You've submitted your defence. The intention to proceed is normal. When you competed your N180 DQ, did you notify them of any dates you will not be able to attend the call? If not, why not? I suggest you get back in touch with the mediation service and ask them to make another date when you will be available or else appoint someone else to take the call for you.
This is the advice for the mediation call:
For the mediation call, the only requirement is for you or someone to "attend" the call. It is not part of the judicial process and no judge is involved.
This is what I advise you to say when you receive the call from the mediator:
“Before I set out my position, please confirm from the claimant’s side:
• the full name of the person attending for them;
• their role/position at their legal representative’s firm; and
• whether they hold written authority to negotiate and settle today.
Please relay that back to me before we continue.”
After the mediator calls back...
If identified and authority confirmed:
“Thank you. I’m content to proceed on that basis. My settlement offer is £0, or I invite the claimant to discontinue with no order as to costs.”
If no/unclear authority:
“Please record that the claimant’s attendee has not confirmed settlement authority. My position remains that liability is denied and my offer is £0, subject to prompt approval by an authorised solicitor if they choose to discontinue.”
All you need to know is the name and the position of the person acting for the claimant and report that back to us. It will be over within minutes. Complete waste of time otherwise.
Yes, you shoul still send that email. Here is why...
That wording – “in accordance with CPR 2.3(1)” – is basically DCB Legal’s boilerplate attempt to make the sign-off look compliant.
Here’s what it refers to:
• CPR 2.3(1) is in the definitions section of the Civil Procedure Rules.
• It defines, amongst other things, what a “legal representative” means:
“Legal representative” means a barrister, solicitor, solicitor’s employee or other authorised litigator (as defined in the Legal Services Act 2007) or a person authorised under the Legal Services Act 2007 to conduct litigation.
So, when they write “Claimant’s Legal Representative as defined by CPR 2.3(1)”, they are asserting that the signatory (e.g. Sarah Ensall) falls into one of those categories.
Why it matters:
• It doesn’t prove authorisation – it’s just a self-certification.
• If the signatory isn’t an authorised person under the Legal Services Act 2007 (or exempt), then describing themselves as a “legal representative under CPR 2.3(1)” is misleading.
• This goes to the point highlighted in Mazur v Charles Russell Speechlys LLP [2025]: only authorised (or exempt) individuals can actually “conduct litigation.” Employees can assist under supervision, but cannot sign/act as the litigating representative themselves.
• Therefore, the reference to CPR 2.3(1) is an assertion of status, and you are entitled to demand proof (SRA number, exemption relied on, etc.).
In short: it’s DCB Legal trying to cloak the signature with CPR authority, but unless the person is actually authorised or exempt, the words don’t cure the defect.
If what you have received is a blank N180 DQ and not just a copy of the claimants DQ, then yes, you should complete it:
Having received your own N180 (make sure it is not simply a copy of the claimants N180), do not use the paper form. Ignore all the other forms that came with it. you can discard those. Download your own here and fill it in on your computer. You sign it by simply typing your full name in the signature box.
https://assets.publishing.service.gov.uk/media/673341e779e9143625613543/N180_1124.pdf
Here are the answers to some of the less obvious questions:
• The name of the court is "Civil National Business Centre".
• To be completed by "Your full name" and you are the "Defendant".
• C1: "YES"
• D1: "NO". Reason: "I wish to question the Claimant about their evidence at a hearing in person and to expose omissions and any misleading or incorrect evidence or assertions.
Given the Claimant is a firm who complete cut & paste parking case paperwork for a living, having this case heard solely on papers would appear to put the Claimant at an unfair advantage, especially as they would no doubt prefer the Defendant not to have the opportunity to expose the issues in the Claimants template submissions or speak as the only true witness to events in question.."
• F1: Whichever is your nearest county court. Use this to find it: https://www.find-court-tribunal.service.gov.uk/search-option
• F3: "1".
• Sign the form by simply typing your full name for the signature.
When you have completed the form, attach it to a single email addressed to both dq.cnbc@justice.gov.uk and info@dcblegal.co.uk and CC in yourself. Make sure that the claim number is in the subject field of the email.
Any document filed electronically does not have to have a "wet" signature. It only needs the persons name typed in full.
The N1SDT Claim Form has been signed by Sarah Ensall who is not authorised to conduct litigation.
