Subject: Response to your Letter Before Claim dated [insert date]
Dear Sirs,
I write as the registered keeper of the vehicle referred to in your recent Letter Before Claim.
1. Previous Letter Before Claim and my January 2025 response
You previously sent me a Letter of Claim dated 9 January 2025 demanding £170 in respect of “one or more Parking Charge Notices”. I responded in writing later that month, denying liability in full. In that response I made it clear that:
a) I am the registered keeper of the vehicle and I make no admission as to the identity of the driver.
b) There is no legal presumption that the registered keeper was the driver on any given occasion.
c) Your client has failed to establish any right to pursue me as keeper under Schedule 4 of the Protection of Freedoms Act 2012.
d) Your January 2025 Letter of Claim did not comply with the Pre-Action Protocol for Debt Claims or the Practice Direction – Pre-Action Conduct because it lacked basic particulars of the alleged claim.
In the same letter I made a clear and detailed request for the information and documents that the Protocol requires you to provide before issuing proceedings. You did not provide that information.
Instead, on 27 January 2025 you sent a “proposed payment plan” letter inflating the alleged sum to around £510 and inviting me to pay by instalments, while completely ignoring both my dispute and my Protocol-based information request.
No proceedings were issued. After about ten months of silence you have now sent a fresh Letter Before Claim demanding £680.
2. Latest Letter Before Claim – non-compliance with the Protocol
Your latest Letter Before Claim is again defective and non-compliant with the Pre-Action Protocol for Debt Claims and the Practice Direction – Pre-Action Conduct.
It simply asserts that I owe £680 for “multiple unpaid invoices” but does not, on the face of the letter, set out:
a) The individual Parking Charge Notices relied upon.
b) The dates, times and locations of each alleged contravention.
c) The alleged conduct said to give rise to liability.
d) Whether the claim is said to be for contractual damages, contractual consideration, trespass or something else.
Instead, your letter attempts to discharge your pre-action obligations by directing me to your “Customer Portal” at portal.moorsidelegal.co.uk for “full details” of the alleged claim. You then add that if you receive further instructions from your client before a claim is issued, those will be “added to the outstanding debt and updated on the portal”.
3. Refusal to use your portal
For the avoidance of doubt:
a) I refuse to use your portal.
b) I am entitled to receive a properly particularised Letter of Claim and supporting documents in writing, not to be required to register with or visit a private website controlled by you in order to find out what I am being accused of.
c) It is presumptive and out of order to assume that a consumer must use your portal as a substitute for proper written service of the information and documents required by the Protocol.
A Letter Before Claim is supposed to be a clear, stable, written summary of the claim with a fixed and up to date balance at the time it is sent. It is not acceptable to send an under-particularised letter and then say that the “real” information is on your portal, nor is it acceptable to reserve the right to keep altering the alleged balance and only reflect those changes on that portal. This approach is wholly inconsistent with both the spirit and the letter of the Protocol.
4. Liability is denied – driver and keeper positions
Liability is denied in full.
I am the registered keeper of the vehicle. I am not obliged to identify the driver and I decline to do so. There is no lawful presumption that the keeper was the driver.
On the information provided to date, your client has not demonstrated compliance with Schedule 4 of the Protection of Freedoms Act 2012. Accordingly, there can be no keeper liability. You are put to strict proof of any lawful basis by which your client contends that I am liable, whether as driver or as keeper.
5. Information and documents required
My detailed letter in January 2025 already set out what is required from you and your client in order for me to understand and respond properly to any alleged claim. You have never provided that information.
For the avoidance of doubt, you must not issue proceedings until you have complied in full with your pre-action obligations and provided, in writing, all of the information and documents previously requested, including but not limited to:
1. A clear explanation of the cause of action.
2. Confirmation of whether your client alleges liability as driver or as keeper.
3. Confirmation of whether your client is relying on Schedule 4 of the Protection of Freedoms Act 2012 and, if so, an explanation of how each statutory requirement is said to be satisfied.
4. Full details of each alleged Parking Charge Notice, including PCN number, date, time, location, alleged contravention and any alleged period of parking.
