-
https://ibb.co/TMjm605H
-
Well done for persevering. Please post a picture of the N279 NoD with the name and position of the signatory. We need this to reference to all the other almost 750 NoDs already on file and that is just a scratch on the tip of the iceberg.
It can all be used as evidence in future that DCB Legal never have any intention of proceeding to trial and are simply abusing the process.
-
I’m happy to report that I have received the N279 today, just as you predicted. I really thought they’d take it to court with it being a telephone hearing. Thank you so much for all your help with this, It’s such a relief that it’s over with.
-
Thank you for this, much appreciated. Hopefully it won’t be needed. I will keep you posted.
-
So, remind me on the 16th December, if they have not yet discontinued or submitted their WS, I will give you something you can submit. It will be something along these lines:
1. I am the Defendant in this claim and the registered keeper of the vehicle with registration number [VRM]. I make this witness statement from my own knowledge and belief in support of my defence to the claim brought by G24 Ltd (“the Claimant”).
2. I deny that any sum is owed to the Claimant. No contract was agreed between the driver and the Claimant at the material time, and in any event the Particulars of Claim (“PoC”) are so sparse and lacking in detail that they fail to comply with CPR 16.4. The claim is defective and should be struck out.
3. The claim arises from a Parking Charge Notice (“PCN”) issued by the Claimant in respect of a visit to the car park serving Sports Direct at [location] on [date in April 2020] during the first Covid-19 lockdown. A copy of the original PCN is at Exhibit A1.
4. At that time, the Sports Direct store itself was closed due to lockdown, but the car park was left open and accessible. No signs were erected to indicate that the car park was closed or that no parking was permitted.
5. I was not the only insured and potential driver of the vehicle at the time. The alleged event took place more than five years ago. I am unable, with any certainty, to say who was driving on that specific date, and in any event I am under no obligation to identify the driver. My defence is therefore advanced on the basis that I am the registered keeper only.
6. The Claimant’s PoC are extremely brief and fail to set out a clear cause of action. They do not state the specific contractual term or terms said to have been breached, whether the Claimant’s case is that the driver breached terms or that a sum is owed as consideration for parking, the precise conduct alleged, or any contractual or statutory basis for the additional sums claimed beyond the original PCN amount.
7. As a litigant in person, I have been left guessing as to the legal and factual basis of the claim. The lack of particularity has made it difficult to understand and respond to the case against me, which is precisely what CPR 16.4 is intended to prevent.
8. My defence invited the Court to strike out the claim on the basis that the PoC fail to comply with CPR 16.4 and do not disclose a properly pleaded cause of action. I rely on that position and ask the Court to adopt a similar approach to that taken by other judges who have struck out near-identical parking claims for the same reason.
9. Even leaving the defective PoC to one side, the basic factual position on signage is clear and supported by contemporaneous photographs taken in April 2020.
10. The car park has at least two vehicular entrances. The entry image used on the PCN (Exhibit A1) shows that the vehicle entered via the [describe entrance]. At the material time, there was no G24 entrance sign at this entrance setting out any terms and conditions or basis upon which parking was offered or restricted.
11. Exhibit A2 is a photograph I took in April 2020 of the exact entrance shown on the PCN entry image. It demonstrates that there was no signage at that entrance informing drivers that the car park was managed by G24, that any parking charge applied, or that there were conditions of parking.
12. In the absence of any sign at the point of entry, no contractual offer from the Claimant could have been communicated to a driver entering the car park by that route. A driver cannot be bound by terms which were not brought to their attention at or before the point of alleged acceptance.
13. The Claimant has subsequently asserted, in correspondence, that the signage at the site stated that the permitted parking time was “0 minutes”. That assertion is untrue and is contradicted by my contemporaneous photographs of the signage that actually existed in 2020.
14. Within the car park there were several different signs which were inconsistent with each other as to the maximum permitted parking time.
15. Exhibit A3 is a photograph of one of the internal signs, taken in April 2020. It states that the maximum stay is 60 minutes.
16. Exhibit A4 is a photograph of another internal sign within the same car park, taken at the same time. It states that the maximum stay is 120 minutes.
17. These two signs were in the same car park, both purporting to set out the contractual terms. One sets a 60-minute maximum stay, the other 120 minutes. This is confusing, contradictory, and incapable of forming a clear and certain contract.
