Quote:1. The Defendant denies the claim in its entirety. The Defendant denies that any sum is owed to the Claimant.

2. The Defendant was the registered keeper of the vehicle at the material time. The Claimant has not identified the driver and is put to strict proof of the basis upon which the Defendant is said to be liable.

3. The Particulars of Claim are generic, incoherent and inadequately pleaded. They fail to identify the precise contractual term allegedly breached, the nature of the alleged breach, or the factual basis upon which liability is asserted.

4. The Particulars merely state that the claim relates to a parking charge for breach of contract terms and conditions and/or restrictions. That wording does not disclose whether the allegation is an overstay, non-payment, underpayment, incorrect registration entry, failure to display, unauthorised parking, or any other specific breach.

5. The Defendant cannot reasonably plead a full defence to a case which has not been properly pleaded. The Claimant has not identified the agreement relied upon, the manner in which it was allegedly formed, the specific term allegedly breached, or the conduct said to amount to that breach.

6. The Particulars of Claim are therefore contrary to CPR 16.4 and Practice Direction 16. Where a claim is based upon an agreement, PD 16 requires proper particulars of that agreement.

7. In Liberty Homes (Kent) Ltd v Rajakanthan & Ors [2022] EWHC 2201 (TCC), Mrs Justice Jefford DBE held that it is implicit that Particulars of Claim must set out whether the agreement relied upon is oral, written, by conduct, or some combination. The Claimant has failed to do so.

8. The Claimant’s failure is not a mere technicality. It goes to the core of the alleged cause of action. The Claimant is an experienced private parking operator and a serial issuer of county court claims. It knows, or ought to know, the basic pleading requirements applicable to a contract claim.

9. The Claimant could have served detailed Particulars of Claim at the outset but chose not to do so. It should not now be given a second opportunity to repair a fundamentally deficient claim after proceedings have been issued and after the Defendant has been required to respond to a case that has not been properly pleaded.

10. Having regard to the overriding objective under CPR 1.1, the generic and deficient pleading, the modest sum claimed, and the routine bulk nature of these proceedings, the Defendant submits that it would be disproportionate and contrary to the efficient use of court resources to direct further pleadings or allow the Claimant to remedy defects which should never have existed.

11. The court is therefore invited to strike out the claim under CPR 3.4(2)(a), as the Particulars of Claim disclose no properly pleaded cause of action. The Defendant specifically submits that this is not an appropriate case for further and better particulars. The appropriate remedy is strike out.

12. The Particulars also appear internally defective. They state “Time in: 15:38” and “Time out: 11:07”, which is impossible as pleaded in the absence of any coherent explanation. That defect further demonstrates that the claim has been issued without proper care or scrutiny.

13. The Claimant has not pleaded any actual period of parking. ANPR entry and exit timestamps, even if accurate, are not the same as a period of parking. They record, at most, vehicle movement past cameras, not when any alleged parking period began or ended.

14. The alleged parking event is said to have occurred on 1 June 2024. The Parking Charge Notice was not issued until 27 November 2025. On the information presently available, that is far outside the time limit required for keeper liability under Schedule 4 of the Protection of Freedoms Act 2012.

15. The Claimant is therefore put to strict proof that it fully complied with Schedule 4 of the Protection of Freedoms Act 2012 if it seeks to recover the charge from the Defendant as registered keeper.

16. In particular, the Claimant is put to strict proof that a compliant Notice to Keeper was delivered within the statutory period and that the notice contained all mandatory wording required by Schedule 4.

17. If the Claimant cannot establish full compliance with Schedule 4 of the Protection of Freedoms Act 2012, the Defendant cannot be held liable as registered keeper.

18. The Defendant further denies that the Claimant has standing to sue. The Claimant is put to strict proof of its authority from the landowner or lawful occupier to operate at the relevant site, issue parking charges, and pursue court proceedings in its own name.

19. The Defendant denies that any contract was formed. The Claimant is put to strict proof of the signage in place at the material time, including entrance signage, internal signage, the wording relied upon, the prominence of any parking charge, and whether the alleged terms were capable of being read and accepted before any alleged contract was formed.

20. The Defendant further denies that the sum claimed is recoverable. The claimed parking charge has been inflated to £170, with additional interest and costs then added. The Claimant is put to strict proof of the contractual and legal basis for each sum claimed.

21. The additional £70 is denied. It appears to be an attempt at double recovery and is not recoverable unless the Claimant can show a proper contractual entitlement and actual legal basis for that sum.

22. The Defendant also denies that the Claimant is entitled to interest as claimed. The Claimant has failed to plead a proper basis for interest, including how it has been calculated and from what valid date it is said to run.

23. The Defendant reserves the right to expand upon this defence if the Claimant is permitted to rely upon a case materially different from that set out in the present Particulars of Claim.

24. For the reasons stated above, the claim should be struck out. In the alternative, the claim is denied and the Claimant is put to strict proof of every element of its claim.

Quote:Subject: Data Rectification Notice – [PCN Reference] / [Claim Number]

Dear Civil Enforcement Ltd Data Protection Officer,

I am writing as the registered keeper in relation to the above‑referenced Parking Charge Notice and the associated County Court claim issued via the County Court Business Centre.

This email is a formal Data Rectification Notice under the UK GDPR and the Data Protection Act 2018.

Although the claim form was correctly served to my current address for service, I require confirmation that you do not hold, process, or rely upon any previous, incorrect or outdated address data relating to me. To prevent any risk of mis‑service of future correspondence connected with the ongoing court proceedings, I require you to rectify your records immediately

Accordingly, you are required to:

1. Confirm that the only address you hold for me is my current address for service.  
   
2. Erase any other addresses you may hold, including outdated, previous, or incorrect address data.  
   
3. Confirm that no such inaccurate or historic address data has been or will be shared with any third parties, including debt recovery agents or legal representatives.  
   
4. Update your systems so that my current address is the sole address used for all future communications relating to this matter.
   

Please confirm in writing within 14 days that:

• You have rectified your records;  
  
• You have erased any other addresses;  
  
• My current address for service is the only address retained and used for all future correspondence.
  

Failure to comply will result in a complaint to the Information Commissioner’s Office for unlawful processing of inaccurate personal data.

Yours faithfully,

[Your Full Name]  


[Your Current Address] 
[Vehicle Registration] 
[PCN Reference] 
[Claim Number]