5. A copy of the alleged contract relied upon, together with the terms and conditions said to form part of it.
6. Contemporaneous photographs said to show the vehicle in breach of any contractual term.
7. Details of the landowner authority under which your client says it can issue Parking Charge Notices and bring legal proceedings in its own name, together with a copy of the contract or agreement relied upon.
8. A plan showing the location of all signage at the material time.
9. Contemporaneous photographs of all signage at the material time, showing wording, font size and position or height.
10. A full breakdown of the sums claimed, including the original PCN amounts, any alleged interest, and each additional fee or charge added, together with an explanation of the legal basis for each element, particularly any so called “debt recovery” add-ons.
Unless and until this information has been supplied in writing in a Protocol-compliant manner (and not buried on a portal), it is premature and unreasonable to issue proceedings.
6. SRA complaint
In view of your conduct to date – including:
a) The defective January 2025 Letter of Claim.
b) Your failure to engage properly with my detailed response and information request.
c) Your “proposed payment plan” letter which treated the alleged debt as admitted.
d) Your latest Letter Before Claim which again relies on a portal and an unstable claimed balance.
I have submitted a formal complaint to the Solicitors Regulation Authority about your firm’s conduct in this matter.
You are on notice that any further misuse of the pre-action process, or any attempt to issue a claim without first providing the information and documents set out above, will be relied upon as further evidence of unreasonable behaviour.
7. Future conduct
If you or your client nevertheless proceed to issue a County Court claim without first complying with the Protocol and providing the requested documents, I will:
a) Apply for an immediate stay of proceedings pending proper compliance.
b) Seek my full costs, including under CPR 27.14 for unreasonable conduct.
No admissions are made and all of my rights are reserved.
I expect your next communication to be either:
A Protocol-compliant response enclosing the information and documents requested.
or
Written confirmation that no further action will be taken and that your file is closed.
Yours faithfully,
[Keeper’s full name]
[Keeper’s postal address]
[Keeper’s email address]
[Your full name]
[Your address]
[Postcode]
[Email]
[Date]
Solicitors Regulation Authority
The Cube
199 Wharfside Street
Birmingham
B1 1RN
Dear Sir or Madam,
Formal complaint about Moorside Legal Services Limited (SRA ID 8006077)
I write to make a formal complaint about Moorside Legal Services Limited (“Moorside Legal”), SRA ID 8006077. In my view their conduct in a private parking matter shows a systemic disregard for the Pre-Action Protocol for Debt Claims (“the Protocol”), the Practice Direction – Pre-Action Conduct, and their professional obligations as solicitors. Their letters appear to be used as pressure tools rather than genuine pre-litigation steps. I ask the SRA to open a formal investigation into both my case and Moorside Legal’s standard practices in this area.
1. Parties
Firm: Moorside Legal Services Limited, trading as Moorside Legal, SRA ID 8006077, Company No. 15069347. Their correspondence to me has given the following addresses:
– January 2025: Ground Floor, Jade Building, Albion Mills, Albion Road, Greengates, BD10 9TQ
– November 2025: Unit 1.01, Hollinwood Business Centre, Albert Street, Failsworth, Oldham, OL8 3QL
Their client: Parking Control Management (UK) Limited (a private parking company).
My status: I am the registered keeper of a vehicle in respect of which their client alleges several unpaid private Parking Charge Notices. I dispute liability in full.
2. Chronology
On 9 January 2025 I received a document headed “Letter of Claim” from Moorside Legal, demanding £170 said to be due in respect of “one or more Parking Charge Notices” allegedly issued by their client. The letter was generic and under-particularised. It did not clearly state the cause of action, the specific PCN number(s), date(s), or location(s), nor did it explain whether the claim was said to be for contractual damages, contractual consideration, or trespass. It threatened that County Court proceedings would be issued if payment was not made.
Later in January 2025 I responded in writing as the registered keeper, denying liability. I made it clear that I am not obliged to identify the driver and that there is no legal presumption that the registered keeper was the driver. I also raised detailed issues about the absence of keeper liability under Schedule 4 of the Protection of Freedoms Act 2012.