18. None of the signs in 2020 stated that the permitted parking time was “0 minutes” or that parking was prohibited entirely because the store was closed. The Claimant’s later suggestion that the allowed time was 0 minutes is inconsistent with the photographic evidence of their own signage.
19. Exhibit A5 is a photograph of the separate sign located at the other car park entrance (not used by the vehicle). That sign merely indicated that ANPR was in operation and that terms and conditions could be viewed inside the car park. It did not itself set out any parking terms or charges and did not say that parking time was 0 minutes.
20. Taking the signage as a whole, there was no entrance sign at the entrance actually used, the other entrance sign was only an ANPR warning and not a contractual offer, and the internal signs contradicted each other and did not state 0 minutes. In these circumstances, it is impossible to identify any clear and unambiguous set of terms that could found a contract between the Claimant and the driver.
21. The alleged parking event occurred during the initial Covid-19 lockdown in April 2020. The Sports Direct store was shut to customers. Nevertheless, the Claimant and/or the landowner chose to leave the car park open and did not erect any special signage to indicate that parking was prohibited or that “0 minutes” were allowed due to the store closure.
22. A reasonable driver entering an open retail car park with no entrance terms and contradictory internal signs would not understand that they were at immediate risk of a punitive parking charge simply for being on site.
23. The original PCN in April 2020 was sent to my previous address. I had moved in [March 2020] and had notified the DVLA of my change of address, but it appears there may have been delay in updating their records due to the national disruption at that time.
24. After the original PCN there was a long period of silence, followed by debt recovery letters beginning around December 2024 and then the Letter of Claim in March 2025. I responded to the Letter of Claim as the registered keeper, disputed the debt, and confirmed my correct current address.
25. The Claimant has therefore always had access to my correct address, yet waited nearly six years to issue a court claim in respect of a minor alleged parking matter arising from unclear signage during lockdown.
26. The Claimant has not produced any fully compliant Notice to Keeper under Schedule 4 of the Protection of Freedoms Act 2012, nor have they clearly pleaded reliance on that legislation in their PoC.
27. In the absence of proper pleadings and proof that the statutory conditions are met, there is no basis for holding me, as the registered keeper, liable for any sum even if a driver had entered into a contract, which is denied.
28. For the reasons set out above, the Claimant’s Particulars of Claim fail to comply with CPR 16.4 and do not disclose a clear cause of action, and on the facts no clear and enforceable contract was formed with any driver due to the absence of an entrance sign at the route used, the contradictory internal signage, and the lack of any sign specifying “0 minutes” or a prohibition on parking.
29. I respectfully invite the Court to strike out or dismiss the claim. If the claim is not struck out before the hearing, I will ask the Court to have regard to the Claimant’s defective pleadings and misleading assertions about the signage when considering the merits and any issue of costs.
-
Hi, I’m getting a bit worried as the WS deadline is 17th December, a week before the court fee is due. I know Dcblegal probably will discontinue before submitting their WS but I’ll have to put together mine just in case they don’t. My question is, how do I submit one and can you please advise me on how to word it all, bearing in mind, not only the sparse Poc but my evidence of no signage on entry to the car park and the conflicting signs within the car park? This is giving me big anxiety and I just want to see that notice of discontinuance :-[
-
Yes, Exactly what I thought, scaremongering tactics! It’s quite laughable that they are claiming £300+ but are willing to settle for £50! I did consider paying just to save the hassle of preparing a witness statement and printing off photo evidence. Sounds like they’ve no intention of preparing a WS. I will forward the email today. Thank you so much for your advice, you are brilliant! :)
-
It's the usual precursor to their discontinuance. Psychological warfare. Stay strong. Respond to that letter with the following email to info@dcblegal.co.uk and CC yourself:
Subject: Re: [Claim number] – Your “without prejudice save as to costs” email dated [date]
Dear Sirs,
WITHOUT PREJUDICE SAVE AS TO COSTS
Thank you for your email of [date].
Liability for the alleged parking charge is denied in full and I will not be making any payment to your client. I will attend the hearing and defend the claim.
You manage to mention “CCJ” no fewer than four times in a short email which says almost nothing about the legal or factual merits of your client’s case. That is plainly designed to intimidate a litigant in person rather than to assist the court in dealing with the matter justly.
For the avoidance of doubt, I am well aware that:
• a County Court Judgment is not an automatic consequence of defending a claim; and
• even if a court were to make an order against me, any judgment would only be registered and capable of affecting my credit if it remained unpaid after one calendar month.
