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UKPC - Parking charge, Harbour Exchange Square London E14

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Re: UKPC - Parking charge, Harbour Exchange Square London E14
Reply #30 on:
#31
Essentially, from
Quote
The reply should include confirmation as to whether the claim is accepted and, if it is not accepted, the reasons why, together with an explanation as to which facts and parts of the claim are disputed
You don’t need to boil the ocean at this stage, just reply simply.
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Re: UKPC - Parking charge, Harbour Exchange Square London E14
Reply #34 on:
#35
Today I had this letter. It looks different so I think it may be the one to respond to. 🤔



Fulltext:

Quote
Civil & Commercial Litigation Solicitors

Date: 03 August 2026

Our Reference: [REDACTED]

LETTER OF CLAIM

RE:
Our Client: UK Parking Control Limited
Parking Charge Ref(s): Please see overleaf
Amount Due: £170.00

We act for UK Parking Control Limited and write in respect of an unpaid parking charge(s). This is a formal Letter of Claim in accordance with the Pre-Action Protocol for Debt Claims.

Basis of Claim

The vehicle with registration number [REDACTED] ("Vehicle") was parked on private land ("Land") managed by our Client. The signs displayed on the Land set out the Terms of parking (i.e. "the Contract"). The Vehicle was parked in breach of the Terms and as such the Contract was accepted and a Parking Charge(s) was issued. You are liable as the Keeper or Driver. The details of the Parking Charge(s) can be found in the schedule at the bottom of this letter. Payment was due within 28 days of the Parking Charge(s) being issued but remains outstanding.

The amount of the debt is £170.00, which includes the Parking Charge(s) and debt recovery costs. If a claim is issued, further costs will be sought, together with accruing interest.

Next Steps

Within 30 days of the date of this letter, you should either make payment using one of the methods detailed overleaf or complete the Reply Form and financial statement. Failure to do so is likely to result in a claim being issued without further notice.

Please visit www.dcblegal.co.uk/response to complete and submit the reply form and financial statement.

You will also find an additional information sheet summarising your rights and responsibilities under the Pre-Action Protocol for Debt Claims.

Your attention is drawn to the Civil Procedure Rules 1998 and the Court's power to impose sanctions if you fail to pay or respond. Any such failure will be brought to the attention of the Court when considering costs. Any non-compliance with the Rules can increase liability for costs. The BPA Code of Practice requires us to make the customer (driver/keeper) aware of the implications of non-payment including, should the Court find against them, the risk to their credit rating.

We suggest you deal with this as a matter of urgency to avoid a claim being issued. You may wish to seek independent legal advice from a Solicitor or other free money advice organisation.

If you would like a 'dispute resolution call' with our team, or a paper copy of the information sheet, reply form or financial statement, please call our office on 0203 434 0427.

Yours sincerely,

Sarah Ensall
Head of Bulk Litigation
Last Edit: August 08, 2026, 04:19:08 pm by TwistedEdge
Re: UKPC - Parking charge, Harbour Exchange Square London E14
Reply #35 on:
#36
You need to respond ( )
Quote
the defendant responding within a reasonable time – 14 days in a straight forward case and no more than 3 months in a very complex one. The reply should include confirmation as to whether the claim is accepted and, if it is not accepted, the reasons why, together with an explanation as to which facts and parts of the claim are disputed

It won't make any difference but it's part of the paper trail you're laying in case this actually gets to court, and shows you're engaging.
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Re: UKPC - Parking charge, Harbour Exchange Square London E14
Reply #36 on:
#37
I am thinking that, if I send them something long-winded, like this, then they'll be less likely to bother with the court, because it means dredging up all the evidence I've asked for.

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Re: Letter of Claim dated 3 August 2026
Your reference: [REFERENCE]
UKPC Parking Charge Reference: [REFERENCE]

Dear Sir/Madam,

I write in response to your Letter of Claim dated 3 August 2026. I dispute the alleged debt in its entirety.

I am the registered keeper of the vehicle. The identity of the driver has not been disclosed, and no admission or inference as to the identity of the driver should be made from this correspondence.

1. Keeper liability

Liability as registered keeper remains disputed. I maintain that UK Parking Control Ltd has not established keeper liability in accordance with the strict requirements of Schedule 4 of the Protection of Freedoms Act 2012.

I acknowledge that POPLA reached a contrary conclusion. I do not accept that POPLA's decision determines my legal liability, and liability remains denied.

2. Permission at this barrier-controlled site

This was not simply an unattended car park in which a vehicle entered and remained without interaction with site personnel.

Access was controlled by an on-site security guard at a barrier. The driver spoke to the security guard, explained that they intended to remain for some time and was permitted to enter. The driver reasonably understood the person controlling access to have authority to permit entry and relied upon that permission.

UKPC subsequently produced evidence showing that the vehicle registration was not entered on its authorised vehicle list. The absence of an entry on that system does not establish that permission was not given. It establishes only that the registration was not entered into the system.

3. Disability and Equality Act 2010

The driver was a disabled person, was using a valid Blue Badge and parked in a designated disabled bay.

The circumstances therefore raise issues concerning the provision of services to disabled persons and the duty to make reasonable adjustments under the Equality Act 2010. Disability may affect matters including time management and the additional time reasonably required when using a site.

POPLA's decision stated that the operator had not been told how the driver's disability affected their ability to comply with the parking terms and treated the circumstances principally as mitigation. That decision does not determine whether UKPC complied with its statutory obligations, which remains disputed.

