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#Post#: 86327--------------------------------------------------
County Court letter from SIP parking in Manchester
DIR By: Kramer
Date: August 19, 2025, 11:31 am
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I received this letter and am weighing up my options.
Seems like I’m bang to rights as I have no ticket and I’ve
checked my bank statement and don’t appear to have bought one
(unless it was cash)…but just a couple of things making me wary
of paying it.
• I don’t have any letters notifying me of the original claim.
And from this letter can’t see their evidence.
• I’m wondering why it’s taken them 31 months to try the courts.
This could be absolutely normal though?
• The only way to make payment is through the claimants postal
address? Again - could be normal but that seems very strange. Im
not 85 years old and so don’t have a cheque book.
I know the “ignore it” advice for private companies is old hat,
but just wondering if I should (a) crack on and pay it
(somehow??), (b) whether I could say that I’ll give them the
£100 charge and the court fee but not the £60 “debt damage”
costs or (c) fight it in court (I would probably lose?)
Just seems a bit boilerplate with no evidence.
Thanks very much
#Post#: 86497--------------------------------------------------
Re: County Court letter from SIP parking in Manchester
DIR By: b789
Date: August 20, 2025, 8:34 am
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It's not just a "letter"! You have received an N1SDT county
court claim. You cannot simply ignore it or do nothing.
Is this the first you knew about this? Did you not receive a
Notice to Keeper (NtK)? Did you not receive a Letter of Claim
(LoC) before the actual claim?
Looking at the Particulars of Claim you have shown us, this has
been issued by SIPs own in-house legal team.
What is the issue date of the claim? Without knowing that, we
cannot advise you of your deadlines for defence submission.
#Post#: 86512--------------------------------------------------
Re: County Court letter from SIP parking in Manchester
DIR By: Kramer
Date: August 20, 2025, 9:35 am
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Yes sorry Claim Form. And as I said, I know it can't be ignored.
And no I haven't received any notices or claims.
Issue date is 7th August (so effectively the 12th).
Thanks for the help
#Post#: 86524--------------------------------------------------
Re: County Court letter from SIP parking in Manchester
DIR By: b789
Date: August 20, 2025, 11:04 am
---------------------------------------------------------
Why do you think that you did not receive any notice or LoC? Is
the address on your V5C showing your current address? One of the
main reasons people get CCJs out of the blue is because they did
not update their V5C after a previous move. Updating your
drivers licence doesn't automatically update your V5C.
Obviously they found you through credit reference search.
However, if you were not served with the claim and you knew
nothing about it until the claim itself. They have not complied
with the Pre Action Protocols.
You are entitled to make a CPR 31.14 request and should send the
following to the Claimant, preferably by email to
info@sipcarparks.co.uk and CC yourself:
--- Quote ---
> Subject: CPR 31.14 Request – Claim [number]
>
> Dear Sirs,
>
> I acknowledge service. Please provide, within 7 days, copies
of the documents mentioned in your Particulars:
>
> [indent]1. the contract/signage terms and site plan for Water
Street, Manchester;
> 2. NtD (if any), NtK, all images/logs, and event record for
06/01/2023 13:30:24 ref 149256680;
> 3. landowner authority/contract;
> 4. the basis and calculation of the £60.[/indent]
>
> If you contend any item is not “mentioned”, explain why.
Absent compliance I will seek directions and costs.
>
> Yours faithfully,
>
> [Name & address]
--- End Quote ---
You should also send SIP a Subject Access Request (SAR) to their
DPO at dataprotection@sipcarparks.co.uk and again, CC yourself.
--- Quote ---
> Subject: Data Subject Access Request – [Full name], VRM
[ABC123], Claim [number]
>
> Dear Sirs,
>
> Please supply all personal data you hold regarding me and VRM
[ABC123], including all letters/emails, images, ANPR/handheld
logs, timeline/system notes, DVLA requests/responses, and the
underlying PCN record for ref 149256680 (06/01/2023). Attached:
proof of ID and proof of address.
>
> [Name]
--- End Quote ---
DO not call them. Everything must be in writing.
You can do the Acknowledgement of Service (AoS) now but do not
submit the defence provided below until you have received
responses to the above emails. Only submit it by the deadline if
you have not heard back from them by then. If you can show us
their responses, there may be a need to tweak the defence
slightly.
For now, take this into account... With an issue date of 7th
August you have until 4pm on Tuesday 26th August to submit your
defence. If you submit an Acknowledgement of Service (AoS)
before then, you would then have until 4pm on Tuesday 9th
September to submit your defence.