Your attempt to present a CCJ as an inevitable outcome unless I capitulate and pay your client is therefore misleading.
You are already on notice that your client’s Particulars of Claim do not comply with CPR 16.4 and that the claim is defective. If, as I expect, the claim does not succeed, I will invite the court to make a costs order under CPR 27.14(2)(g) on the basis of your client’s unreasonable conduct in:
1. issuing and pursuing a claim on the back of non-compliant Particulars of Claim; and
2. sending threatening settlement correspondence which relies on exaggerated and misleading references to a “CCJ” rather than addressing the merits of the claim.
I will rely on this email, if necessary, at the costs stage as a further example of unreasonable conduct.
If your client now accepts that the claim is fatally flawed, the sensible course is to discontinue with no order as to costs. Failing that, I will proceed to trial and invite the court to strike out or dismiss the claim and to make an appropriate costs order in my favour.
Yours faithfully,
[Defendant’s full name]
[Postal address]
[Email address]
-
So they say “CCJ” four times just so you don’t accidentally miss it.
-
Good Afternoon,
WITHOUT PREJUDICE SAVE AS TO COSTS
We write in respect to the above Claim and shall shortly be sending to you our Client's Witness Statement together with all documents in support of their Claim against you. This evidence will be presented at Trial, and we are confident that your liability for repayment of the Parking Charge will be determined by the Court.
Despite this, we have been instructed to attempt to settle the case with you so that the matter can be brought to an early conclusion and in order that you may avoid a County Court Judgment (CCJ) being granted against you, should the Court award this in our Client's favour. They are therefore willing to settle the case at this stage for a reduced sum of £50.00. Should you be agreeable to the same, please ensure payment is made within 14 days of this email.
If payment in the above sum is not made within 14 days, we have instructions to proceed to Trial, where a CCJ could be granted against you. A CCJ can remain on your credit file for 6 years from the date it is granted, and its impact may make it difficult for you to obtain credit in the future, such as a mortgage.
Once paid we shall inform the Court of the early settlement, requesting the Trial be vacated and the Claim marked as paid. We shall then close our file.
The benefits to you making a payment to settle the Claim at this stage are:
Avoid the case proceeding to Trial where you may have to attend.
Avoid the risk of a CCJ being granted against you and the impact this could have on your credit file.
Avoid the risk of further fees and costs being added to the amount you owe should the Claim proceed.
You can make your payment to settle this Claim by using one of the easy payment methods below:
-
Hi again, I don’t know whether you noticed but I’m in the same position as another member that you have been advising, in that my witness statement must be provided BEFORE the court fee is due. Very annoying to have to put the work in for nothing. However I received this email today from DCBLegal offering to settle, for £50! What do you think?…
-
Ah I get it, thanks. I'll update you in due course.
-
Of course you can start to put together a WS. However, unless you've seen their WS first, you can only use the "hooks" used in your defence. The defence is based on the technical failures by the claimant and until they submit their WS and evidence you have nothing else you can "witness".
Do not submit anything until you show it to us first.
-
I'm thinking about starting to put together a witness statement now in case it does go to court. The PoC being non compliant as the main defence, however, I have photos from April 2020 showing no signs at the entrance to the car park that the driver used. The entry photo on the PCN indicates that this entrance was used. The other entrance to the carpark did have a sign, but no T&C's, it just said ANPR was in use and T&C's can be viewed inside the car park. (The signage is all different now.) DCBLegal claimed in their email to me that the T&C's of the carpark signage stated that there was 0 mins free parking, they said no such thing. They said 60 mins and 120 mins on contradicting signs. The store was closed as it was lock down, but the carpark remained open. I know that they issue many PCNs during lockdown which were cancelled on appeal. I didn't get chance to appeal as they sent the PCN to my previous address. I did update with the DVLA around the time they would've applied but as it was lockdown there was possibly a delay in updating the records. Do you think all this will help back up my defence? As you say, I may not need to do a WS but I want to be prepared. I wont have long after the court fee deadline.
-
There is still a very high probability that DCB Legal will discontinue before the £27 trial fee. However, as it is a telephone hearing, it is no cost to them to attend the haring and they may do so. That puts you at a tremendous disadvantage. It would have been better for you to choose a different county court, such as Liverpool in necessary.
