already stated, there were different drivers on each visit. The operator has therefore failed to discharge the burden of proving any personal liability on the part of any identified contracting party. In the absence of PoFA compliance, there is no lawful route to keeper liability, and no proper evidential basis upon which liability could be imposed.
5. Breach of the Private Parking Single Code of Practice and unfair commercial practice
The Private Parking Single Code of Practice (“PPSCoP”), which binds accredited operators, contains clear obligations not to misrepresent the legal position regarding keeper liability and PoFA. In particular, clause 8.1.1(d) (as in force from 17 February 2025) prohibits operators from suggesting that a keeper is liable under PoFA where the statutory conditions are not in fact met.
By issuing a defective NtK that omits key PoFA information, by presenting it as if keeper liability were engaged, and by then seeking to uphold the charge against the keeper despite these defects, the operator is in clear breach of the PPSCoP. The operator has accessed and processed keeper data obtained from the DVLA on a legally defective basis and has mischaracterised its entitlement to recover the charge from the keeper. That conduct is also highly questionable when viewed against the framework of the Digital Markets, Competition and Consumers Act 2024, which addresses misleading actions and omissions and unfair commercial practices.
6. Conclusion
In summary, the operator’s case fails on multiple independent grounds:
(a) There is no coherent contractual route to liability in a two-visit, two-driver scenario relying on a “no return” restriction aimed at “the vehicle”, which is legally meaningless.
(b) The Notice to Keeper is non-compliant with PoFA 2012 Schedule 4. It fails to specify, in its wording, the date and period of parking as required by paragraph 9(2)(a) and, in any event, purports to relate to multiple visits, contrary to paragraph 9(3)’s requirement of a single period of parking.
(c) In the absence of PoFA compliance, there is no statutory keeper liability. The operator has failed to prove the identity of any driver and cannot rely upon any legal presumption to convert the registered keeper into the driver.
(d) The operator’s conduct contravenes the PPSCoP and raises concerns as to unfair commercial practices.
For all of the above reasons, the appellant respectfully submits that this Parking Charge Notice is neither lawful nor enforceable against the registered keeper and invites the Independent Appeals Service to allow the appeal and direct that the charge be cancelled. -
-
Amazing, thank you. In line with another observation below:
"Yes, they're claiming that the vehicle isn't to return within 2 hours.
The only person who could be party to that would be driver A, and they're presumably claiming that person should have told driver B not to return because they would breach the contract they have originally agreed.
Obviously lots of argument over whether this is in fact enforceable.
But they've undermined their own argument by stating "as YOU (Registered Keeper & Driver A) did return within the no return period, YOU (Registered Keeper & Driver A) became liable for the Charge advertised".
This did not occur. Driver B returned.
This is important as under POFA as "the driver of a vehicle is required by virtue of a relevant obligation to pay".
They have stated driver A is liable and stated they have the "relevant obligation."
I would therefore wait until a Letter Before Action and then name Driver B as the driver. Driver A is taken out of the equation.
Then they go down a snake all the way to the start of the board and have to issue a Notice to Driver, new debt letters etc.
If they then decided to make a claim against Driver B there would be no contract and they have stated Driver A is liable and they'd be stymied because driver A wasn't the driver. Rock and a hard place.
At the end of the day they can just make a claim against the RK and it'll probably be discontinued anyway. So it's all moot even when you have a cast iron defence because you have to faff about dealing with a claim. But you have the opportunity to send them down a snake, and quite often they lose interest after that and don't even bother with a court claim." -
-
DOn't know where you got that "observation" from but some of the comments are clearly made by someone with no idea of how to progress this. This comment, for example:Quote
I would therefore wait until a Letter Before Action and then name Driver B as the driver. Driver A is taken out of the equation.
Is clearly made by someone who suffers from intellectual malnourishment.
If they do ever issue a claim, you would be well within your rights to go for a summary judgment before allocation and claim fixed costs of £750 plus your application and then another hearing to cover costs for their unreasonable behaviour. But that is way down the road. -
Like x 1
View List