Crucially, I identified that Moorside Legal’s Letter of Claim did not comply with the Protocol and the Practice Direction – Pre-Action Conduct. I therefore treated their letter as non-compliant and made a detailed request for the information and documents which the Protocol requires a creditor to supply before issuing proceedings. Among other things, I requested:
– A clear explanation of the cause of action
– Confirmation of whether I was being pursued as driver or keeper
– Confirmation of whether their client was relying on Schedule 4 of PoFA 2012
– Copies of any contract relied upon, together with the relevant signage and landowner authority
– A proper breakdown of the sum claimed and an explanation of any “debt recovery” add-on
I expressly stated that I would respond substantively within 30 days of receiving a Letter of Claim that satisfied the Protocol and that I required Moorside Legal to comply with their pre-action obligations before any claim was issued.
On 27 January 2025, instead of providing any of the requested documents or clarifying the basis of the alleged claim, Moorside Legal sent me a letter headed “Proposed payment plan” (or words to that effect) inviting me to pay around £510 by instalments, said to be for “three unpaid invoices” or similar. This letter completely ignored my dispute and my Protocol-based request for information. It simply assumed that the alleged debt was valid and sought to pressure me into a payment plan to “avoid court action”. There was still no explanation of how the overall figure was calculated, and no disclosure of any underlying documents.
After that, there was a period of around ten months where no proceedings were issued and no proper response was provided to my pre-action letter.
On 12 November 2025 I then received a new “Letter Before Claim” from Moorside Legal, this time on different headed paper and from a different address. It stated that I supposedly owed £680 for “multiple unpaid invoices” for Parking Control Management (UK) Limited. Again, the letter itself did not list the alleged PCNs (no dates, locations, or reference numbers, and no explanation of the alleged breaches). Instead, the letter asserted that “full details” of the case were available on Moorside Legal’s “Customer Portal” (portal.moorsidelegal.co.uk), and that if they received further instructions from their client “before a claim is issued, these will be added to the outstanding debt and updated on the portal”.
3. Refusal to use the “portal” and concerns about service and transparency
I wish to make it clear that I have refused, and continue to refuse, to use Moorside Legal’s portal. I am entitled to receive a properly particularised Letter of Claim and supporting documents in writing, not to have to register with and navigate a third-party website in order to find out what I am being accused of.
In my view it is presumptive and out of order for a regulated firm to assume that pointing a consumer to an online portal satisfies their obligations under the Protocol. A Letter Before Claim is supposed to contain, or be accompanied by, the key information and documents itself. It is not acceptable to send an under-particularised letter and then attempt to shift the burden onto the recipient to go fishing for details online, particularly where the portal is controlled by the creditor’s solicitors and the contents can be changed at will.
The November 2025 Letter Before Claim is especially troubling because it openly states that the alleged “outstanding debt” is not fixed and may be increased before proceedings are issued, with any such changes only reflected on the portal. In other words, the “Letter Before Claim” itself is neither final nor complete, and Moorside Legal appear to regard their portal as the true locus of the alleged claim. This undermines the purpose of the Protocol, which requires a clear, stable pre-action summary of the claim and an up-to-date statement of account at the time the Letter of Claim is sent.
For the avoidance of doubt:
– I do not consent to using Moorside Legal’s portal.
– I do not accept that a private portal is an appropriate or sufficient method of serving the information and documents required under the Protocol.
– I consider their insistence on channelling “full details” and “updates” through the portal, rather than disclosing them transparently in writing, to be presumptive, unfair, and contrary to good professional practice.
4. Why I say this breaches SRA Principles and Codes
In my view, Moorside Legal’s conduct breaches several core duties, including the obligation to uphold the rule of law and proper administration of justice, to act with integrity, and to act in a way that maintains public trust.
A firm acting properly would, upon receiving my detailed Protocol-based response in January 2025, either:
– Provide the requested documents and information and produce a compliant, particularised Letter of Claim; or
– Explain why certain documents could not be provided and narrow the issues to enable informed engagement.