What you will have to wait and see is if they pay the trial fee by the deadline. If they don't, the claim is struck out. If they do, then you will wait to see their Witness Statement. Do not submit your own WS until you have first seen theirs.
We can cross that bridge as and when/if they pay the trial fee.
-
Letter emailed to Court, Cc'd DCBLegal. Thanks. Here's the court letter I couldn't upload yesterday..
https://ibb.co/S7MbLry1
https://ibb.co/JV5Pgfm
-
Let me Google that for you (https://gprivate.com/6j4a2)
civil.sthelens.countycourt@justice.gov.uk
-
Thanks for this, I can't seem to find an email for St Helens County Court, any idea who to email it to? I could easily hand deliver the letter.
-
Is there anything in the Notice of Allocation you received that says something along the lines:
“If you object to this hearing being conducted by telephone/video, you must notify the court…”
It does say..
''This order has been made in the absence of the parties: any party affected by it may apply within 7 days of service of this order, for it to be varied or set aside.''
The claimant is required to pay the court fee by 4pm on the 23rd Dec 2025
-
Is there anything in the Notice of Allocation you received that says something along the lines:
“If you object to this hearing being conducted by telephone/video, you must notify the court…”
You should send something like this to the court and CC the claimant:
URGENT – Request to convert telephone hearing to in-person hearing – Claim No [xxxxxxx]
Dear Sir or Madam,
Claim No: [xxxxxxx]
Parties: [Claimant] v [Defendant]
Hearing date and time: [dd/mm/yyyy, hh:mm]
Court: St Helens County Court
I write in relation to the above claim. The notice of hearing indicates that the small claims hearing is listed to take place by telephone.
I respectfully object to the hearing being conducted by telephone and request that it be re-listed as an in-person hearing at St Helens County Court.
The claimant is a professionally represented parking company which issues large volumes of near-identical small claims and is a serial litigant in this field. Their legal representative will be experienced in this type of hearing and will have the benefit of professional facilities and support.
By contrast, I am a litigant in person with no legal representation. In a telephone hearing I would be at a clear disadvantage in trying to:
• follow the claimant’s submissions in real time;
• locate and move between documents in the hearing bundle while listening; and
• respond properly to points raised by the claimant’s representative.
I am concerned that, in practice, the claimant’s representative will be better able to manage the technology and documentation, and may be assisted off-camera by colleagues, which cannot be effectively policed in a telephone hearing. This creates a real inequality of arms between a serial, professionally represented litigant and an unrepresented defendant.
I therefore submit that an in-person hearing is necessary in the interests of justice and to ensure that I can participate effectively in the proceedings and have a fair opportunity to present my case.
I respectfully ask the court to:
1. Vacate the current telephone listing; and
2. Relist the matter for an in-person hearing at St Helens County Court on the first available date.
If the court considers that a formal application is required, I would be grateful for urgent confirmation so that I can take the appropriate steps without delay.
I have copied the claimant/[claimant’s solicitors] into this email.
Yours faithfully,
[Defendant’s full name]
[Postal address]
[Email address]
-
I used this letter template to get a hearing listed act St Helens sent to the defendants local court, Adapt as necessary:
Dear xxxxx.
Thank you for your response.
While I note the Judge has listed the matter for a Telephone Hearing, I must respectfully maintain my position that this case has been misallocated, in breach of CPR 26.2A(2) and Practice Direction 26, paragraph 7.1, which state that a defended claim against an individual must be transferred to the defendant’s local court.
Whether the hearing is by telephone or in person is not the issue; the allocation itself is procedurally incorrect. I ask again that this matter be put before a Judge for judicial reconsideration under CPR 3.3(4) and that I receive written confirmation of the outcome, including reasons if the request is refused.
In parallel, I have:
* Filed a formal complaint via the HMCTS service, and
* I’ve raised this matter with my MP, as it reflects a broader pattern of systemic court allocation errors linked to bulk litigation by private parking firms. These errors, along with the aggressive legal tactics used, suggest a deliberate misuse of the civil justice system to pressure individuals into unfair settlements.
I respectfully ask the Court to correct the allocation error without placing further burden on me as a litigant in person and without requiring an N244 application, given the clear language of the Rules.
Yours sincerely,
is this letter relevant to me since they have allocated it to my local court, albeit by telephone?
-
It's potentially less hassle for them to 'attend' when it's via phone, vs having to foot the bill of sending a legal rep to court.