Once your defence is received by the CNBC, they acknowledge receipt and inform you that they are sending a copy of it to the claimant and that you will hear back once they have received their copy. Did you not receive a letter from DCB Legal confirming that they had received a copy of your defence and that their client intends to proceed? That letter usually includes a copy of their N180DQ and is usually signed by someone with [initial]. [last name] and is usually a paralegal.
They may not have sent that yet.
Anyway, for now, you should email DCB Legal at info@dcblegal.co.uk and CC yourself with eh following:
Subject: Claim [insert court reference] – N1SDT Claim Form signed by Sarah Ensall: authority to conduct litigation, and regulatory notice
Dear Sir/Madam,
I refer to the Claim Form (N1SDT) filed/served in this matter. The document is signed by Sarah Ensall, position stated as Head of Legal, and purports to be signed on behalf of the Claimant’s solicitor.
Please confirm by return:
1. Their role, and whether they are an authorised person within the meaning of the Legal Services Act 2007 with current rights to conduct litigation (provide SRA or CILEX number and practising status). If not authorised,
2. The precise exemption relied upon under Schedule 3 of the Legal Services Act 2007 that permits this individual personally to conduct litigation and sign this document in these proceedings (if relying on a court order, provide the sealed order; if relying on an enactment, identify it precisely).
For the avoidance of doubt:
• Preparing, signing, filing, or serving [insert document name] is an act of conducting litigation, a reserved legal activity.
• Practice Direction 22 requires the signatory’s full name and capacity when signing on behalf of a party; initials only are not sufficient for verification of authorisation.
• Following Mazur v Charles Russell Speechlys LLP [2025], unqualified employees may assist but cannot themselves conduct litigation unless authorised or exempt.
Action required:
• Confirm the above within 7 days.
• If the document was not signed by an authorised (or exempt) person, re-file and serve a compliant version personally signed by an authorised individual, with their full name clearly stated.
Costs and regulatory notice:
If the document was signed by a person not authorised or exempt, or must be re-filed/served to correct the signatory’s identity/status, I, as a litigant in person, will treat this as unreasonable conduct. In line with Mazur and CPR 27.14(2)(g), I will invite the Court, in its discretion, to order the Claimant to pay the Defendant’s costs caused by your firm’s irregular conduct, and, if appropriate, to consider wasted costs against representatives.
Further, carrying on a reserved legal activity without entitlement is a criminal offence under the Legal Services Act 2007. If any unauthorised conduct of litigation has occurred, I will report the matter to the Solicitors Regulation Authority without further notice and reserve the right to place this correspondence before the Court.
Yours faithfully,
[Full Name]
[Postal Address]
[Email]
You misunderstand slightly. What you have received is a copy of the Notice of Proposed Allocation. The Claimants solicitor received the same notice and it is they who received a copy of your defence. The version sent to you should have had that bit crossed out.
Before we continue, was the N1SDT Claim Form you received signed by a Sarah Ensall? Also, you should have had a letter from DCB Legal after you submitted your defence that said their client intended to proceed and would normally have included a copy of their N180 Directions Questionnaire (DQ). If so, what is the name of the person who signed it and in what capacity (paralegal?)
If the notice you just received includes a blank N180 DQ, you DO NOT fill anything out and you can discard all the forms that ask about persona finance etc. Just follow this advice:
Having received your own N180 (make sure it is not simply a copy of the claimants N180), do not use the paper form. Ignore all the other forms that came with it. you can discard those. Download your own here and fill it in on your computer. You sign it by simply typing your full name in the signature box.
https://assets.publishing.service.gov.uk/media/673341e779e9143625613543/N180_1124.pdf
Here are the answers to some of the less obvious questions:
• The name of the court is "Civil National Business Centre".
• To be completed by "Your full name" and you are the "Defendant".
• C1: "YES"
• D1: "NO". Reason: "I wish to question the Claimant about their evidence at a hearing in person and to expose omissions and any misleading or incorrect evidence or assertions.
Given the Claimant is a firm who complete cut & paste parking case paperwork for a living, having this case heard solely on papers would appear to put the Claimant at an unfair advantage, especially as they would no doubt prefer the Defendant not to have the opportunity to expose the issues in the Claimants template submissions or speak as the only true witness to events in question.."
• F1: Whichever is your nearest county court. Use this to find it: https://www.find-court-tribunal.service.gov.uk/search-option
• F3: "1".
• Sign the form by simply typing your full name for the signature.