Instead, Moorside Legal ignored my requests, sent a payment-plan demand as if the debt were admitted, then did nothing for ten months before issuing an even more generic Letter Before Claim for a higher sum, which again failed to particularise the alleged claim and attempted to push everything onto an online portal. This is not how a responsible firm behaves when using the court process.
Their communications are also misleading and oppressive. The second Letter Before Claim presents itself as a formal pre-court letter, while at the same time stating that the alleged debt is subject to change and that “full details” exist only behind a portal. The relentless emphasis on County Court judgments and credit damage, without providing the basic information necessary for me to understand and challenge the alleged claim, is precisely the kind of behaviour which the Protocol and the Practice Direction were designed to prevent.
In addition, Moorside Legal’s model appears to misuse the threat of litigation as a debt-collection tool. They wield their status as solicitors and references to court proceedings to exert pressure, but fail to comply with the safeguards and duties that accompany that status. In my case, they have treated the Protocol obligations as a tick-box formality while prioritising payment plans and online portals over proper written disclosure.
5. Why I believe this is systemic rather than a one-off
The November 2025 Letter Before Claim is clearly a template, not something drafted around the specifics of my case. Its reliance on a “Customer Portal”, its statement that the debt amount may be altered pre-issue, and its lack of in-letter particulars all point to a systemic process. Given the volume nature of private parking claims, I am concerned that many consumers will simply be browbeaten into paying without ever receiving a clear, written explanation of what is alleged against them.
I therefore ask the SRA not to treat this as an isolated file-handling error but to examine Moorside Legal’s systems, templates and supervision in relation to:
– The content of their Letters Before Claim
– Their use of portals in place of written disclosure
– Their treatment of Protocol-compliant responses and document requests
– The escalation of claimed sums without explanation
6. What I am asking the SRA to do
I respectfully request that the SRA:
1. Open a formal investigation into Moorside Legal’s conduct in my matter, including their failure to respond properly to my January 2025 letter, their issuing of a “Proposed payment plan” instead of a substantive reply, and their November 2025 Letter Before Claim which relies on a portal and an unstable debt figure.
2. Examine Moorside Legal’s standard practices and templates for private parking and other debt claims, particularly in relation to compliance with the Pre-Action Protocol for Debt Claims and the Practice Direction – Pre-Action Conduct.
3. Consider whether regulatory or disciplinary action is necessary to ensure that Moorside Legal’s future conduct upholds the rule of law, treats consumers fairly, and does not misuse threats of court proceedings as a substitute for proper disclosure.
I include copies of the January 2025 Letter of Claim, my January 2025 response, the “Proposed payment plan” letter of 27 January 2025, and the 12 November 2025 Letter Before Claim in support of this complaint. If you require any further information or documents I will be happy to assist.
Yours faithfully,
[Your name]
Moor Legal can be reading all this and kind of figure out who the notice was issued to.Realistically, they issue far too many of these claims to have the time or effort to waste trawling forums for the small minority of defendants who put up a good fight. But even if they do, none of the information shared here is likely to be prejudicial to your case.
Moorside Legal
PO Box 1418
Bradford
BD19GP
By email to: help@ moorsidelegal.co.uk
Ref: [PCN number]
[Date]
Dear Sirs,
Your Letter Before Claim dated [date] contains insufficient detail of the claim and fails to provide copies of evidence your client places reliance upon and thus is in complete contravention of the Pre-Action Protocol for Debt Claims.
I am the registered keeper of the vehicle. I am not obliged to identify the driver and I decline to do so. As there is no legal presumption that the keeper of a vehicle was its driver on any particular occasion, your client cannot pursue me as driver as per VCS v Edward H0KF6C9C [2023].
As you and your client are well aware, there can be no keeper liability as defined in Schedule 4 to the Protection of Freedoms Act 2012 as they have not fully complied with all the requirements of the Act. So your client cannot pursue me as keeper.