You only need to submit an AoS if you need extra time to prepare
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
Until very recently, we never advised using the MCOL to submit a
defence. However, due to recent systemic failures within the
CNBC, we feel that it is safer to now submit a short defence
using MCOL as it is instantly submitted and entered into the
"system". Whilst it will deny the use of some formatting or
inclusion of transcripts etc. these can always be included with
the Witness Statement (WS) later, if it ever progresses that
far.
You will need to copy and paste it into the defence text box on
MCOL. It has been checked to make sure that it will fit into the
122 lines limit.
--- Quote ---
> 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 adequately comply
with CPR 16.4.
>
> 3. For the avoidance of doubt, even if the phrase “Vehicle not
permitted & grace period exceeded” were taken to be a minimal
compliance with CPR 16.4(1)(a), the PoC remain defective. The
Defendant is unable to plead properly to the PoC because:
>
> (a) The claim is put on a contractual footing but no written
terms are pleaded or exhibited, contrary to 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 pleaded bases are internally inconsistent (“vehicle
not permitted” vs “grace period exceeded”): either parking was
prohibited (no contractual offer) or it was permitted subject to
terms; it cannot be both.;
>
> (d) No period of parking is pleaded, nor facts explaining how
any breach is said to have occurred (a timestamp alone is
insufficient);
>
> (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 do not state what proportion of the claim is the
parking charge and what proportion is damages;
>
> (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.
>
> 4. The Defendant submits that courts have previously struck
out similar claims of their own initiative for failure to
adequately comply with CPR 16.4, particularly where the
Particulars of Claim failed to specify the contractual terms
relied upon or explain the alleged breach with sufficient
clarity.
>
> 5. In comparable cases involving modest sums, judges have
found that requiring further case management steps would be
disproportionate and contrary to the overriding objective.
Accordingly, strike-out was deemed appropriate. 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
due to the Claimant’s failure to adequately comply with CPR
16.4, rather than permitting an amendment. The Defendant
proposes that the following Order be made:
>
> Draft Order:
>
> Of the Court's own initiative and upon reading the particulars
of claim and the defence.
>
> AND the court being of the view that the particulars of claim
do not adequately comply with CPR 16.4(1)(a) because: (a) they
do not set out the exact wording of the clause (or clauses) of
the terms and conditions of the contract which is (or are)
relied on; and (b) they do not adequately set out the reason (or
reasons) why the claimant asserts that the defendant was in
breach of contract.
>
> AND the claimant could have complied with CPR 16.4(1)(a) had
it served separate detailed particulars of claim, as it could
have done pursuant to CPR PD 7C.5.2(2), but chose not to do so.
>
> AND upon the claim being for a very modest sum such that the
court considers it disproportionate and not in accordance with
the overriding objective to allot to this case any further share
of the court's resources by ordering further particulars of
claim and a further defence, each followed by further referrals
to the judge for case management.
>
> ORDER:
>
> 1. The claim is struck out.
>
> 2. Permission to either party to apply to set aside, vary or
stay this order by application on notice, which must be filed at
this Court not more than 5 days after service of this order,
failing which no such application may be made.
--- End Quote ---
#Post#: 86795--------------------------------------------------
Re: County Court letter from SIP parking in Manchester
DIR By: Kramer
Date: August 22, 2025, 8:33 am
---------------------------------------------------------
Thanks so much again for this - have taken your suggested
actions - my V5C is up to date so am exploring they haven't
followed protocol as suggested.
However I did get an email bounceback saying:
Thank you for your email, we have received your email and will
be back in touch with you as soon as possible.
PLEASE NOTE: any email related to Parking Charge Notices (PCN's)
will not be responded too.
Any correspondence related to a PCN can be served via
HTML https://www.sipcarparks.com/appeal-a-parking-charge-notice-pcn<br
/>or by writing to SIP Parking Limited, PO BOX 5450, Manchester,
M61 0JX.
So I am going to follow up on their website as above.
Thanks
#Post#: 86856--------------------------------------------------
Re: County Court letter from SIP parking in Manchester
DIR By: sparx
Date: August 22, 2025, 8:32 pm
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Hi Kramer,
I think that's just an automated boilerplate reply because they
want you to dob yourself in on their online form (probably
pre-selected "I was the driver" balls) if it's related to a PCN
(not court level). You've sent it to their email (that is
depicted on their website) therefore the form should be
unnecessary (although be cautious if you do send via the form,
as it may have pre-selected options that suggest you are the
driver).
To others (not OP), SIP also have a "Pre-action protocol reply"
link in their contact menu... hidden behind a form asking for
PCN number and other bits.
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