When you have completed the form, attach it to a single email addressed to both dq.cnbc@justice.gov.uk and info@dcblegal.co.uk and CC in yourself. Make sure that the claim number is in the subject field of the email.
However, please answer the questions about who signed the claim form with the PoC and their copy of the N180DQ.
With an issue date of 3rd July, you have until 4pm on Tuesday 22nd July to submit your defence. If you submit an Acknowledgement of Service (AoS) before then, you would then have until 4pm on Tuesday 5th August to submit your defence.
If you want to submit an AoS then follow the instructions in this linked PDF:
https://www.dropbox.com/s/xvqu3bask5m0zir/money-claim-online-How-to-Acknowledge.pdf?dl=0
Otherwise, here is the defence and link to the draft order that goes with it. You only need to edit your name and the claim number. You sign the defence by typing your full name for the signature and date it. There is nothing to edit in the draft order.
When you're ready you combine both documents as a single PDF attachment and send as an attachment in an email to claimresponses.cnbc@justice.gov.uk and CC in yourself. The claim number must be in the email subject field and in the body of the email just put: "Please find attached the defence and draft order in the matter of UK Parking Control Ltd v [your full name] Claim no.: [claim number]."
IN THE COUNTY COURT
Claim No: [Claim Number]
BETWEEN:
UK Parking Control Ltd
Claimant
- and -
[Defendant's Full Name]
Defendant
DEFENCE
1. The Defendant denies the claim in its entirety. The Defendant asserts that there is no liability to the Claimant and that no debt is owed. The claim is without merit and does not adequately disclose any comprehensible cause of action.
2. There is a lack of precise detail in the Particulars of Claim (PoC) in respect of the factual and legal allegations made against the Defendant such that the PoC do not comply with CPR 16.4.
3. The Defendant is unable to plead properly to the PoC because:
(a) The contract referred to is not detailed or attached to the PoC in accordance with CPR PD 16.7.3(1);
(b) The PoC do not state the exact wording of the clause (or clauses) of the terms and conditions of the contract (or contracts) which is/are relied on;
(c) The PoC do not adequately set out the reason (or reasons) why the claimant asserts the defendant has breached the contract (or contracts)
(d) The PoC do not state with sufficient particularity exactly where the breach occurred, the exact time when the breach occurred and how long it is alleged that the vehicle was parked before the parking charge was allegedly incurred;
(e) The PoC do not state precisely how the sum claimed is calculated, including the basis for any statutory interest, damages, or other charges;
(f) The PoC do not state what proportion of the claim is the parking charge and what proportion is damages;
(g) The PoC do not provide clarity on whether the Defendant is sued as the driver or the keeper of the vehicle, as the claimant cannot plead alternative causes of action without specificity.
4. The Defendant attaches to this defence a copy of a draft order approved by a district judge at another court. The court struck out the claim of its own initiative after determining that the Particulars of Claim failed to comply with CPR 16.4. The judge noted that the claimant had failed to:
(i) Set out the exact wording of the clause (or clauses) of the terms and conditions relied upon;
(ii) Adequately explain the reasons why the defendant was allegedly in breach of contract;
(iii) Provide separate, detailed Particulars of Claim as permitted under CPR PD 7C.5.2(2).
(iv) The court further observed that, given the modest sum claimed, requiring further case management steps would be disproportionate and contrary to the overriding objective. Accordingly, the judge struck out the claim outright rather than permitting an amendment.
5. The Defendant submits that the same reasoning applies in this case and invites the court to adopt a similar approach by striking out the claim for the Claimant’s failure to comply with CPR 16.4.
Statement of truth
I believe that the facts stated in this Defence are true. I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth.
Signed:
Date:
Draft Order for the defence (https://www.dropbox.com/scl/fi/tcewefk7daozuje25chkl/Strikeout-order-v2.pdf?rlkey=wxnymo8mwcma2jj8xihjm7pdx&st=nbtf0cn6&dl=0)
Send the following two complaints, to the BPA and the DVLA and include. copy of the complaint you sent to UKPC. Send them by email and also CC in yourself.
BPA formal complaint to aos@britishparking.co.uk:
Subject: Formal Complaint Against UK Parking Control Ltd (UKPC) – Breach of PPSCoP & KADOE
Dear BPA Compliance Team,
I wish to formally raise a complaint against UK Parking Control Ltd (UKPC), a member of the British Parking Association (BPA), for multiple breaches of the BPA/IPC Private Parking Single Code of Practice (PPSCoP) and non-compliance with their Keeper at Date of Event (KADOE) contract with the DVLA.
