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#Post#: 74655--------------------------------------------------
BW legal letter of claim
DIR By: Sel1700
Date: June 3, 2025, 4:05 pm
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Hello, a relative of mine received a letter of claim from HM
tribunals and courts informing him that he owes to £245 for not
paying for parking.this is the first I know about it. Could
someone please have a look at this claim form to see if it
adheres to the rules.thanks
[attachment deleted by admin]
#Post#: 74658--------------------------------------------------
Re: BW legal letter of claim
DIR By: DWMB2
Date: June 3, 2025, 4:18 pm
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Excellent - they claim that the parking charge is £100, that
their client is also claiming £70 of "recovery costs", and yet
the "Amount claimed" is £160 ;D
Before we advise on responding to the claim form - has your
relative engaged in any correspondence with Napier prior to the
issuing of this claim?
(PS - if possible it would be preferable for your relative to
post directly, as everything will need to be done in their name)
#Post#: 74663--------------------------------------------------
Re: BW legal letter of claim
DIR By: Sel1700
Date: June 3, 2025, 4:38 pm
---------------------------------------------------------
Thank you for the quick reply. My relative is next to me and we
are acting together in his name. no he has not engaged in any
correspondence with any one including Napier.
#Post#: 74682--------------------------------------------------
Re: BW legal letter of claim
DIR By: b789
Date: June 4, 2025, 3:19 am
---------------------------------------------------------
With an issue date of 27th May, you have until 4pm on Monday
16th June to submit your defence. If you submit an
Acknowledgement of Service (AoS) before then, you would then
have until 4pm on Monday 30th June to submit your defence.
If you want to submit an AoS then follow the instructions in
this linked PDF:
HTML https://www.dropbox.com/s/xvqu3bask5m0zir/money-claim-online-How-to-Acknowledge.pdf?dl=0
Otherwise, here is the defence and link to the draft order that
goes with it. You only need to edit your name and the claim
number. You sign the defence by typing your full name for the
signature and date it. There is nothing to edit in the draft
order.
When you're ready you combine both documents as a single PDF
attachment and send as an attachment in an email to
claimresponses.cnbc@justice.gov.uk and CC in yourself. The claim
number must be in the email subject field and in the body of the
email just put: "Please find attached the defence and draft
order in the matter of Napier Parking Ltd v [your full name]
Claim no.: [claim number]."
--- Quote ---
> [center]IN THE COUNTY COURT[/center]
> [right]Claim No: [Claim Number][/right]
>
> [center]BETWEEN:
>
> Napier Parking Ltd
> Claimant
>
> - and -
>
> [Defendant's Full Name]
> 
Defendant
>
>
---------------------------------------------------------
>
> DEFENCE[/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 does not
adequately disclose any comprehensible cause of action.
>
> 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:
>
> [indent](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 adequately set out the reason (or reasons)
why the claimant asserts the defendant has breached the contract
(or contracts)
>
> (d) 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;
>
> (e) The PoC do not state precisely how the sum claimed is
calculated, including the basis for any statutory interest,
damages, or other charges;
>
> (f) The PoC contradict themselves regarding the amount
claimed. The Claimant states that the claim is “for £100.00 for
an unpaid parking charge”, yet also states that £70.00 in
recovery costs is included. £100.00 plus £70.00 equals £170.00,
but the amount claimed is only £160.00. The figures are
mathematically incoherent and cannot all be true. The Defendant
is left in the position of not knowing what sum is genuinely
being claimed or how it is calculated;;
>
> (g) The PoC do not provide clarity on whether the Defendant is
sued as the driver or the keeper of the vehicle, as the claimant
cannot plead alternative causes of action without
specificity.[/indent]
>
> 4. The Defendant attaches to this defence a copy of a draft
order approved by a district judge at another court. The court
struck out the claim of its own initiative after determining
that the Particulars of Claim failed to comply with CPR 16.4.
