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#Post#: 75266--------------------------------------------------
Re: NCP Parking PCNs – No Payment – Chobham Academy Stratford
DIR By: b789
Date: June 7, 2025, 12:06 pm
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Do you really want them to actually issue an N1SDT Claim Form?
They have up to 6 years to issue a claim. They may never issue
one. If they don't issue a claim within a few months of issuing
an LoC, they should issue a new LoC otherwise they are acting
unreasonably and opening themselves up to a costs order for
unreasonable behaviour.
#Post#: 75351--------------------------------------------------
Re: NCP Parking PCNs – No Payment – Chobham Academy Stratford
DIR By: correcthaunt
Date: June 8, 2025, 7:08 am
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No of course not but I do not want to be in a position that in
5.5 years time I will forget about it and then they issue N1SDT
Claim Forms to an address I do not reside anymore or what if I
am abroad etc. Keeping their lawfirm updated of mywhereabouts is
not ideal so I would prefer this gets resolved/closed.
#Post#: 115853--------------------------------------------------
Re: NCP Parking PCNs – No Payment – Chobham Academy Stratford
DIR By: correcthaunt
Date: April 14, 2026, 8:54 am
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Hi [member=103]DWMB2[/member] and [member=26]b789[/member],
I hope you have been well and are still around as I can see
you’ve been last active in Feb 26.
I know it’s been almost 2 years since the initial post but the
N1SDT Claim Form has just arrived, please see below a copy.
HTML https://i.postimg.cc/hXKKNTGc/N1SDT-Claim-Form-Redacted-Copy.jpg
HTML https://postimg.cc/hXKKNTGc
It appears that Moorside combined both claims into a single
claim on their own as no contact has been made from the
registered owner of the car side, and they demand £464.44 GBP in
total.
As highlighted in the letter “The driver agreed to pay within 28
days but did not”. As far as the registered owner is aware there
has been no contact with anyone (other than here on this forum)
regarding this case, so this is misleading if not straight up
lying.
I’ve just added the claim on moneyclaim.gov.uk and did the
Acknowledgment of Service as per the guidance provided:
HTML https://www.dropbox.com/s/xvqu3bask5m0zir/money-claim-online-How-to-Acknowledge.pdf?dl=0<br
/>
Please can you kindly help me out with my defence? Hopefully it
won’t go past this stage….
#Post#: 115856--------------------------------------------------
Re: NCP Parking PCNs – No Payment – Chobham Academy Stratford
DIR By: DWMB2
Date: April 14, 2026, 9:23 am
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--- Quote from: correcthaunt link ---
>
> As highlighted in the letter “The driver agreed to pay within
28 days but did not”. As far as the registered owner is aware
there has been no contact with anyone (other than here on this
forum) regarding this case, so this is misleading if not
straight up lying.
>
--- End Quote ---
This isn't necessarily misleading - in private parking cases,
the signage in the car park creates the contract, and the driver
accepts the contract by parking. That contract includes a term
that if the driver parks in breach of the advertised terms and
conditions, they agree to pay a parking charge of £100 within 28
days. (This doesn't mean the money is owed, much less by you as
the registered keeper, but that is the basis of these claims).
I would recommend reading similar cases on this forum to get an
idea of how to structure your defence, but it should be a fairly
concise series of statements covering each of NCP's claims,
stating whether you accept them, deny them, or are unable to
answer them.
As a quick example of a couple of points:
[indent]1. It is denied that the Claimant is entitled to relief
in the sum claimed or at all.
2. It is admitted that the Defendant was the registered keeper
of the relevant vehicle but liability is denied. The Claimant
failed to comply with the requirements of Schedule 4 of the
Protection of Freedoms Act 2012, namely, failing to give a
Notice to Keeper within the relevant period of 14 days beginning
with the day after that on which the specified period of parking
ended, as required by paragraph 9(4) of the act. Accordingly, it
is denied that the Claimant is entitled to recover any unpaid
charges from the Defendant as the registered keeper of the
vehicle.[/indent]
You may also wish to challenge their incredibly vague
particulars of claim (they don't even state the term they claim
was breached giving rise to any liability).