4. Authority and signage

I continue to dispute whether UKPC has adequately demonstrated the necessary authority to enforce the charge. The documentation disclosed during the POPLA proceedings was heavily redacted and involved a managing agent rather than establishing a clear and verifiable chain of authority from the landowner.

I also continue to dispute the adequacy of the evidence concerning the applicable signage. In particular, UKPC relied during the POPLA proceedings upon signage photographs dating from 2023 in relation to a parking event on 12 November 2025.

5. Additional £70

I dispute the additional £70 described as debt recovery costs. Please identify the precise contractual and legal basis upon which your client contends that this additional sum is recoverable from me.

6. Request for information and documents

In accordance with the Pre-Action Protocol for Debt Claims, please provide:

The contractual and legal basis for the additional £70, including the specific contractual term relied upon.
The evidence upon which your client intends to rely to establish keeper liability under Schedule 4 of the Protection of Freedoms Act 2012.

Contemporaneous evidence of the signage and terms in force at the site on 12 November 2025.

Evidence establishing UKPC's authority to enforce parking charges and bring proceedings at this location, including the relevant chain of authority where authority derives through a managing agent.

The procedures, instructions or contractual arrangements applicable on 12 November 2025 concerning the authority of security or concierge personnel controlling the barrier to admit vehicles, and the process for registering or exempting authorised vehicles.

Any records held concerning the vehicle's admission or authorisation at the site on 12 November 2025, including any relevant security, concierge, barrier-access or vehicle-registration records.

This response is intended to make my position clear and to engage constructively with the pre-action process. The alleged debt remains disputed in its entirety.

In light of the matters above, I invite your client to reconsider whether proceedings are appropriate. If your client intends to continue pursuing the claim, please provide a substantive response to the disputed issues and the information and documents requested above before commencing proceedings.

Yours faithfully,
Re: UKPC - Parking charge, Harbour Exchange Square London E14
Reply #37 on:
#38
If you send them something long-winded they will ignore you.

They will not respond.

In general, I advise against long-winded replies like this, because they will simply ignore the majority of the points you make and (maybe) respond to the minority of points they can rebut.

It won't make any difference, as I already said, but honestly I wouldn't bother. Keep it short and to the point.

DCB Legal always issues a county court claim and almost always discontinues at the last moment. You only need to search the forum to see this.

Keep the long-winded stuff for the defence to the court claim, because the court won’t ignore points it doesn’t agree with.
Last Edit: August 09, 2026, 03:55:28 pm by jfollows
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Re: UKPC - Parking charge, Harbour Exchange Square London E14
Reply #39 on:
#40
I sent a much shorter dispute response – I had this email today. Along with repeats of attachments including the original PCN etc.

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Dear [redacted]

We write in response to your correspondence received in our office.
We now respond to the same as follows.

When parking on private land, the contractual terms of the site are set out on the signs. You are entering a contract and agreeing to the terms by parking and staying on the site. Parking in breach of the terms as stipulated on the signage means that you are then breaking the terms of the contract.

The terms and conditions on the signs stated the maximum stay allowed, or otherwise a parking charge would be issued. The vehicle was recorded on the land for longer than permitted, as is demonstrated in the photographic evidence attached. The parking charge was issued correctly.

Schedule 4 (4)(1) of the Protection of Freedoms Act 2012 (“the Act”) states “The creditor has the right to recover any unpaid parking charges from the keeper of the vehicle”. For the purpose of the Act; “keeper” means the person by whom the vehicle is kept at the time the vehicle was parked, which in the case of a registered vehicle is to be presumed, unless the contrary is proved, to be the registered keeper. The DVLA confirmed that you were the Registered Keeper at the time the parking charge was issued and as no transfer of liability has been received by our client, they have the right to recover the parking charge from you as the Keeper of the vehicle.

In accordance with the British Parking Association (BPA) Code of Practice, where the Parking Charge (PC) becomes overdue and before Court proceedings have commenced, a reasonable sum may be added for the debt recovery fees. The correct recovery fees have been added and will not be removed. As such, the outstanding balance of £170.00 remains payable to prevent further action.

We refer to our communication as per our letter of claim, we confirm that despite your latest correspondence, our position remains as previously advised. As such, should our client instruct us to proceed with further legal action, we reserve the right to do so without any further reference to you. If you are at all unsure of your legal position, we recommend that you seek your own independent legal advice.

 You now have 30 days from the date of this email to make payment of £170.00. Failure to make payment may result in a Claim being issued against you without any further reference.
Payment can be made via bank transfer to our designated client account: -

    Account Name: DCB Legal Ltd Client Account
    Sort Code: 20-24-09
    Account Number: 60964441

You must quote the correct case reference (REDACTED) when making payment. If you do not, we may be unable to correctly allocate the payment. If further action is taken by us as a result of an incorrect reference being quoted, you will be liable for any further fees or costs incurred.

Alternatively, you can contact DCB Legal Ltd on 0203 838 7038 to make payment over the telephone or online at https://dcblegal.co.uk/response/pay-online/.

Kind Regards,

Not really addressing many of my original objections. Do I continue to engage or continue to ignore?
Re: UKPC - Parking charge, Harbour Exchange Square London E14
Reply #40 on:
#41
Ignore.

They sent you a Letter of Claim, you replied. Job done.

Save your energy for writing a defence to the county court claim, which should address their Particulars of Claim (on their claim form, which you haven't received yet) and specific defence points applicable to your situation.

DCB Legal have a familiar process in which they almost always discontinue before having to pay the court fee, because their clients don't want to pay the fee and, more significantly, for someone to attend court. So you follow the process, get the case allocated to a court local to you for a hearing in person, and don't miss any deadlines along the way.
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