The judge noted that the claimant had failed to:
>
> [indent](i) Set out the exact wording of the clause (or
clauses) of the terms and conditions relied upon;
>
> (ii) Adequately explain the reasons why the defendant was
allegedly in breach of contract;
>
> (iii) Provide separate, detailed Particulars of Claim as
permitted under CPR PD 7C.5.2(2).
>
> (iv) The court further observed that, given the modest sum
claimed, requiring further case management steps would be
disproportionate and contrary to the overriding objective.
Accordingly, the judge struck out the claim outright rather than
permitting an amendment.[/indent]
>
> 5. The Defendant submits that the same reasoning applies in
this case and invites the court to adopt a similar approach by
striking out the claim for the Claimant’s failure to comply with
CPR 16.4.
>
> 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:
--- End Quote ---
Draft Order for the defence
HTML https://www.dropbox.com/scl/fi/tcewefk7daozuje25chkl/Strikeout-order-v2.pdf?rlkey=wxnymo8mwcma2jj8xihjm7pdx&st=nbtf0cn6&dl=0
#Post#: 74761--------------------------------------------------
Re: BW legal letter of claim
DIR By: Sel1700
Date: June 4, 2025, 9:38 am
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Thank you so much for this. I'm really taken back by your
generosity and the clarity you've brought to the matter. Would
love to show support back. I'm going to file the defence and
feel good in my heart that these faceless, money grabbing
businesses feel some pushback. I'm sure that this will get the
case dropped but do you have any knowledge of instances where
the claimant in the face of this defence still went for a
hearing
#Post#: 80815--------------------------------------------------
Re: BW legal letter of claim
DIR By: Sel1700
Date: July 13, 2025, 10:58 am
---------------------------------------------------------
Hello, I received these letters in the post last week. It looks
like they are going through with it to court. Will I have to
attend or is my defence enough?
[attachment deleted by admin]
#Post#: 80816--------------------------------------------------
Re: BW legal letter of claim
DIR By: Sel1700
Date: July 13, 2025, 10:59 am
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Here are the others
[attachment deleted by admin]
#Post#: 80817--------------------------------------------------
Re: BW legal letter of claim
DIR By: b789
Date: July 13, 2025, 11:00 am
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Just standard procedural stuff.
Having received your own N180 (make sure it is not simply a copy
of the claimants N180), do not use the paper form. Ignore all
the other forms that came with it. you can discard those.
Download your own here and fill it in on your computer. You sign
it by simply typing your full name in the signature box.
HTML https://assets.publishing.service.gov.uk/media/673341e779e9143625613543/N180_1124.pdf
Here are the answers to some of the less obvious questions:
[indent]• The name of the court is "Civil National Business
Centre".
• To be completed by "Your full name" and you are the
"Defendant".
• C1: "YES"
• D1: "NO". Reason: "I wish to question the Claimant about their
evidence at a hearing in person and to expose omissions and any
misleading or incorrect evidence or assertions.
Given the Claimant is a firm who complete cut & paste parking
case paperwork for a living, having this case heard solely on
papers would appear to put the Claimant at an unfair advantage,
especially as they would no doubt prefer the Defendant not to
have the opportunity to expose the issues in the Claimants
template submissions or speak as the only true witness to events
in question.."
• F1: Whichever is your nearest county court. Use this to find
it:
HTML https://www.find-court-tribunal.service.gov.uk/search-option
• F3: "1".
• Sign the form by simply typing your full name for the
signature.[/indent]
When you have completed the form, attach it to a single email
addressed to both dq.cnbc@justice.gov.uk and info@dcblegal.co.uk
and CC in yourself. Make sure that the claim number is in the
subject field of the email.
#Post#: 114021--------------------------------------------------
Re: BW legal letter of claim
DIR By: Sel1700
Date: March 22, 2026, 1:10 pm
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Hello. I've followed all the advice on the site out it seems
bwlegal have paid the court fee and I'm going to court. Should
we just settle now?
HTML https://ibb.co/xqbGgR4q
#Post#: 114022--------------------------------------------------
Re: BW legal letter of claim
DIR By: Sel1700
Date: March 22, 2026, 1:11 pm
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HTML https://ibb.co/xqbGgR4q
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