-
St Helens is my local court, am I at a disadvantage if its over the phone?
-
I used this letter template to get a hearing listed act St Helens sent to the defendants local court, Adapt as necessary:
Dear xxxxx.
Thank you for your response.
While I note the Judge has listed the matter for a Telephone Hearing, I must respectfully maintain my position that this case has been misallocated, in breach of CPR 26.2A(2) and Practice Direction 26, paragraph 7.1, which state that a defended claim against an individual must be transferred to the defendant’s local court.
Whether the hearing is by telephone or in person is not the issue; the allocation itself is procedurally incorrect. I ask again that this matter be put before a Judge for judicial reconsideration under CPR 3.3(4) and that I receive written confirmation of the outcome, including reasons if the request is refused.
In parallel, I have:
* Filed a formal complaint via the HMCTS service, and
* I’ve raised this matter with my MP, as it reflects a broader pattern of systemic court allocation errors linked to bulk litigation by private parking firms. These errors, along with the aggressive legal tactics used, suggest a deliberate misuse of the civil justice system to pressure individuals into unfair settlements.
I respectfully ask the Court to correct the allocation error without placing further burden on me as a litigant in person and without requiring an N244 application, given the clear language of the Rules.
Yours sincerely,
-
Yes, it’s the one I requested
What did you put in your N180 submission?
Per Reply #27?
https://www.ftla.uk/announcements/posting-images/#new
-
Yes, it’s the one I requested
-
It says the hearing will be conducted by telephone.
At St. Helens by any chance? If so, this is a repeated issue where cases that should be allocated for an in-person hearing get transferred to St. Helens and listed via phone.
-
I’ve received the notice of allocation to the small claims track. It says the hearing will be conducted by telephone. I wasn’t expecting this. Is this usual?
Written evidence must be filed at court by 17th December. I will try to upload the letter, I’m having trouble doing it at the moment
-
Report them to the SRA.
-
Hi, to update, I sent the email about proof of authority to DCBLegal a week ago, not had a response. What do you advise please?
-
It is extremely unlikely you will have to submit a Witness Statement (WS) because in well over 99% of cases, they will discontinue before that stage, You do not submit any WS before you have seen the claimants.
The case you have referenced where there defendant was not successful is not the usual. In that case the defendant was sued for around £280 and ended up only having to pay £135. It cost the claimant much much more to progress that far and they are not going to be happy about it. It was pyrrhic victory for the incompetents at Excel and DCB Legal. They are sulking in some corner licking their wounds.
-
Yes absolutely, it’s a chance worth taking, we have to stand up to these bullies.
Can I just ask, does the witness statement stage happen after the court fee has been paid? What is likely to happen next in my case?
-
Try not to get too disheartened by that. There are a couple of important points to note:
- If you look at other cases, you'll see that DCB cases progressing to a hearing are still very much a tiny minority of cases seen on here (I think we're still at fewer than 5 total)
- Even if you are one of the few unlucky ones, going to a hearing doesn't mean you'll lose
- Even if you do lose, there's a good chance you'll pay less than the total the claimant is seeking. This happened in the case you are referencing, where the judge did not award some of the additional costs, like the spurious debt recovery fee
This forum cannot offer guarantees. The only way you could have guaranteed an outcome would have been to pay up, in which case you would have guaranteed yourself a loss. Fighting it gives you a good chance of a win.
-
Thank you, I have forwarded the email. I really appreciate the time you have put in to advise me on this. I did think it was odd for a support staff member to attend the call. It would be easier for them to just discontinue rather than go through all this for the sake of a relatively small amount. It was disheartening to read about another poster being taken all the way to court today by DCB Legal, and losing. :o
-
Thank you for the update. I advised you to ask who was attending, their role and whether they had authority so you wouldn’t be left relying later on an oral claim by a non-lawyer. Mazur v Charles Russell Speechlys LLP confirms that reserved steps in litigation must be taken by an authorised person or authorised entity; “supervision” of an unauthorised employee is not enough on its own.
Those questions were asked to force identification on the record so we could assess lawful authority there and then. That creates contemporaneous evidence (mediator note + your note) you can rely on later.
If the attendee is only “Litigation Support”, they may not personally be authorised to conduct litigation. Any substantive step they take (e.g. accepting/rejecting settlement, agreeing discontinuance, signing a document that carries legal responsibility) is open to challenge unless adopted by an authorised person.
