Did you send the formal complaints I advised you to send earlier? If so, have you had any responses to those?
Respond to the Letter of Claim (LoC) by email to info@dcblegal.co.uk and CC in yourself with the following:
Subject: Response to Letter of Claim, your ref: [reference no]
Dear Sirs,
Your Letter Before Claim, dated 30 May 2025, 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.
Because 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 of 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 BPA/IPC Private Parking Single Code of Practice (PPSCoP).
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,
[Your name]
The parking charge was issued because an expired disabled badge was displayed by mistake, but this doesn’t mean the driver wasn’t entitled to use the disabled bay. The driver or an occupant is disabled, has an in-date badge, and simply displayed the wrong one by error.
Under the Equality Act 2010, people with disabilities are entitled to reasonable adjustments, and parking operators must not penalise someone for a genuine mistake when it’s clear they qualify for using the space. The purpose of disabled bays is accessibility, and that need was still valid in this case.
UKPC’s rejection of the appeal isn’t just a failure to consider their legal obligations—it’s a blatant breach of the law. By pursuing this charge, they are discriminating against a disabled person with protected characteristics.
Send the following as a formal complaint to UKPC and include a copy of the valid blue badge but make sure you redact any personal information on it. The letter and the copy of the BB should be as PDF files attached to an email which is sent to: complaints@ukparkingcontrol.com and also CC in yourself.
UK Parking Control Ltd
Eastcastle House
27/28 Eastcastle St
London
W1W 8DH
By email: complaints@ukparkingcontrol.com
Date [date]
Subject: Formal Complaint and Appeal Regarding Parking Charge Notice [PCN Reference Number]
Dear UKPC,
I am writing as the registered keeper of the vehicle in question to formally lodge a complaint regarding the Parking Charge Notice issued on 14th December 2024 for allegedly “parking in a disabled person's space displaying an expired disabled person's badge.” A copy of a valid Blue Badge is enclosed as proof of eligibility to use the disabled bay in question.
To clarify for the benefit of your operative—who evidently struggles to grasp this fundamental point—a person’s disability does not magically expire when their Blue Badge does. If this simple concept is too difficult for your staff to comprehend, then they are entirely unfit to work in any role requiring judgment, let alone one involving the enforcement of parking terms that intersect with disability rights. This is a blatant case of discrimination against a disabled individual, as defined under the Equality Act 2010.
The Equality Act mandates reasonable adjustments for disabled people, yet you are penalising a genuine mistake that has no bearing on the eligibility of the vehicle to use a disabled bay. This is not only grossly unfair but also an illegal act of discrimination. The actions of your company—rejecting the initial appeal and persisting in pursuing this charge—demonstrate a total disregard for the law and basic decency.
Additionally, this complaint should also be treated as an appeal in line with the BPA/IPC Private Parking SingleE Code of Practice (PPSCoP), which states that all complaints relating to a parking charge must be treated as appeals, regardless of whether a prior appeal has been submitted. Your rejection of the initial appeal does not exempt you from addressing this matter properly.
The purpose of disabled bays is to provide accessibility to those who need them, not to punish disabled individuals for clerical errors or oversights. The driver or occupant of the vehicle was eligible to use the bay, and your attempt to penalise this usage is both unlawful and unconscionable.
I demand the immediate cancellation of this Parking Charge Notice and written confirmation that no further action will be taken. A copy of the valid Blue Badge is enclosed to further support this complaint. If you fail to comply, I will escalate this matter to the British Parking Association (BPA) for a formal investigation into your breaches of the Equality Act and the PPSCoP. Furthermore, I reserve the right to pursue legal action for damages arising from this act of discrimination.
You have 14 days to provide a written response confirming that the PCN has been cancelled. I suggest that this time is used to review your policies, re-educate your staff on equality law, and reflect on the inadequacy of your current processes.
Yours sincerely,
[Registered Keeper's Name]
You should also send the following complaint to the landowner, British Land Company PlC and copy in Ryan McDonnell, the CEO of Lidl UK.
British Land Company Plc
York House
45 Seymour Street
London
W1H 7LX
By email: info@britishland.com
CC: Ryan McDonnell@lidl.co.uk
[Date]
Subject: Formal Complaint Regarding Parking Charge at [Lidl Solartron Retail Park]
Dear British Land Company Plc,
I am writing to formally complain about the conduct of your parking operator, UKPC, and the handling of a Parking Charge Notice (PCN) issued at the Lidl store on your property on 14th December 2024. As the landowner, you are jointly and severally liable for the actions of your agents, and this incident has caused significant distress and inconvenience. Should this PCN escalate, you will be included in any future litigation.
The alleged contravention involved “parking in a disabled person's space displaying an expired disabled person's badge.” The vehicle was parked in a disabled bay by a driver or occupant who is disabled and holds a valid, in-date Blue Badge. Unfortunately, an expired badge was displayed in error. Despite this, the driver or occupant’s eligibility to use the bay is indisputable, and penalising a disabled individual for such a minor administrative mistake is not only unreasonable but discriminatory.
UKPC’s rejection of the initial appeal demonstrates a complete lack of understanding of their obligations under the Equality Act 2010, which requires reasonable adjustments for disabled individuals. Their actions constitute unlawful discrimination, and as the landowner, you bear ultimate responsibility for the actions of your agents.
The purpose of disabled bays is to provide accessibility to those who need them, not to punish genuine users for minor oversights. This heavy-handed approach tarnishes the reputation of businesses operating on your property and alienates customers who rely on these facilities. I am appalled that British Land Company Plc would allow such an inflexible and discriminatory parking enforcement policy to persist on your premises.
I demand the following actions:
• Immediate intervention to ensure that this Parking Charge Notice is cancelled.
• A review of your relationship with UKPC and the manner in which parking enforcement is conducted on your sites.
• Written confirmation of what steps British Land Company Plc will take to ensure that disabled customers are treated with the dignity and respect they deserve.
If this matter is not resolved promptly, I will escalate my complaint and reserve the right to pursue legal action for damages arising from this discriminatory incident.
I trust British Land Company Plc will act swiftly and appropriately to address this serious matter.
Yours sincerely
[Your Name]
[Contact Information]