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#Post#: 122262--------------------------------------------------
Claim Form UK parking patrol office limited / BW Legal PCN
DIR By: Moaya
Date: June 18, 2026, 1:54 pm
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Hi,
I'm helping a neighbour with a private PCN that has advanced to
a N1SDT claim form. He had ignored all letters received and
discarded them. He does not even recall being parked in the
place in question as he is away on work very frequently and his
car is in use by other family members.
The claim form issue date is 18th of May and I helped him file
an acknowledgement of service on 3rd of June. We need to file
the defence. Is there a specific defence template and draft
order for Uk Parking Patrol Office?
Also the claim form states
"D is liable driver, or keeper per Sch. 4 PoFA2012. C also
claims £70.00 contractual recovery costs as set out in its terms
and conditions and the ATA Code of Practice."
Im guessing thats not correct as the keeper is not liable.
For some reason I'm having trouble uploading the paperwork, will
try and use another phone to do it shortly.
thanks.
#Post#: 122267--------------------------------------------------
Re: Claim Form UK parking patrol office limited / BW Legal PCN
DIR By: DWMB2
Date: June 18, 2026, 2:31 pm
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Guide: Posting Images
HTML https://www.ftla.uk/announcements/posting-images/
--- Quote ---
> Im guessing thats not correct as the keeper is not liable.
--- End Quote ---
How have you reached that conclusion without sight of the
original parking charge notice?
--- Quote ---
> Is there a specific defence template and draft order for Uk
Parking Patrol Office?
--- End Quote ---
I would recommend against a template defence. Some of the ones
previously suggested on here are fairly frequently being struck
out on the basis that they do not properly respond to the claim.
#Post#: 122282--------------------------------------------------
Re: Claim Form UK parking patrol office limited / BW Legal PCN
DIR By: Moaya
Date: June 18, 2026, 4:58 pm
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Sorry regarding the liability I phrased it incorrectly. I meant
they have not identified the defendant as the driver or keeper
in the PoC. Am I mistaken?
Are you saying this a lost cause and and think he should just
pay up?
Many thanks for your input.
#Post#: 122293--------------------------------------------------
Re: Claim Form UK parking patrol office limited / BW Legal PCN
DIR By: InterCity125
Date: June 19, 2026, 12:56 am
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--- Quote from: Moaya link ---
>
>
> Are you saying this a lost cause and and think he should just
pay up?
>
>
>
--- End Quote ---
No, nobody said that. Quite the opposite in fact.
If you could post up the original PCN and the Claim Form then we
can advise.
Obviously redact only personal info and password.
#Post#: 122341--------------------------------------------------
Re: Claim Form UK parking patrol office limited / BW Legal PCN
DIR By: Moaya
Date: June 19, 2026, 6:29 am
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He only has the claim form which I will link below. He doesn't
have any of the original PCNs.
HTML https://ibb.co/1yg9D86
HTML https://ibb.co/XrRqMgPC
HTML https://ibb.co/JRsDkRvd
#Post#: 122349--------------------------------------------------
Re: Claim Form UK parking patrol office limited / BW Legal PCN
DIR By: jfollows
Date: June 19, 2026, 6:48 am
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So 22 June deadline for a defence.
If a Subject Access Request had been sent to the car park
operator, the original PCN could have been obtained. But it’s
too late now. Wisdom of hindsight - don’t ignore and throw away.
Any defence needs to be specific to the claim, in particular to
the Particulars of Claim which are the usual rubbish. “Parked
causing an obstruction”.
PoFA 2012 can be used to transfer liability to the registered
keeper, but without the original PCN we can’t tell whether or
not this was done properly. If it was, the keeper is now liable
regardless of who the driver was.
#Post#: 122393--------------------------------------------------
Re: Claim Form UK parking patrol office limited / BW Legal PCN
DIR By: Moaya
Date: June 19, 2026, 12:25 pm
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I've told him numerous times not to throw things away, he was
under the impression that you should still ignore private
parking letters. He almost threw away the claim form before I
stopped him and told him he needs to take it seriously.
As far as I can see this company rarely takes matters to county
court.
At this point do I just advise to take it on the chin and pay up
or is there anything he can do. I get the feeling he would
rather prolong the whole process for them rather than pay up
these cowboys.
thanks
#Post#: 122407--------------------------------------------------
Re: Claim Form UK parking patrol office limited / BW Legal PCN
DIR By: jfollows
Date: June 19, 2026, 1:22 pm
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--- Quote from: Moaya link ---
>
>
>
> As far as I can see this company rarely takes matters to
county court.
>
>
--- End Quote ---
They already have done.
Whether or not they discontinue before paying the court fee
remains to be seen.
They hope that your friend throws the claim form away because
then they will apply for and obtain a judgement in default
against your friend.
The deadline for response, either by filing an Acknowledgement
of Service or a defence was 8 June.
If an AoS was filed by 8 June, the deadline for filing a defence
is 22 June.
If the 8 June deadline was missed, there may already be a
default judgement against the defendant. But you say above that
AoS was filed.
Either file a defence or pay up! But the defence really needs
needs to be specific to this case and its circumstances. Not
some boilerplate generic stuff. The keeper is liable if the
Protection of Freedoms Act 2012 has been correctly applied to
transfer liability from the unknown driver to the registered
keeper.
Without the original PCN it’s hard to conclude whether or not
this process was correctly followed.
In the absence of this I would suggest you stop wasting your
time and tell your friend to stop throwing important things
away.
#Post#: 122430--------------------------------------------------
Re: Claim Form UK parking patrol office limited / BW Legal PCN
DIR By: InterCity125
Date: June 20, 2026, 2:48 am
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So we need to enter a skeleton defence which broadly defends the
claim.
I have found a previous UK Parking Patrol NtK from earlier this
year so we will assume that the wording was similar.
Skeleton defence;
1. That the claim is denied in its entirety and no money is owed
by myself to the Claimant.
2. That it is acknowledged that I was the Registered Keeper of
the vehicle at the material time.
3. That the driver of the vehicle is not known to the Claimant
and there is no legal requirement for a vehicle keeper to
provide that information to the Claimant and, as such, I will
not be providing that information under any circumstance.
4. That the Claimant is attempting to invoke what is known as
'keeper liability' via the use of Protection of Freedoms Act
2012 (PoFA).
5. That in order to invoke keeper liability under PoFA the
Claimant's Notice to Keeper (NtK) is required to meet a very
strict set of conditions which are set out in Schedule 4
Paragraph 9(2) of the Act.
6. That in this instance the Claimant's NtK fails to meet
numerous requirements under Schedule 4 Paragraph 9(2) of PoFA
and therefore keeper liability is not available to the Claimant.
7. That with the driver unknown and no keeper liability
available, there is no legal route to liability in this matter.
8. That the claim is therefore denied in its entirety.
Submit the above through MCOL adding all the other procedural
details required.
#Post#: 122643--------------------------------------------------
Re: Claim Form UK parking patrol office limited / BW Legal PCN
DIR By: Moaya
Date: June 22, 2026, 11:12 am
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many thanks for your help. My friend has put in his defence
today before 4pm, will keep you posted.
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