A mediator’s statement that someone “said they had authority” is not the same as proof of authorisation. Documentary proof of status (or a signed adoption by a named authorised solicitor) is what matters.
About the N180 signed “DCB Legal Ltd”:
Filing an N180 is a step in the conduct of litigation. The form can be completed “by or on behalf of” a party/representative. A firm-name signature is often treated as the authorised entity acting. However, because the step is reserved, you are entitled to request who at the authorised firm approved and caused it to be filed. You’re not asserting automatic invalidity; you’re putting them to strict proof of authorised conduct.
What you should do now is put DCB Legal to strict proof (48-hour deadline) for:
• the attendee’s full name, role and regulatory status; and
• either (a) confirmation with evidence that the individual is personally authorised to conduct litigation, or (b) a short signed adoption by a named authorised solicitor (with SRA number) confirming they exercised professional judgment and adopted any substantive stance taken on the call.
• Identify the N180 decision-maker. Request confirmation of the named authorised person (name, role, SRA number) who approved and caused the N180 to be filed, and a short statement from them confirming that they adopted/authorised its contents at the time of filing. (If they prefer, they can file a brief corrective statement rather than re-issuing the N180.)
Until you receive the identification/adoption above, treat any settlement position from the call as provisional. Reserve all rights.
If they fail to respond, you can (a) write to the court for short directions requiring identification/ratification of the reserved steps, and (b) consider a regulatory report. Keep a time log for costs.
Send the following email to info@dcblegal.co.uk and c yourself:
Subject: Urgent — Strict proof of authority (mediation attendee & N180 signatory); Legal Services Act 2007; Mazur v Charles Russell Speechlys LLP — 48-hour deadline
To: info@dcblegal.co.uk
Cc: [court email if desired]
Dear Sirs
Re: [Claimant] v [Defendant] — Claim No. [XXXXXXXX]
Strict proof of authority: mediation attendee and N180 Directions Questionnaire
I write as the litigant in person defendant. This email puts you to strict proof on two separate issues of conduct of litigation (a reserved activity under the Legal Services Act 2007).
1. Mediation attendee — authority to conduct litigation
At the court-referred mediation on [date], your attendee was identified as Ariba Kamal — “Litigation Support”. The only substantive purpose of the call was to communicate settlement positions (my offer was £0; no agreement was reached). Making, accepting, or rejecting settlement offers within extant proceedings is a reserved litigation step.
Further to
Mazur v Charles Russell Speechlys LLP, “supervision” by an authorised solicitor does not itself authorise an unauthorised employee to conduct reserved activities. Accordingly, within 48 hours please provide:
(a) Documentary proof of individual authorisation for Ms Kamal to conduct litigation: full name as registered, regulator, authorisation category/status, and authorisation/reference number; or
(b) If no such individual authorisation exists, a signed adoption from a named authorised solicitor (full name and SRA number) confirming they personally exercised final professional judgment at the time of the mediation call and that they adopt and ratify any substantive stance communicated by Ms Kamal during that call.
For the avoidance of doubt, a mediator’s informal statement that an attendee “had authority” is not proof of authorisation to conduct a reserved activity.
2. N180 signed “DCB Legal Ltd” — identification and ratification
Lodging an N180 Directions Questionnaire is a step in the conduct of litigation. The N180 on this claim bears only “DCB Legal Ltd” as signatory. Within 48 hours please provide:
(a) The full name, role, and SRA number of the authorised person who approved and caused the N180 to be filed on behalf of the claimant; and
(b) A short signed statement from that authorised person confirming they personally authorised/adopted the contents of the N180 at the time of filing.
If any unauthorised employee handled submission, provide a signed adoption from the authorised person as above.
Scope and evidence preservation
This request concerns the mediation attendee’s authority and the N180 only. I have retained a contemporaneous note of the mediation (time/date; attendee name/role; authority confirmed by the mediator; settlement positions). Please preserve your own notes/records accordingly.
Non-compliance
If you fail to comply fully within 48 hours of this email, I will, without further notice and without prejudice to other remedies:
• Write to the Court seeking short directions requiring immediate identification/ratification of these reserved steps;
• Seek appropriate costs for the time and expense caused; and
• Consider a regulatory report to the SRA regarding potential breaches of the Legal Services Act 2007 and your regulatory obligations.
Please acknowledge receipt and provide full, substantive compliance within 48 hours.
