Parking Fine CCJ Set Aside Application Letter

[YOUR NAME]
[YOUR ADDRESS]
[YOUR CITY]
[YOUR POSTCODE]

[DATE]

[COUNTY COURT NAME]
[COURT ADDRESS]

Claim Number: [CLAIM NUMBER]
Claimant: [PARKING OPERATOR OR DEBT COLLECTOR NAME]
Defendant: [YOUR NAME]

Dear Sir or Madam,

Application to Set Aside Default Judgment Under CPR Part 13.3

I am applying to set aside the default judgment entered in this claim on [DATE JUDGMENT ENTERED, IF KNOWN]. I was not aware of the claim until [DATE YOU BECAME AWARE] and have not had the opportunity to file a defence. I respectfully request that the judgment be set aside under CPR Part 13.3 for the following reasons.

1. I Had No Knowledge of the Claim

I did not receive the Claim Form or any court documents relating to this matter. [EXPLAIN WHY: e.g. the documents were sent to a previous address; I had moved and updated my address with the DVLA but the claimant used an outdated address; the documents may have been lost in the post.] As a result, I was unable to file a defence or acknowledgment of service within the required timeframe and the judgment was entered in my absence.

2. I Have a Real Prospect of Successfully Defending This Claim

I have a genuine defence to this parking charge on the following grounds:

(a) POFA 2012 Non-Compliance: The claimant is required to serve a compliant Notice to Keeper within 14 days of the alleged contravention under Schedule 4 of the Protection of Freedoms Act 2012. I do not believe this requirement was met. Without a valid NtK, keeper liability does not transfer and the claimant cannot pursue the registered keeper.

(b) Signage and Contractual Issues: The signage at the car park was inadequate and did not meet the requirements of the [BPA / IPC] Code of Practice. [ADD SPECIFIC DETAILS IF KNOWN.]

(c) ANPR Evidence: The ANPR evidence relied upon by the claimant has not been disclosed to me. I challenge the accuracy of the recorded entry and exit times and the clarity of the images.

[ADD ANY ADDITIONAL GROUNDS SPECIFIC TO YOUR CASE.]

3. I Acted Promptly

I became aware of the judgment on [DATE] and am making this application promptly. I have not delayed unreasonably.

4. Statement of Case

If the judgment is set aside, I intend to file a defence raising the grounds outlined above. I am prepared to comply with any directions the court may give regarding the timetable for filing my defence and any supporting evidence.

Orders Sought

I respectfully request:
(a) That the default judgment dated [DATE] be set aside under CPR Part 13.3.
(b) That I be given 14 days from the date of the order to file and serve my defence.
(c) That the claimant pay the costs of this application, as the judgment was entered without my knowledge.

I enclose:
- The completed N244 Application Notice with the applicable court fee.
- A draft witness statement in support of this application.
[LIST ANY OTHER ENCLOSED DOCUMENTS.]

Yours faithfully,

[YOUR NAME]