On [date], I submitted a formal complaint to UKPC regarding serious procedural breaches in the handling of Parking Charge Notice [PCN reference number]. This complaint was sent via email to complaints@ukparkingcontrol.com.
Despite the BPA's expectations that its members must respond to formal complaints within 14 days, UKPC has failed to do so. Instead, I have now received a second debt recovery letter from ZZPS, demonstrating that UKPC has continued enforcement despite being made aware of their breaches.
The specific breaches are as follows:
1. Breach of the Private Parking Single Code of Practice (PPSCoP)
(a) Premature Enforcement in Violation of Section 10.1
UKPC issued a Notice to Keeper (NtK) on 10th January 2025, which was "given" on 14th January 2025 (two working days later).
The 28-day statutory response period expired on 11th February 2025, but UKPC escalated the matter to debt recovery on 7th February 2025, four days early.
PPSCoP Section 10.1 states that a parking charge is only overdue after 28 days, yet UKPC disregarded this provision.
(b) Failure to Acknowledge and Respond to a Formal Complaint in Violation of Section 11
PPSCoP Section 11 requires operators to respond to formal complaints within 14 days. UKPC has failed to meet this requirement. BPA members are required to engage with complaints meaningfully, yet UKPC has ignored mine and instead escalated the matter to a debt collector.
2. Breach of the Keeper at Date of Event (KADOE) Contract with the DVLA
UKPC’s premature debt escalation means they are unlawfully using DVLA Keeper data to pursue enforcement outside of PoFA-compliant procedures. The KADOE contract requires strict adherence to all applicable legislation and BPA codes of practice. UKPC’s failure to follow PoFA and the PPSCoP invalidates their use of my Keeper data.
Requested Actions from the BPA
I request that the BPA:
1. Investigates UKPC for continued breaches of the PPSCoP, particularly premature enforcement and failure to handle complaints properly.
2. Requires UKPC to cancel the PCN on the basis of procedural non-compliance.
3. Issues a sanction against UKPC for failing to meet BPA’s expected standards.
4. Confirms whether UKPC has been issued any prior sanctions for similar complaints.
Please confirm receipt of this complaint and provide details on how the BPA intends to proceed.
Yours faithfully,
[Your Full Name]
[Your Address]
[Your Contact Information]
Send the following to the DVLA T datasharing@dvla.gov.uk:
Subject: Formal Complaint Against UK Parking Control Ltd (UKPC) – Misuse of Keeper Data
Dear DVLA Data Sharing Team,
I am writing to formally raise a complaint against UK Parking Control Ltd (UKPC) regarding their continued breach of their Keeper at Date of Event (KADOE) contract and misuse of my personal data obtained from the DVLA.
I submitted a formal complaint to UKPC on [date] (copy attached), outlining multiple procedural breaches concerning Parking Charge Notice [PCN reference number]. Despite BPA requirements to respond within 14 days, UKPC has completely ignored my complaint and instead escalated the matter to a debt collection agency (ZZPS).
This is a clear misuse of my personal data, as UKPC has violated their BPA membership obligations and the statutory framework under which they obtained my Keeper details.
Breach of KADOE Contract with the DVLA
The KADOE contract requires operators to comply with all relevant legislation and the BPA Code of Practice when using DVLA Keeper data.
UKPC unlawfully escalated the charge to debt recovery before the statutory 28-day response period expired, which is a direct breach of PoFA, the PPSCoP, and the KADOE contract.
UKPC has refused to respond to a legitimate complaint, which further highlights their disregard for compliance obligations.
Requested Actions from the DVLA
I request that the DVLA:
1. Investigates UKPC’s misuse of Keeper data and their breach of the KADOE contract.
2. Considers suspending or revoking UKPC’s access to DVLA data due to repeated procedural breaches.
3. Requires UKPC to confirm that no further processing of my data will occur and that any debt collection activity ceases immediately.
Please confirm receipt of this complaint and provide details on how the DVLA intends to proceed.
