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#Post#: 100545--------------------------------------------------
Re: VCS CN - Stopping in a prohibited zone - Bristol airport - 3
x CNs in 13 minutes
DIR By: b789
Date: December 1, 2025, 10:17 am
---------------------------------------------------------
You have redacted the county court name. Why? Worcester County
Court is basic public domain info! Which County Court does the
order say to send documents to?????
Also, because you have been ordered to submit an amended defence
I need to see the three NtK's that were received for the alleged
breaches. I need to see them UNREDACTED except for your name,
address and the PCN number. NOTHING else needs to be redacted. I
need to see BOTH sides of each NtK. ONLY the original NtKs, not
any reminders.
I need to see for how long each stop was for and the location
they say that each stop was at. I need to see the evidence they
have on the NtK. If they have any other CCTV "evidence", show
that to us also.
If you want me to provide a suitable amended defence, do what I
have requested above!!!
#Post#: 100577--------------------------------------------------
Re: VCS CN - Stopping in a prohibited zone - Bristol airport - 3
x CNs in 13 minutes
DIR By: benb76
Date: December 1, 2025, 12:46 pm
---------------------------------------------------------
Thank you for coming back to me.
HTML https://drive.google.com/drive/u/0/folders/1bhwrWzVEc8wHkVpzG558F9vvHQMCIAWi
I have included the information you have requested, amended as
per your instructions. (Docs recd 011225).
I have included the NtKs, redacted according to your
instructions. (NtK redacted). These are in time order but do not
appear to state how long the car was parked for, however you
will see from the times that it was only a matter of minutes.
I have included a link to the evidence sent to me via email on
15/04/25, which includes the email itself and the attachments -
images of vehicle, signage and site plan.
Thank you for your assistance and please let me know if you
require any further information.
#Post#: 100586--------------------------------------------------
Re: VCS CN - Stopping in a prohibited zone - Bristol airport - 3
x CNs in 13 minutes
DIR By: InterCity125
Date: December 1, 2025, 1:52 pm
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The site plan they have provided is out dated. VSC signed a new
contract on 17th March 2023 with a revised site plan.
#Post#: 100659--------------------------------------------------
Re: VCS CN - Stopping in a prohibited zone - Bristol airport - 3
x CNs in 13 minutes
DIR By: b789
Date: December 2, 2025, 6:49 am
---------------------------------------------------------
Good. Here is the amended defence you must submit to the court
(not the CNBC as the original was):
--- Quote ---
>
> [center]IN THE COUNTY COURT AT WORCESTER[/center]
> [right]Claim No: [Claim Number][/right]
>
> [center]BETWEEN:
>
> Vehicle Control Services Ltd
> Claimant
>
> - and -
>
> [Defendant's Full Name]
> 
Defendant
>
>
---------------------------------------------------------
>
> AMENDED DEFENCE pursuant to order of DJ Redmond dated 20th
November 2025
> This amended defence replaces the original defence pursuant to
the court’s order.[/center]
>
> 1. The Defendant denies the claim in its entirety. The
Defendant asserts that there is no liability to the Claimant and
that no debt is owed. The claim is without merit and discloses
no lawful cause of action.
>
> 2. The Particulars of Claim are inadequately pleaded. They do
not identify the precise terms alleged to have been breached,
fail to specify the contractual basis for the claim, and provide
no clear calculation of the sum claimed.
>
> 3. The Claimant alleges the Defendant is liable either as the
driver or, in the alternative, as the keeper under Schedule 4 of
the Protection of Freedoms Act 2012. The Defendant is the
registered keeper of the vehicle but has never admitted to being
the driver. The Claimant has provided no evidence of driver
identity.
>
> 4. The location in question is Bristol Airport, which is
governed by statutory byelaws and therefore not classified as
relevant land under Schedule 4 of the Protection of Freedoms Act
2012. Accordingly, the Claimant cannot rely on the provisions of
PoFA to transfer liability from the unknown driver to the
registered keeper.
>
> 5. The Defendant relies on the persuasive appellate authority
in Vehicle Control Services Ltd v Edward (2023) [H0KF6C9C], in
which HHJ Gargan held at paragraph 35.3 that no inference can be
drawn from keeper status alone, and that the Claimant must prove
on the balance of probabilities that the Defendant was the
driver. No such evidence exists in this case.
