DIR Return Create A Forum - Home
---------------------------------------------------------
FreeTrafficLegalAdvice
HTML https://ftla.createaforum.com
---------------------------------------------------------
*****************************************************
DIR Return to: Private parking tickets
*****************************************************
#Post#: 80603--------------------------------------------------
VCS PCN - Bristol Airport - No Stopping
DIR By: SR1891
Date: July 11, 2025, 9:39 am
---------------------------------------------------------
8 June 2024 Hampton turning at Bristol Airport. photographed
11:32:45 and 11:33:48 images attached. My husband is the
registered keeper of the vehicle.
An appeal was posted with no acknowledgement on who drive was.
the appeal was dismissed Having considered the points you have
raised and reviewed our records, we are unable to accept your
appeal. Our
main reason(s) for this decision are as follows:
The signs at the entrance to Bristol Airport and the access
roads within, clearly state "No Stopping", giving clear
notice that the land is private property and that a Charge of
£100 will be levied if vehicles do stop. The above detailed
vehicle stopped in a zone where stopping is prohibited and the
driver became liable to pay that Charge.
In your appeal it is unclear who the driver was when your
vehicle was seen to be stopped on the access road.
It is important we highlight that we will continue to pursue
this matter on the reasonable assumption that you were the
driver of the vehicle on the date in question until
information/evidence to the contrary is provided.
A review of our CCTV evidence has confirmed that on the date in
question, your vehicle stopped for an unreasonable
amount of time on the access road where restrictions apply.this
was dismissed due to the unreasonable amount of time the vehicle
was stopped
Yesterday I received court paperwork
[attachment deleted by admin]
#Post#: 80608--------------------------------------------------
Re: VCS PCN - Bristol Airport - No Stopping
DIR By: RichardW
Date: July 11, 2025, 9:54 am
---------------------------------------------------------
Please post the claim form, redacting personal details, claim no
and MCOL password; and your original appeal. This is probably
easily defended, but it will depend on what's in the appeal and
claim.
#Post#: 80762--------------------------------------------------
Re: VCS PCN - Bristol Airport - No Stopping
DIR By: b789
Date: July 13, 2025, 3:39 am
---------------------------------------------------------
So, you cone one here requesting assistance for an easily
defended case but fail to show us the claim form. DO you want
advice on how to bet this scam or not?
#Post#: 80867--------------------------------------------------
Re: VCS PCN - Bristol Airport - No Stopping
DIR By: SR1891
Date: July 14, 2025, 3:24 am
---------------------------------------------------------
apologies for delay in coming back for responses! attached is
the court papers and a copy of the appeal response.
[attachment deleted by admin]
#Post#: 80875--------------------------------------------------
Re: VCS PCN - Bristol Airport - No Stopping
DIR By: Dave65
Date: July 14, 2025, 4:15 am
---------------------------------------------------------
I see that they are still using this scam,
"It is important we highlight that we will continue to pursue
this matter on the reasonable assumption that you were the
driver of the vehicle on the date in question until
information/evidence to the contrary is provided"
There can be no assumption that someone was the driver.
They regulars will comment on this point.
#Post#: 80880--------------------------------------------------
Re: VCS PCN - Bristol Airport - No Stopping
DIR By: jfollows
Date: July 14, 2025, 4:25 am
---------------------------------------------------------
Airport Bylaws prevent the use of PoFA 2012 to transfer
liability from the unknown driver to the registered keeper. This
will form one part of your defence, which you’ll submit to the
court in due course. First of all you will need to respond to a
Letter of Claim (but maybe that time has passed). Ignore
everything from debt collectors, but post anything else from
anyone else and we can advise.
The complete rubbish about “reasonable assumption” about the
driver can be countered easily (VCS v Edward, for example). Just
continue not to identify the driver.
#Post#: 80884--------------------------------------------------
Re: VCS PCN - Bristol Airport - No Stopping
DIR By: SR1891
Date: July 14, 2025, 4:37 am
---------------------------------------------------------
I have completed the AOS
#Post#: 81238--------------------------------------------------
Re: VCS PCN - Bristol Airport - No Stopping
DIR By: b789
Date: July 16, 2025, 6:39 am
---------------------------------------------------------
With an issue date of 8th July, and having submitted an AoS
before 4pm Monday 28th July, you have until 4pm on Monday 11th
August to submit your defence.
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 Vehicle Control Services Ltd v [your full
name] Claim no.: [claim number]."
--- Quote ---
>
> [center]IN THE COUNTY COURT[/center]
> [right]Claim No: [Claim Number][/right]
>
> [center]BETWEEN:
>
> Vehicle Control Services 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 16.7.3(1);
>
> (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 explain the legal basis for the £170
claimed, nor does it provide any breakdown or justification for
the £70 add-on;
>
> (f) The PoC do not state what proportion of the claim is the
parking charge and what proportion is damages;
>
> (g) The PoC states that the Claimant is suing the Defendant as
“the driver and/or keeper”. This is impermissibly vague. The
Claimant must plead a single, coherent cause of action. The land
in question is not “relevant land” under Schedule 4 of the
Protection of Freedoms Act 2012, and therefore no keeper
liability can arise;
>
> (h) The PoC do not identify the driver. There is no legal
presumption that the registered keeper was the driver, and no
facts are pleaded to support such an inference;
>
> (i) The signage allegedly relied upon is prohibitory (“no
stopping”) and incapable of forming a contract. There is no
offer, no consideration, and no acceptance. The claim is legally
incoherent.[/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#: 81245--------------------------------------------------
Re: VCS PCN - Bristol Airport - No Stopping
DIR By: SR1891
Date: July 16, 2025, 7:05 am
---------------------------------------------------------
Thank you
*****************************************************
Page 1 of 1