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#Post#: 114761--------------------------------------------------
Re: BW LEGAL - LETTER OF CLAIMS
DIR By: kimon
Date: March 29, 2026, 10:16 am
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true!! is this better??
Subject: Response to Letter of Claim – Ref: X0932074 / PCN
6981720
Dear Sir/Madam,
I write in response to your Letter of Claim dated 23 March 2026.
1. Position on the claim
I do not accept your client’s claim.
2. Basis of dispute
The claim is denied in its entirety. My position is as follows:
(a) No keeper liability established
I am the registered keeper of the vehicle. I was not the driver
at the time of the alleged contravention, and the driver has not
been identified.
You are put to strict proof that your client has complied with
all requirements of Schedule 4 of the Protection of Freedoms Act
2012. In the absence of full compliance, there is no lawful
basis to pursue me as keeper.
For the avoidance of doubt, I am under no obligation to identify
the driver, and I will not be doing so.
(b) Your Letter of Claim is non-compliant with the Pre-Action
Protocol
Your Letter of Claim is deficient and fails to comply with the
Practice Direction – Pre-Action Conduct and Protocols.
In particular, it fails to provide sufficient information to
enable me to understand or properly respond to the claim. The
following key information is missing:
* The precise legal basis of the claim (breach of contract,
contractual charge, or otherwise)
* Copies of the contract relied upon, including signage terms
* Evidence of any alleged contravention
* Evidence of compliance with Schedule 4 of the Protection of
Freedoms Act 2012
* A clear and lawful explanation of the additional sums added to
the original charge
* Evidence of the identity of the driver (if alleged)
This is not a minor oversight. It is a clear failure to engage
in the required pre-action exchange of information.
The Practice Direction requires parties to set out their case
clearly and provide sufficient detail to allow the other party
to understand the issues and make informed decisions. Your
letter falls materially short of that standard.
3. Documents and information required
To comply with your obligations, you must now provide:
1. A fully compliant breakdown of the claim
2. All evidence relied upon (including photographs and signage)
3. Proof of PoFA compliance (if relied upon)
4. The legal basis of the claim
5. Justification for all additional sums
Until such time, the matter is not properly particularised.
4. Conduct warning
If you proceed to issue a claim without addressing the above
deficiencies, I will:
* Bring your failure to comply with the Pre-Action Protocol to
the attention of the Court;
* Seek appropriate sanctions and/or cost consequences;
* Rely on this correspondence as evidence of unreasonable
conduct.
5. Conclusion
For the avoidance of doubt, I deny any liability to your client
and will robustly defend any proceedings.
I expect a fully compliant response.
Yours faithfully,

#Post#: 114762--------------------------------------------------
Re: BW LEGAL - LETTER OF CLAIMS
DIR By: jfollows
Date: March 29, 2026, 10:19 am
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Yes, that looks good to me.
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