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#Post#: 120011--------------------------------------------------
Re: Stansted Airport
DIR By: jfollows
Date: May 29, 2026, 8:40 am
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I sugest you need to do your own research and post your proposed
defence here.
Template/boilerplate defences are increasingly being struck out
by courts, however the circumstances here are so common that you
should have little difficulty modifying something used
previously to meet your requirements.
#Post#: 120088--------------------------------------------------
Re: Stansted Airport
DIR By: InterCity125
Date: May 30, 2026, 2:29 am
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Southgate Park - Stansted / MET Parking Defence Points
That the claim is denied in its entirety and that no debt is
owed.
It is acknowledged that I am the Registered Keeper of the
vehicle specifically mentioned in the Claim Form.
In the first instance, the vehicle driver is not known by the
claimant.
That this is a contract dispute and, as such, there is
absolutely no legal requirement for a Registered Keeper to
reveal driver details to an unregulated private parking
contractor.
As such, I will not be providing any driver details and no
presumption can be drawn from me simply exercising my legal
right.
That the land, mentioned by he Claimant, at Southgate Park,
Stansted is clearly inside the boundary of the Stansted Airport
Area.
That all the land inside the Stansted Airport Area is
designated, by the Government, as being Land Under Statutory
Control and, as such, PoFA 2012 Schedule 4 cannot be used at
this particular location as this location is not 'relevant land'
as defined under PoFA 2012.
That a Statutory Instrument exists and is legally in place.
That this Statutory Instrument is known as 'The Stansted -
London Byelaws'.
That the Statutory Instrument sets out parking controls within
the Land Under Statutory Control.
That the 'Statutory Control' mentioned in the term 'Land Under
Statutory Control' is the Statutory Instrument and, as such, by
definition, the Statutory Instrument covers the entire area of
Land Under Statutory Control.
That while the land at Southgate Park is privately owned, it
remains within the official Airport Area and therefore remains
under the control of the Statutory Instrument.
The Claimant has stated (in previous communications) that the
land at Southgate Park is no longer within the designated area
under statutory control and that, consequently, PoFA 2012 can in
fact be used to establish Keeper Liability at the location.
That I therefore put the Claimant to STRICT PROOF to provide, to
the Court, a formal Airport Plan document provided by either the
LOCAL AUTHORITY or the GOVERNMENT which shows the claimed
revised airport area boundary which specifically excludes the
land at Southgate Park.
That the airport plan often used, by the claimant, in the
parking appeals process will not be accepted since that plan
specifically excludes land not owned by the airport operator -
meaning; that even if the land at Southgate Park was inside the
Airport Area it would never be shown on that particular plan.
That, as PoFA 2012 cannot be used at Southgate Park, the
Claimant is unable to move liability from the unknown driver
onto the Registered Keeper.
That, with both the driver unknown and no keeper liability,
there is no legal route by which the Claimant can hold me
liable.
The Claim is therefore denied in its entirety.
Additional defence points which the Court should be made aware
of;
That the Claimant's issued Parking Charge Notices (PCNs) are in
clear breach of the parking operators Code of Practice since the
PCNs specifically mention PoFA Keeper Liability.
The operators Code of Practice EXPRESSLY PROHIBBITS operators
specifying keeper liability under PoFA 2012 when PoFA cannot
apply.
A breach of the Code of Practice is automatically a breach of
the operator's KODAE Agreement with the DVLA since that
agreement specifically requires that the operator agree to
follow the Code of Practice.
My details have therefore been obtained in breach of the KODAE
Agreement.
That this also constitutes a misuse of personal data.
#Post#: 120111--------------------------------------------------
Re: Stansted Airport
DIR By: Gaz88
Date: May 30, 2026, 7:26 am
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Thanks a lot InerCity, that's very kind and much appreciated :)
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