#Post#: 115863--------------------------------------------------
Re: NCP Parking PCNs – No Payment – Chobham Academy Stratford
DIR By: correcthaunt
Date: April 14, 2026, 10:23 am
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Hi [member=103]DWMB2[/member],
Thank you for your prompt response.
Please note that the signage was updated in between the time the
alleged contravention happened (early July 2024) and when the
initial two PCNs were physically seen ( August 2024). In a space
of a couple of weeks the car park management has gotten rid of
the old yellow signage (as can be seen on the google maps,
albeit illegible) and replace it with new purple ones.
I tried looking for another Chobham posts but these were
resolved before this has gotten to this stage.
Here is what I manged to find, will this be enough or is this
too generic?
“
DEFENCE
1. The Defendant denies any liability for this claim.
2. There is a lack of precise detail in the Particulars of Claim
(PoC) in respect of the factual and legal allegations made
against the Defendant such that the PoC do not comply with CPR
16.4.
3. The Defendant is unable to plead properly to the PoC because:
(a) The contract referred to is not detailed or attached to the
PoC in accordance with CPR PD 16(7.5);
(b) The PoC do not state the exact wording of the clause (or
clauses) of the terms and conditions of the contract (or
contracts) which is/are relied on;
(c) The PoC do not state with sufficient particularity exactly
where the breach occurred, the exact time when the breach
occurred and how long it is alleged that the vehicle was parked
before the parking charge was allegedly incurred;
(d) The PoC do not state exactly how the claim for statutory
interest is calculated;
(e) The PoC do not state what proportion of the claim is the
parking charge and what proportion is damages;
(f) The PoC states that the Claimant is suing the defendant as
the driver or the keeper. The claimant obviously knows whether
the defendant is being sued as the driver or the keeper and
should not be permitted to plead alternative causes of action.
4. The Defendant has attached to this defence a copy of an order
made at another court which the allocating judge ought to make
at this stage so that the Defendant can then know and understand
the case which he/she/it faces and can then respond properly to
the claim.
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:
”
Also not sure I can include what you’ve posted as they’ve issued
the letter on 15.07.2024 for the date of the incident of
01.07.2024, so that’s within the 2 weeks no? Should I add
anything to the above defence regarding the change of signage or
that they never provided a copy of the said signage? Also, if
they were to provide a picture of the current signane, would I
be able to challenge this? Like how can they prove..
HTML https://www.google.com/maps/@51.5499359,-0.0077207,3a,15.9y,340.71h,87.73t/data=!3m8!1e1!3m6!1siPNYxHfKzatB0CPtyPIFmw!2e0!5s20210301T000000!6shttps:%2F%2Fstreetviewpixels-pa.googleapis.com%2Fv1%2Fthumbnail%3Fcb_client%3Dmaps_sv.tactile%26w%3D900%26h%3D600%26pitch%3D2.268096929336579%26panoid%3DiPNYxHfKzatB0CPtyPIFmw%26yaw%3D340.7064147750741!7i16384!8i8192?entry=ttu&g_ep=EgoyMDI2MDQwOC4wIKXMDSoASAFQAw%3D%3D<br
/>
Any help is greatly appreciated.
#Post#: 115872--------------------------------------------------
Re: NCP Parking PCNs – No Payment – Chobham Academy Stratford
DIR By: DWMB2
Date: April 14, 2026, 11:30 am
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If you read the relevant sections of Schedule 4 of the
Protection of Freedoms Act, you'll note that the requirement is
that the notice is given, that is, delivered within 14 days, nor
merely issued within 14 days.
The same act clarifies that a notice sent by post is presumed to
be delivered 2 working days after the day on which it is posted.
