3 private parking tickets being pursued for all 3 and had a ccj claim made

[b789]

@Barbudaprince, we need to keep each claim separate, even if they are for basically the same reasons, otherwise it becomes very difficult for me to keep track of which case I am advising on. However, yes, the point about the location of the alleged contravention falling outside of the claimants boundary of operation is significant and should be used in the other case.

Back to this case... the order confirms what we expected.

The judge has recorded that there were no detailed Particulars of Claim on the court file, that you told the court you had not received them, and that your existing defence was therefore only pleaded in response to the original bare claim form.

The court has now regularised the position. UKCPM had to re-file and re-serve the detailed Particulars of Claim by 4pm on 6 May 2026. You must now file and serve a fully pleaded defence to those detailed Particulars of Claim by 4pm on 20 May 2026.

If UKCPM wants to reply to your defence, they may do so by 4pm on 3 June 2026.

Both sides may then file and serve updated witness evidence and supporting documents by 4pm on 24 June 2026.

The hearing has been adjourned and will be re-listed as an in-person small claims hearing with a 2.5 hour time estimate, on the first available date after 24 June 2026.

Costs are reserved, which means the judge has not decided who should pay any costs arising from the adjournment. That issue remains live and can be dealt with later.

The order also makes clear that any reference to “filing” means filing at Wandsworth County Court, not Brentford. The final hearing bundle must be agreed at least 7 working days before trial, and UKCPM must file that bundle with the court at least 3 working days before trial.

I have already drafted the defence, but I wanted to see the sealed order first so that we knew exactly what the court had directed. The key point now is that this is not just an optional amended defence. The court has expressly ordered you to file and serve a fully pleaded defence by 4pm on 20 May 2026, so that deadline must be treated as fixed.

You can submit the following as your defence:

IN THE COUNTY COURT AT WANDSWORTH

CLAIM NUMBER: [Claim number]

Between

UK CAR PARK MANAGEMENT LIMITED

Claimant

And

[DEFENDANT NAME]

Defendant

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DEFENCE TO THE DETAILED PARTICULARS OF CLAIM

1. The Defendant denies the claim in its entirety. No debt is owed to the Claimant, whether as alleged or at all.

2. This Defence is filed pursuant to the order dated 29 April 2026, following the Claimant’s re-service of its detailed Particulars of Claim.

3. The detailed Particulars of Claim remain inadequately pleaded, contrary to CPR 16.4 and PD 16. Where a claim is based upon an agreement, PD 16 requires proper particulars of that agreement. In Liberty Homes (Kent) Ltd v Rajakanthan & Ors [2022] EWHC 2201 (TCC), Mrs Justice Jefford DBE held that it is implicit that the Particulars of Claim must set out whether the agreement relied upon is oral, written, by conduct, or some combination. The Claimant has failed to plead its alleged contractual basis with sufficient clarity.

4. The Claimant pleads three different alleged contraventions, namely “Permit Required”, “No Parking On Access Roads / Roadways”, and “Not Displaying A Valid Permit”. Those are materially different allegations. The Claimant has not properly particularised each alleged breach separately, the precise contractual term relied upon for each PCN, or how each alleged term was incorporated and breached.

5. The Defendant is the registered keeper. The driver has not been identified. The Claimant is put to strict proof of the driver’s identity and, alternatively, of full compliance with Schedule 4 of the Protection of Freedoms Act 2012 if it seeks keeper liability.

6. The Notices to Keeper fail to specify any proper period of parking. They do not identify a start time, end time, duration, or actual observation period. The Claimant is put to strict proof of any alleged period of parking and any basis for keeper liability.

7. The Claimant is put to strict proof that any driver was given the required consideration period before any parking contract could be formed. The Defendant denies that the Claimant has evidenced any continuous observation period or any fair opportunity for a driver to read the signs, consider the terms and leave.

8. The alleged location is inadequately and/or inaccurately identified. The Claimant is put to strict proof of the exact relevant land, the precise vehicle locations, the signs allegedly applicable at those locations, and the basis on which the pleaded location corresponds with the land on which the vehicle was allegedly parked.

9. The Defendant was a tenant/resident at the property at the material time. Parking was already governed by the residential/tenancy arrangements. The Claimant’s signage did not override those pre-existing rights or create liability to the Claimant unless the Claimant proves a separate enforceable contract, properly incorporated terms, and authority to impose charges on residents or their vehicles.

10. The Defendant understands that the Claimant’s own boundary/authority map does not cover the hard-standing area where the vehicle was located for at least two of the alleged PCNs. The Claimant is put to strict proof that it had contractual authority at the precise location of each alleged contravention.

11. The Claimant is put to strict proof that the signage was visible, prominent, applicable to the precise vehicle locations, and capable of forming a contract. Any prohibitory wording, including “No Parking On Access Roads / Roadways”, is denied to create any contractual licence or liability for a parking charge.

12. The Claimant is put to strict proof of landowner authority to operate at this residential site, impose parking charges, access keeper data, and bring proceedings in its own name.

13. The added sums are denied as unrecoverable, unsupported and inadequately pleaded. If the Claimant relies on keeper liability, recovery from the keeper is in any event limited to the amount specified on the relevant Notice to Keeper.

14. The Claimant has already had the opportunity, pursuant to the order dated 29 April 2026, to re-file and re-serve detailed Particulars of Claim. If the detailed Particulars still fail to plead a proper cause of action, the Defendant submits that the Claimant should not be granted a further opportunity to repair its defective case. Having regard to the overriding objective under CPR 1.1, the modest sums claimed, the routine bulk nature of these proceedings, and the need to deal with cases justly and at proportionate cost, the Defendant invites the court to strike out the claim of its own initiative pursuant to CPR 3.4 and CPR 3.3.

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:

It must be emailed to the court AND BW Legal as a PDF attachment in the same email. Also, CC yourself. Please confirm when that has been done.

[Barbudaprince]

All done thank you for your help

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So just received this automated response. Surely this is not fair.


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