Pcn

[des8]

Lack of planning permission does not invalidate the PCN, although it is required by PoFA2012 (sec12) to transfer of liability for unpaid charges to the keeper.

Relying on wrong signs might be a stronger point, but that will depend on the variation of the wording.

If " N180 must be filed and served by Monday, 15 September 2025 (deadline 19 September...." seems there are two deadlines ?????

Where in Section G of N180 form are you going to include reference to enforcement notices?
The form is not for you to include legal arguments, so be careful.

[winston00]

hey DES8 once again thank you for your input

Note – Defendant’s N180 (Directions Questionnaire)

Attached is a redacted copy of the Defendant’s N180 (to be posted to the court with proof of posting).

• Deadline: Court requires it by 19 Sept 2025. We are sending it early so there is no risk of delay.
• Section D1: We included the line:
  “There are factual disputes which require oral evidence: signage legality, absence of advertisement consent, and disputed contractual terms.”
• Section F: Bournemouth (Defendant’s home court) is requested as the hearing centre, with 2 witnesses (Defendant + Lay Rep).
• Section G: No free-text on this version of the form, so nothing added there.

The hard copy will be sent to the Civil National Business Centre by post, with a copy served on DCB Legal.

Any feedback before I post would be appreciated.

[des8]

hey DES8 once again thank you for your input

Note – Defendant’s N180 (Directions Questionnaire)

Attached is a redacted copy of the Defendant’s N180 (to be posted to the court with proof of posting).

• Deadline: Court requires it by 19 Sept 2025. We are sending it early so there is no risk of delay.
• Section D1: We included the line:
  “There are factual disputes which require oral evidence: signage legality, absence of advertisement consent, and disputed contractual terms.”
• Section F: Bournemouth (Defendant’s home court) is requested as the hearing centre, with 2 witnesses (Defendant + Lay Rep).
• Section G: No free-text on this version of the form, so nothing added there.

The hard copy will be sent to the Civil National Business Centre by post, with a copy served on DCB Legal.

Any feedback before I post would be appreciated.

OK except your lay rep is not a witness, but worth advising court in advance of his/her attendance.

[winston00]

Thanks once again for your insights and assistance. You’re absolutely right — the lay rep shouldn’t be listed as a witness. I’ve amended the N180 accordingly so it now shows only the Defendant as a witness.

I’ll also be notifying the court separately that I will attend as lay representative under CPR 27.7 (email drafted, and I’ll include the same note in hard copy with the N180).

Your guidance has kept this on track — much appreciated.


To: ccbc@justice.gov.uk
Subject: Claim No. Mxxxxxxx – Notice of Lay Representative Attendance

Dear Sir/Madam,

Re: Britannia Parking Group Ltd v xxxx xxxxxxx
Claim No: Mxxxxxx

I write to notify the Court that the Defendant intends to be represented at the hearing by a Lay Representative under CPR 27.7.

The Lay Representative will not be giving evidence and is not listed as a witness. The Defendant herself will attend and give oral evidence.

This notice is provided in advance in order to comply with the requirements of CPR 27.7 and the Lay Representatives (Rights of Audience) Order 1999.

Kind regards,

[winston00]

Evidence pack from DCB Legal
Attached are the signage photos DCB sent as part of their “evidence pack.”
– Timestamped 27 Sept 2021, not contemporaneous with the alleged contravention (15 Dec 2024).
– Wording is the standard Britannia template, no reference to planning/advert consent.
– No approval documents or Condition 5 discharge included.
Sharing here for review — comments welcome.

[winston00]

Defendant’s Appeal (Redacted)
This is the online appeal submitted by xxx on 30 Dec 2024.
– Confirms ticket was purchased (£2.70) after phone signal issues.
– Explains delay was due to app/network buffering.
– Attached ticket evidence was provided.

Sharing redacted version here so you can see exactly what Britannia received.

[des8]

What did the signs state at the time of the event?

[winston00]

Reply to DES8 – Site Visit (Exeter Road Car Park)

Following your question about what the signs stated at the time of the event: unfortunately, I don’t have photographs from December 2024, but I visited the site on 30 September 2025 and took a full set of current photos.

These show the entrance layout, tariff boards, and general condition/visibility of the signage as it stands now. They can be compared with the dated Britannia photos (27 Sept 2021) that DCB rely on.

It’s worth noting that the planning record confirms the signage wasn’t formally approved until 24 January 2025 (Condition 5 discharge under 7-2023-643-Y), so these 2025 images likely represent the first lawfully approved version.

Uploading them here for reference and feedback — any observations on positioning, wording, or compliance are welcome.

[des8]

Latest photo seems to show signage identical,( but images not completely legible)

Lack of planning for signs will not necessarily invalidate PCN

[winston00]

Update for DES8 – General Form of Judgment or Order (Received 21 Oct 2025)

Morning DES8,

We received the General Form of Judgment or Order dated 16 October 2025, delivered on 21 October 2025. It gives the Defendant seven days from service to file the N180 or risk the defence being struck out.

For context, we actually posted the N180 in mid-September, ahead of the original deadline. I sent it by standard post (not recorded), so it appears it may not have been logged at the Civil National Business Centre.

I’m treating this as an opportunity to re-file and reassess rather than a setback. We’ll re-send the N180 immediately (both by email and post) to stay well within the new deadline of 28 October 2025, and take the moment to review our overall position before allocation.

Appreciate any thoughts on whether you’d treat this simply as a re-submission exercise or use it to refine direction before the case moves forward.

Kind regards,
Andrew

[des8]

Don't change anything in case the original forms turn up