For the other one, you can make the same point, insofar as the
notice wasn't delivered. You'll struggle to prove it wasn't
delivered, but it's an honest version of events, and will put
them to proof both that a notice was issued, and issued on time!
You might also want to introduce a point that denies any
contract was entered into by the driver, by virtue of the
signage being insufficient.
#Post#: 115876--------------------------------------------------
Re: NCP Parking PCNs – No Payment – Chobham Academy Stratford
DIR By: correcthaunt
Date: April 14, 2026, 12:30 pm
---------------------------------------------------------
Okay I tried to put something together. Please can someone
glimps over this before I e-mail this to the court?
DEFENCE
1. Denial of Liability
a)
in the sum claimed, or at all.
b)
vehicle but denies liability for the entirety of the claim.
2. Defective Particulars of Claim
a)
and Practice Direction 16, lacking sufficient detail to
establish a cause of action.
b)
to the following deficiencies:
(a) No contract is attached, contrary to CPR PD 16(7.5);
(b) No specific contractual terms are identified;
(c) No clear details of location, time, or duration of the
alleged breach;
(d) No explanation of how the sum claimed has been calculated;
(e) No distinction between the parking charge and additional
sums;
(f) The Claimant pleads liability as “driver or keeper,” which
is improper.
3. No Keeper Liability (PoFA 2012)
a)
Protection of Freedoms Act 2012.
b)
Notice to Keeper within the required 14-day period (paragraph
9(4)).
c)
was received at all.
d)
driver to the Defendant as registered keeper.
e)
and has not done so.
4. Failure of Service
a)
to Keeper within the statutory timeframe.
b)
c)
d)
e)
5. No Contract Formed (Signage Issues)
a)
and the Claimant.
b)
inadequate.
c)
several years, was that parking charges only applied during
weekday daytime hours.
d)
this understanding without issue.
e)
replaced, indicating that the previous signage was inadequate or
misleading.
The Claimant is put to strict proof of:
1.
2.
3.
4.
no contract can be formed.
6. Inconsistent and Confusing Enforcement
a)
relation to two separate alleged contraventions.
b)
by a valid Notice to Keeper.
c)
confusion and prejudice.
7. Inflated and Unlawful Charges
a)
original parking charge of sub £2.
b)
recoverable and constitute double recovery.
c)
decisions.
8. Defence Order
The Defendant has attached to this defence a copy of an order
made at another court which the allocating judge ought to make
at this stage so that the Defendant can then know and understand
the case which he/she/it faces and can then respond properly to
the claim.
9. Conclusion
The Defendant denies that:
a)
b)
c)
d)
dismissed.
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.
#Post#: 119195--------------------------------------------------
Re: NCP Parking PCNs – No Payment – Chobham Academy Stratford
DIR By: correcthaunt
Date: May 19, 2026, 7:40 am
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Hi [member=103]DWMB2[/member],
I hope all is well.
Please note that I have submitted the above defence a few weeks
back and I have just received a letter from Moorside Legal
offering to settle the outstanding balance of £464.44 GBP out of
the court by £220 in one of payment or the full balance via 2
separate payments.
If the claim is not settled and we can’t reach a settlement they
advise that their client wishes to proceed with the claim.
They explain in the letter that both parties need to file DQ,
provided their copy of it and say they have filed it with the
court now.
I just wanted to check, given that they have already filed their
N180 and I am not planning on settling with them then can I
submit my own N180?
Just to confirm I have to e-mail
“dq.cnbc[member=6517]justice[/member].gov.uk” and cc Moorside
Legal correct?
#Post#: 119200--------------------------------------------------
Re: NCP Parking PCNs – No Payment – Chobham Academy Stratford
DIR By: correcthaunt
Date: May 19, 2026, 7:59 am
---------------------------------------------------------
Correction, I think I need to wait for MOCL to be updated/letter
to arrive before I can e-mail the court with my own DQ. I will
keep an eye on it. Is there any point reaching out to Moorside
Legal?
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