As your client cannot pursue me as driver or keeper, it would be an abuse of the court’s process for your client to issue a claim against me and I will defend any such claim vigorously and seek costs in relation to your client’s unreasonable and vexatious conduct under Part 27.14(2)(g)
As your letter lacks specificity and breaches the requirements of the Pre-Action Protocol for Debt Claims (paragraphs 3.1(a)-(d), 5.1 and 5.2) as well as the Practice Direction - Pre-Action Conduct (paragraphs 6(a) and 6(c)), you must treat this letter as a formal request for all of the documents/information that the protocol now requires your client to provide. Your client must not issue proceedings without complying with that protocol.
As solicitors you must surely be familiar with the requirements of both the Practice Direction and the Pre-Action Protocol for debt claims and your client, as a serial litigator of debt claims, should likewise be aware of them. As you (and your client) must know, the Practice Direction and Protocol bind all potential litigants, whatever the size or type of the claim. Its express purpose is to assist parties in understanding the claim and their respective positions in relation to it, to enable parties to take stock of their positions and to negotiate a settlement, or at least narrow the issues, without incurring the costs of court proceedings or using up valuable court time. It is embarrassing that a firm of Solicitors are sending a consumer a vague and un-evidenced 'Letter Before Claim' in complete ignorance of the pre-existing Practice Direction and the Pre-Action Protocol.
I confirm that, once I am in receipt of a Letter Before Claim that complies with the requirements of para 3.1 (a) of the Pre-Action Protocol, I shall then seek advice and submit a formal response within 30 days, as required by the Protocol. Thus, I require your client to comply with its obligations by sending me the following information/documents:1. An explanation of the cause of action
2. whether they are pursuing me as driver or keeper
3. whether they are relying on the provisions of Schedule 4 of POFA 2012
4. what the details of the claim are; for how long it is claimed the vehicle was parked, how the monies being claimed arose and have been calculated
5. Is the claim for a contractual breach? If so, what is the date of the agreement? The names of the parties to it and provide to me a copy of that contract.
6. If the claim is for a contractual breach, photographs showing the vehicle was parked in contravention of said contract.
7. Is the claim for trespass? If so, provide details.
8. Provide me a copy of the contract with the landowner under which they assert authority to bring the claim, as required by the IPC Code of Practice v9 Appendix 1 of the alleged contravention took place before 1st October 2024 or the BPA/IPC Private Parking Single Code of Practice after that date.
9. a plan showing where any signs were displayed
10. Photographs of the signs displayed (size of sign, size of font, height at which displayed) at the time of any alleged contravention.
11. Provide details of the original charge, and detail any interest and administrative or other charges added
12. Am I to understand that the additional £70 represents what is dressed up as a 'Debt Recovery' fee, and if so, is this nett or inclusive of VAT? If the latter, would you kindly explain why I am being asked to pay the operator’s VAT?
13. With regard to the principal alleged PCN sum: Is this damages, or will it be pleaded as consideration for parking?
I am clearly entitled to this information under paragraphs 6(a) and 6(c) of the Practice Direction. I also need it in order to comply with my own obligations under paragraph 6(b).
If your client does not provide me with this information then I put you on notice that I will be relying on the cases of Webb Resolutions Ltd v Waller Needham & Green [2012] EWHC 3529 (Ch), Daejan Investments Limited v The Park West Club Limited (Part 20) Buxton Associates [2003] EWHC 2872, Charles Church Developments Ltd v Stent Foundations Limited & Peter Dann Limited [2007] EWHC 855 in asking the court to impose sanctions on your client and to order a stay of the proceedings, pursuant to paragraphs 13, 15(b) and (c) and 16 of the Practice Direction, as referred to in paragraph 7.2 of the Protocol.
Until your client has complied with its obligations and provided this information, I am unable to respond properly to the alleged claim and to consider my position in relation to it, and it is entirely premature (and a waste of costs and court time) for your client to issue proceedings. Should your client do so, then I will seek an immediate stay pursuant to paragraph 15(b) of the Practice Direction and an order that this information is provided.
Yours faithfully
what did you recive before the letter you've posted???
and did you reply?
post everything using an external host as per...
https://www.ftla.uk/private-parking-tickets/read-this-first-private-parking-charges-forum-guide/