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#Post#: 122216--------------------------------------------------
Re: Horizon Parking - Court Papers received - Water Gardens
Harlow
DIR By: ParkingLobster72
Date: June 18, 2026, 9:31 am
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HTML https://smallpdf.com/file#s=7a2ca02d-a7ff-4652-891a-cb22bd779c8b
#Post#: 122309--------------------------------------------------
Re: Horizon Parking - Court Papers received - Water Gardens
Harlow
DIR By: ParkingLobster72
Date: June 19, 2026, 3:17 am
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Today is the last day I have to pay the money and make it all go
away.
I cant afford a CCJ
#Post#: 122338--------------------------------------------------
Re: Horizon Parking - Court Papers received - Water Gardens
Harlow
DIR By: jfollows
Date: June 19, 2026, 6:15 am
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CCJ: read
HTML https://www.ftla.uk/private-parking-tickets/kellys-storage-luton-universal-parking-enforcement-ltd/msg59804/#msg59804
What do you mean by
--- Quote ---
> Today is the last day I have to pay the money and make it all
go away.
--- End Quote ---
?
--- Quote ---
> If the fee has been paid and the claimant has submitted a
Witness Statement then (a) you need to complain that you weren’t
sent a copy (b) you need to get a copy and rebut anything you
disagree with in it and (c) you do this by submitting your own
Witness Statement.
--- End Quote ---
Assuming the court fee has been paid, and the claimant has
submitted a Witness Statement, then you need to submit your own
Witness Statement.
#Post#: 122342--------------------------------------------------
Re: Horizon Parking - Court Papers received - Water Gardens
Harlow
DIR By: ParkingLobster72
Date: June 19, 2026, 6:34 am
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Oh I was wrong.
The email they sent said "The Claimant is willing to accept the
sum of £135.00 in full and final settlement of the claim,
provided that payment is received by 4pm 17th June 2026. This
offer is made on the basis that, upon cleared receipt of the
settlement sum, the Claimant will take steps to vacate the
hearing, with no further order as to costs save as agreed"
Where do I start?
Who do I complain to that they did not submit the witness
statement?
And what do I write because theirs is all about another case.
#Post#: 122351--------------------------------------------------
Re: Horizon Parking - Court Papers received - Water Gardens
Harlow
DIR By: ParkingLobster72
Date: June 19, 2026, 7:10 am
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ChatGPT has helped me with this, should i also include how they
did not submit their witness statement or pay the fee by the
deadline?
1. Introduction
I am the registered keeper of the vehicle with registration
number XXX.
I make this statement from my own knowledge and belief in
response to the Claimant’s claim.
2. I was not the driver
I was not the driver of the vehicle on 25 February 2024, the
date of the alleged parking event.
At that time, the vehicle was being used by my former partner.
3. Domestic abuse circumstances
My former partner was subsequently removed from my home by the
police following a domestic abuse situation.
As a result of this, I no longer have contact with him and I am
unable to obtain a statement or any evidence from him.
I respectfully ask the court to take into account that this is
the reason I cannot provide further details from the driver.
4. Awareness of the Parking Charge
I did not have proper knowledge or control over correspondence
relating to this matter at the time it was being sent.
I became aware of the Parking Charge Notice and related
correspondence only after my former partner had been removed
from the property.
Upon becoming aware, I acted promptly and sought advice, and I
have engaged with the process in good faith.
5. The Claimant has not proven I was the driver
The Claimant has provided no evidence that I was the driver of
the vehicle.
Their case relies on an assumption that I, as the registered
keeper, am liable.
I deny that I was the driver and there is no evidence before the
court to contradict my statement.
6. Failure to establish keeper liability under POFA
As the Claimant cannot establish that I was the driver, they
must rely on Schedule 4 of the Protection of Freedoms Act 2012
(“POFA”) to hold me liable as keeper.
POFA requires strict compliance with specific statutory
conditions in order to transfer liability from the driver to the
keeper.
The Claimant has not demonstrated such compliance. In
particular:
(a) The Claimant has not provided a clear explanation or
evidence of how each requirement under Schedule 4 has been
satisfied.