Yours faithfully,
[Your Full Name]
[Your Address]
[Your Contact Information]
So, yes, UKPC has breached both PoFA and the PPSCoP. As it is too late to appeal now, you should send the following formal complaint to UKPC. Send it by email to complaints@ukparkingcontrol.com and also CC in yourself:
Compliance Team
UK Parking Control Ltd (UKPC)
Eastcastle House
27/28 Eastcastle St
London
W1W 8DH
By email to: complaints@ukparkingcontrol.com
[Date]
Subject: Formal Complaint Regarding Procedural Breaches – Parking Charge Notice [PCN Reference Number]
Dear Sir/Madam,
I am writing to formally lodge a complaint regarding significant procedural breaches by UK Parking Control Ltd (UKPC) in relation to Parking Charge Notice [PCN Reference Number]. This complaint is submitted in accordance with Section 11 of the Private Parking Single Code of Practice (PPSCoP) and must be treated as such. It is not an appeal.
1. Breach of the Protection of Freedoms Act 2012 (PoFA)
UKPC has failed to comply with the statutory framework set out in the Protection of Freedoms Act 2012 (PoFA), specifically:
(a) Failure to Allow the Statutory 28-Day Response Period (PoFA Paragraph 9(2)(f))
- The Notice to Keeper (NtK) was dated Friday, 10th January 2025 and is deemed "given" on Tuesday, 14th January 2025 (two working days after posting).
- Under PoFA, the Keeper must be allowed a full 28 days from the date the NtK is given before any enforcement action is initiated.
- The legally required 28-day period expired on 11th February 2025. However, UKPC prematurely escalated the matter by issuing a debt recovery notice on 7th February 2025, four days before the statutory period had lapsed.
(b) Unlawful Debt Recovery Action Before Statutory Deadline (PoFA Paragraph 11(1))
- By initiating debt recovery proceedings before the 28-day statutory response period expired, UKPC has unlawfully pursued enforcement outside the prescribed timeframe.
- As a result, UKPC has invalidated any reliance on PoFA to hold the Keeper liable.
2. Breach of the Private Parking Single Code of Practice (PPSCoP)
In addition to breaching PoFA, UKPC has failed to adhere to the regulatory framework outlined in the PPSCoP, specifically:
(a) Breach of PPSCoP Section 10.1 – Premature Enforcement
- Section 10.1 of the PPSCoP clearly states that a parking charge is considered "overdue after the expiry of 28 days where payment is required."
- UKPC's escalation to debt recovery on 7th February 2025 is a clear breach of this provision.
- Furthermore, UKPC failed to specify when the 28-day period actually begins, as required by Section 8.1.2(e), which states: "...that if the recipient appeals within 28 days of receiving the parking charge...".
- This omission creates ambiguity regarding the Keeper's deadline to respond and adds to the procedural non-compliance.
(b) Breach of PPSCoP Section 8.1.2(e) Note 2 – Proof of Posting
- The burden is on UKPC to prove actual posting of the NtK, not merely its issuance.
- I require documentary proof of posting, including evidence of dispatch through Royal Mail, rather than a system-generated "issue date."
- In the absence of such proof, the presumed "given" date may be contested, further undermining UKPC’s procedural compliance.
(c) Breach of PPSCoP Section 1.1(d) – Invalidating PoFA Compliance
- By commencing enforcement prematurely, UKPC has forfeited the ability to rely on PoFA to establish Keeper Liability.
- UKPC must confirm that it will no longer pursue the Keeper under PoFA and must cancel the PCN immediately as a direct consequence of these procedural failings.
3. Breach of KADOE Contract with the DVLA
UKPC’s premature debt escalation constitutes a material breach of the Keeper at Date of Event (KADOE) Contract with the DVLA, which mandates full compliance with relevant laws and codes of practice when accessing Keeper details.
Failure to rectify this breach will result in a formal complaint to the DVLA, requesting an investigation into UKPC’s misuse of Keeper data.
Required Actions and Next Steps
In light of these multiple breaches, UKPC is required to:
1. Confirm in writing that UKPC acknowledges these breaches and has forfeited its ability to hold the Keeper liable under PoFA.
2. Confirm that the PCN has been cancelled as a result of these procedural failures.
3. Provide evidence of actual posting of the NtK, including Royal Mail proof of dispatch.
4. Confirm that no further enforcement action, including debt recovery, will be taken.
Failure to respond appropriately within 14 days will result in immediate escalation to the British Parking Association (BPA) and the DVLA for regulatory intervention.
Please consider this matter carefully and ensure that compliance failures of this nature do not recur.
Yours faithfully,
[Your Name]
[Your Contact Details]