>
> 6. The Claimant has failed to provide any proof that the
Defendant was the driver. As keeper, the Defendant cannot be
held liable under PoFA, and no alternative legal basis for
keeper liability has been established.
>
> 7. The three PCNs relate to alleged incidents at 02:23, 02:31,
and 02:36 on the same date. The Claimant has not provided any
evidence showing where the vehicle was located in each instance,
how long it was allegedly stationary, or whether any alleged
stopping occurred in view of any signage. The Claimant’s
photographs show only partial vehicle images in darkness and
reveal no identifiable surroundings.
>
> 8. The Claimant relies on a site plan dated October 2019. The
Defendant is aware that the Claimant entered into a new contract
with a revised site plan on 17 March 2023. The outdated plan
currently relied on is therefore no longer applicable and does
not assist the court in understanding where the vehicle was in
relation to signage or patrol zones.
>
> 9. The Claimant has issued three separate charges within a
13-minute window without establishing that the vehicle moved in
and out of distinct zones or that each instance involved a fresh
agreement or breach. In the absence of clear evidence, the
issuing of multiple charges for what may be a single or
continuous event amounts to double or triple recovery and an
abuse of process.
>
> 10. The signs relied upon by the Claimant state that stopping
is prohibited. These signs do not set out any contractual terms
capable of acceptance. They are prohibitory in nature and do not
constitute an offer.
>
> 11. It is a fundamental principle of contract law that an
offer must be capable of acceptance. A sign that says “No
stopping” or threatens a charge for stopping is not inviting
acceptance of terms but is instead forbidding an action. There
can be no contract where there is no offer. The signs do not
meet the requirements for contract formation and no valid
agreement was ever created.
>
> 12. This position is supported by established persuasive
authority including Jopson v Homeguard [2016] B9GF0A9E, where
HHJ Harris QC confirmed that momentary stopping does not
constitute parking, and that context is key. In that case, the
court rejected liability where the alleged contravention
involved a brief stop for a legitimate purpose. The Claimant in
this case has provided no contextual detail and no evidence that
any contractual terms were accepted.
>
> 13. The High Court in Ransomes v Anderson [2011] EWHC 1127
(QB) held that signage which merely prohibits an activity,
rather than offering terms for compliance, cannot give rise to a
contract. The signage relied on by the Claimant is of this
nature — it imposes a prohibition against stopping and threatens
a charge, but offers no service or terms that could be accepted.
As such, it is incapable of creating a contractual relationship,
and any charge claimed is a penalty, not a contractual debt.
>
> 14. The Claimant seeks £510, including £210 of unexplained
add‑ons. These sums are not supported by contract or
evidence. The Supreme Court in ParkingEye v Beavis [2015] UKSC
67 upheld a single parking charge as enforceable, but made no
allowance for additional recovery fees. Such uplifts fall
outside the ratio of Beavis and are penal in nature, contrary to
the principles in Dunlop Pneumatic Tyre Co Ltd v New Garage
[1915] AC 79. The Defendant therefore submits that the
add‑ons are irrecoverable and that the claim is liable to
strike‑out under CPR 3.4(2)(b).
>
> 15. The Defendant submitted a detailed response to the
Claimant’s Letter of Claim, clearly explaining that there was no
basis for pursuing the registered keeper, that the land is not
relevant under PoFA, that the signage cannot create a contract,
and that the claim was excessive and unreasonable. The Claimant
ignored this and issued proceedings without addressing any of
the issues raised. This is a breach of the Pre-Action Protocol
for Debt Claims and further evidence of unreasonable conduct.
>
> 16. The Defendant invites the court to strike out the claim
pursuant to CPR 3.4(2)(b) for failing to disclose a cause of
action, or alternatively to enter summary judgment under CPR
24.2. The Defendant further asks the court to consider a costs
order under CPR 27.14(2)(g) due to the Claimant’s unreasonable
conduct.
>
> Statement of truth
>
> I believe that the facts stated in this Amended 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:
--- End Quote ---
You must email the amended defence as a PDF attachment in a
single email addressed to
civil.worcester.countycourt[member=6517]justice[/member].gov.uk
and CCd to info@dcblegal.co.uk and to yourself.