(b) The Claimant relies on a generic assertion of keeper
liability rather than strict proof.
(c) The Notice to Keeper relies on ANPR entry and exit times
rather than properly identifying a clear “period of parking” as
required by POFA.
(d) The Claimant’s witness statement does not address POFA
compliance in any structured or legally sufficient way.
In the absence of strict compliance with POFA, liability cannot
be transferred to me as the registered keeper.
7. ANPR evidence does not prove a breach
The Claimant relies on ANPR timestamps to allege a parking
duration.
These timestamps only show entry and exit from the site and do
not establish:
The actual period the vehicle was parked,
Whether the driver had time to read terms and conditions,
Whether a contract was properly formed.
I submit that this evidence is insufficient to establish a
breach of contract.
8. Claimant’s absence
The Claimant has confirmed that it will not attend the hearing
and has asked the Court to decide the matter in its absence.
[Trial Bundle (1) | PDF]
As a result, the Claimant is not present to:
Challenge my evidence,
Clarify deficiencies in its case,
Provide further proof of compliance with POFA.
I respectfully submit that this undermines the Claimant’s
ability to discharge the burden of proof.
9. Additional costs are not recoverable
The Claimant has added £70 in additional “contractual costs” to
the original parking charge. [Trial Bundle (1) | PDF]
I submit that these additional costs are not recoverable,
represent an inflated claim, and are inconsistent with
established case law principles.
10. Conclusion
I was not the driver of the vehicle.
The Claimant has failed to prove that I was the driver.
The Claimant has failed to demonstrate strict compliance with
the Protection of Freedoms Act 2012 and therefore cannot hold me
liable as keeper.
The Claimant has chosen not to attend the hearing and cannot
address the clear deficiencies in its case.
11. Request to the Court
In light of the above, I respectfully request that the Court
dismisses the claim.
Statement of Truth
I believe that the facts stated in this witness statement are
true.
Signed: ___________________________
#Post#: 122353--------------------------------------------------
Re: Horizon Parking - Court Papers received - Water Gardens
Harlow
DIR By: jfollows
Date: June 19, 2026, 7:17 am
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Yes, you should include their failures in your statement as you
say, also double-check their WS to ensure there are no further
claims in it with which you disagree, otherwise I’d say send
this asap.
#Post#: 122360--------------------------------------------------
Re: Horizon Parking - Court Papers received - Water Gardens
Harlow
DIR By: ParkingLobster72
Date: June 19, 2026, 8:01 am
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OK, I have sent this to them and the court.
So now I'm going to court?
What do I need to do?
#Post#: 122448--------------------------------------------------
Re: Horizon Parking - Court Papers received - Water Gardens
Harlow
DIR By: jfollows
Date: June 20, 2026, 5:38 am
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The usual advice is to print and take multiple copies of your
Witness Statement, including references it makes such as the
text of the legislation it refers to, to give to the magistrates
on the day to help them with their decision. You don’t need to
do the same for the claimant’s bumf - if they can’t be bothered
to turn up it’s their problem - except for anything they’ve
stated that you disagree with and which isn’t covered by your
Witness Statement.
What do you mean by
--- Quote ---
> theirs is all about another case
--- End Quote ---
?
If you mean their WS is wrong, nothing to do with you, then your
WS should have said this already.
#Post#: 122451--------------------------------------------------
Re: Horizon Parking - Court Papers received - Water Gardens
Harlow
DIR By: InterCity125
Date: June 20, 2026, 5:54 am
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The original NtK is massively non-compliant and this needs to be
drawn to the attention of the Court if this hearing does go
ahead.
I can provide extra commentary for you to take with you on the
day - this can then be used to walk the Judge through the
non-compliance.
#Post#: 122455--------------------------------------------------
Re: Horizon Parking - Court Papers received - Water Gardens
Harlow
DIR By: jfollows
Date: June 20, 2026, 6:12 am
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Remember, if you win, to claim for expenses, which are limited
but include travel expenses (ironically including parking fees)
and loss of earnings.
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