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#Post#: 127612--------------------------------------------------
Re: PCN for parking for driving in a parking monitored area
DIR By: RichardW
Date: August 12, 2026, 6:56 am
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The act is very specific in saying that the NTK must state the
words - not imply or otherwise.
However, not sure this has actually been tested at the court -
when challenged the Parking Cos normally discontinue - there is
always a first time of course. At this stage you have nothing
to lose - there is no other route of appeal where you are now,
so you might as well throw everything at it to show you are not
going to be a push over.
#Post#: 127834--------------------------------------------------
Re: PCN for parking for driving in a parking monitored area
DIR By: shahcar
Date: August 15, 2026, 3:52 am
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Hi,
If they proceed to Court, should the Defense be based on the
response to the LOC or these two are separate? What’s the point
of responding to the LOC as these debt collector don't care?
Thanks
#Post#: 127835--------------------------------------------------
Re: PCN for parking for driving in a parking monitored area
DIR By: jfollows
Date: August 15, 2026, 4:09 am
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The Letter of Claim is not from a debt collector, it will be
from a solicitor. You respond simply to add to the paper trail
so that in the unlikely event this ever comes to court you can
show you have followed the protocols and tried to avoid this
getting to court.
Don’t go overboard with your response, see
HTML https://www.justice.gov.uk/courts/procedure-rules/civil/rules/pd_pre-action_conduct#6.1
--- Quote ---
> the defendant responding within a reasonable time – 14 days in
a straight forward case and no more than 3 months in a very
complex one. The reply should include confirmation as to whether
the claim is accepted and, if it is not accepted, the reasons
why, together with an explanation as to which facts and parts of
the claim are disputed
--- End Quote ---
The defence needs to address the Particulars of Claim on the
N1SDT claim form you will receive and can point out how pathetic
they are if true, and should also address any other material
matters claimed on the Notice to Keeper. The defence need not
refer to the Letter of Claim unless it makes a point with which
you disagree which is different from the PoC and the NtK.
Do not look for a boilerplate/template defence, because the
courts are increasingly striking these out. It needs to be your
defence appropriate to your circumstances.
#Post#: 127840--------------------------------------------------
Re: PCN for parking for driving in a parking monitored area
DIR By: Improt999
Date: August 15, 2026, 5:35 am
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Ive actually tested 2(e)(ii) and won in court on that point
alone against PCM
#Post#: 128473--------------------------------------------------
Re: PCN for parking for driving in a parking monitored area
DIR By: shahcar
Date: August 22, 2026, 3:00 am
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I have written this to respond to the LOC.
Please tell me your comments.Thank you
Dear Sir/Madam,
I am writing in response to your Letter of Claim regarding an
alleged debt stemming from a Parking Charge Notice (PCN) issued
by Parking & Property Management Ltd. I formally dispute the
entirety of this alleged debt. I am the registered keeper of the
vehicle, and liability is completely denied.
Your client cannot transfer liability to me as the registered
keeper because the Notice to Keeper (NTK) fails to comply with
the requirements of Schedule 4 of the Protection of Freedoms Act
2012 (POFA). Accordingly, keeper liability has not been
established, and I do not accept that I am liable for the
alleged charge.
Your client’s claim relies entirely on Automatic Number Plate
Recognition(ANPR) camera data, which merely records images of a
vehicle passing a boundary line. This data fails to provide any
evidence of actual parking. I deny liability on the absolute
grounds that the vehicle was never parked. The vehicle was in
continuous motion for the entire duration, with the driver
inside, navigating the property at Parkwood.
The ANPR timestamps therefore do not establish the duration of
any parking event. They merely indicate the times at which the
vehicle passed the relevant entry and exit camera points. If
your client alleges that a parking contract was formed and
subsequently breached, it must provide evidence establishing the
actual parking event relied upon, rather than simply relying on
the vehicle's passage between ANPR camera locations.
Under the International Parking Community (IPC) Code of
Practice, operators must provide a mandatory Consideration
Period to allow drivers to enter a site, read the terms and
signage, and exit safely if they choose not to park. The time
spent driving around the property clearly falls within a
reasonable period of consideration and navigation. Because the
vehicle never came to a rest in a bay, no contract was ever
formed, and no breach occurred.
Pursuant to the Pre-Action Protocol for Debt Claims under the
Civil Procedure Rules, I request that you provide the following
essential documentation within 30 days of this letter:
•Conclusive, date-and-time-stamped photographic evidence proving
that the vehicle was stationary and parked in a designated bay,
rather than merely moving around or exiting.
•A copy of the contract or written authority from the landowner
at Parkwood permitting Parking & Property Management Ltd to
issue charges and bring legal action.
•A full, transparent breakdown of the sum claimed, as arbitrary
"debt collection/solicitor fees" represent unlawful double
recovery under consumer protection laws.
If you proceed to issue county court proceedings without
providing proof of actual parking, I will robustly defend the
claim and bring this letter to the court's attention regarding
your unreasonable conduct.
Yours faithfully,
#Post#: 128496--------------------------------------------------
Re: PCN for parking for driving in a parking monitored area
DIR By: shahcar
Date: August 22, 2026, 6:51 am
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I have got a few days to respond to the LOC.
I appreciate any comments.
#Post#: 128498--------------------------------------------------
Re: PCN for parking for driving in a parking monitored area
DIR By: jfollows
Date: August 22, 2026, 7:24 am
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Your response seems fine to me, but it will essentially be
ignored.
You will in due course receive a county court claim, for which
the details will be more relevant, because courts don’t ignore
things.
Your response to the LoC is essentially a paper trail to show
that you understand and are complying with the process. Little
more than that. Don’t get too exercised about it.
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