--- Quote ---
> Subject: Claim No: [insert claim number] – Amended Defence
Pursuant to Court Order
>
> To:
civil.worcester.countycourt[member=6517]justice[/member].gov.uk
> CC: info@dcblegal.co.uk
>
> Dear Sir or Madam,
>
> Please find attached the Defendant’s amended defence in this
matter, filed pursuant to the Order of District Judge Redmond
dated 20 November 2025. This has been served within the
timeframe specified by the court.
>
> Claim Number: [insert claim number]
> Claimant: Vehicle Control Services Ltd
> Defendant: [insert full name of defendant]
>
> The amended defence has also been served on the Claimant’s
legal representative, DCB Legal Ltd, by way of copy to this
email.
>
> Please confirm receipt by return.
>
> Yours faithfully,
>
> [Defendant’s full name]
> [Address]
> [Email address]
--- End Quote ---
#Post#: 100790--------------------------------------------------
Re: VCS CN - Stopping in a prohibited zone - Bristol airport - 3
x CNs in 13 minutes
DIR By: benb76
Date: December 3, 2025, 1:44 am
---------------------------------------------------------
Thank you very much, that is extremely helpful and much
appreciated.
#Post#: 108073--------------------------------------------------
Re: VCS CN - Stopping in a prohibited zone - Bristol airport - 3
x CNs in 13 minutes
DIR By: benb76
Date: January 30, 2026, 1:46 pm
---------------------------------------------------------
Good evening, I have returned from holiday this week to receive
the Claimant's Witness statement for the court date on 24th
February 2026 (Doc One, Two & Three in the attached). Any advice
would be gratefully appreciated as always. Many thanks.
HTML https://drive.google.com/drive/u/0/folders/1bhwrWzVEc8wHkVpzG558F9vvHQMCIAWi
Edit - I have removed Doc one as I realised my name was showing
on one page, I will re-attach as soon as I can, apologies.
#Post#: 108081--------------------------------------------------
Re: VCS CN - Stopping in a prohibited zone - Bristol airport - 3
x CNs in 13 minutes
DIR By: benb76
Date: January 30, 2026, 3:28 pm
---------------------------------------------------------
Apologies, all files should be correct now, many thanks.
#Post#: 108082--------------------------------------------------
Re: VCS CN - Stopping in a prohibited zone - Bristol airport - 3
x CNs in 13 minutes
DIR By: movano
Date: January 30, 2026, 3:54 pm
---------------------------------------------------------
it would be interesting to know with all the court defences on
the forum, have these defences actually won in court? If so, how
many and where can we find transcripts.
Thank in advance
#Post#: 108083--------------------------------------------------
Re: VCS CN - Stopping in a prohibited zone - Bristol airport - 3
x CNs in 13 minutes
DIR By: DWMB2
Date: January 30, 2026, 4:32 pm
---------------------------------------------------------
I'm unlikely to get chance to look at this before Sunday PM. In
the meantime, do some searches both on here and the MSE forum
and you should find some other cases from Bristol Airport.
Here's one recent success - Bristol Airport no stopping fine -
Case success and £724 cost - DCB Legal
HTML https://forums.moneysavingexpert.com/discussion/6635565/bristol-airport-no-stopping-fine-case-success-and-724-cost-dcb-legal
[member=5761]movano[/member] - an individual's live case thread
is not the place for general queries about successes and
failures. I don't keep a success tally, but you can see all
cases on this forum. We don't get many transcripts, because most
defendants don't pay for them. Although here's another recent
one involving Bristol Airport where the defendant did pay for a
transcript - VCS crash and burn at Southampton County Court:
Bristol Airport Case
HTML https://forums.moneysavingexpert.com/discussion/6625532/vcs-crash-and-burn-at-southampton-county-court-bristol-airport-case
#Post#: 108086--------------------------------------------------
Re: VCS CN - Stopping in a prohibited zone - Bristol airport - 3
x CNs in 13 minutes
DIR By: benb76
Date: January 30, 2026, 5:16 pm
---------------------------------------------------------
Thank you. The court date isn't until 24th February.
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