Yours faithfully
[Your full name]
[Postal address]
[Email]
Defendant — Claim No. [XXXXXXXX]
-
Hi just an update on the mediation call, I did as you said, the claimant’s attendee was named as Ariba Kamal, her position was Litigation Support. The mediator confirmed she had authority. After my offer, she stated that the claimant would not discontinue, they would’ve done so already if that was the case.
Can I also mention, after reading another thread, their N180 form was signed ‘DCB Legal Ltd’. Is this significant?
-
Nothing, as you are only offering £0. What we need the information for is to find out whether the person on their end is authorised to conduct litigation.
-
Thank you, I will do as you advise. Just wondering, what would be the consequence of their mediation attendee not having any authority to do so?
-
There is no such thing as "court proceedings". The case has reached the litigation stage. However, it will never get as far as an actual hearing with a judge. They will eventually discontinue if the case isn't first struck out.
For the mediation call, the only requirement is for you "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.
-
DCB Legal always continue with court proceedings after the mediation at which you should offer £0 to settle.
DCB Legal is scaring you into paying them.
DCB Legal will discontinue the claim before having to pay the court fee, with at least 99% certainty, but you have to stay the course with advice you’ll get here first.
Search the forum for lots of DCB Legal cases if you don’t believe me.
-
Just want to update, I’ve got a mediation call on 1st October. So, I just refuse to settle? Do you know of any cases where DCBLegal have continued with court proceedings in a case like mine? I really don’t want it to go that far.
-
Just don't tick anything then.
-
It's no big deal. You can just resend the form again, with the correct tick. Just make sure you send it to both the court and the claimant.
I didn’t tick the legal rep box, just the defendant box but it appears differently on the PDF after it’s saved, the boxes disappear so it looks like I’m saying I’m the legal representative! I’m guessing I don’t need to tick the defendant box after the signature?
-
It's no big deal. You can just resend the form again, with the correct tick. Just make sure you send it to both the court and the claimant.
-
Hi again, I’ve just sent off my N180 form by email which I downloaded as advised. When I looked over the sent form, I noticed after the signature it says ‘legal representative for the’… I inadvertently ticked the defendant box.
I don’t know if this is an issue?
-
It will update when they hav e sent it.
-
Ok, I entered the details from the claim form in the ‘respond to a claim’ box. The claim details are there, the last update being that my defense was received on 24/6/25. No mention of any directions questionnaire yet.
-
I’ve just enrolled on MCOL. There’s no history of any claims, I haven’t submitted anything or responded to the claim form on there, I just sent my defense to the email you advised. Have I missed something along the way?
-
It should be.
-
If I log on via government gateway and create an account, will the claim details be on there?
-
Sorry, I’m a bit confused, I haven’t registered on MCOL.
-
It doesn't matter how or if you submitted your AOS. You should still be able to log into your MCOL and check everything.
-
Thanks. I didn’t acknowledge through MCOL though , I just submitted my defense straight away. Does that matter?
-
You will receive your own DQ but you can pre-empt it by checking your MCOL history for when yours has been sent then 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.
-
Hi again, I’ve received an email from DCBLegal stating their intention to proceed, attached is a directions questionnaire which they have completed. What happens next? Will I receive the same questionnaire?
[attachment deleted by admin]
-
The only reason you would need to submit the AoS is if you need more time to put your defence together. Do you need more time?
...I didn't think so!
-
Ok, thanks. So If I email the defence today, I don't need to send an acknowledgement of service via MCOL at all?
-
Evidence etc. would come later at the Witness Statement stage, if (unlikely) it gets that far.
-
Thank you! I'm so grateful for your advice, I'll probably go straight ahead with sending my defence. In addition to the non compliant PoC, is it worth adding anything to the template letter, for instance, the photos of the confusing signage and lack of parking T&Cs on entry to the car park?
-
With an issue date of 3rd June, you have until 4pm on Monday 23rd June to submit your defence. If you submit an Acknowledgement of Service (AoS) before then, you would then have until 4pm on Monday 7th July 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 G24 Ltd v [your full name] Claim no.: [claim number]."
IN THE COUNTY COURT
Claim No: [Claim Number]
BETWEEN:
G24 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(7.5);
(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)
-
The original PCN
[attachment deleted by admin]
-
My main defense is that the signage was absent on entry and there was conflicting signs inside, none stated the time allowed was 0 minutes. Can I get advice how to word my defense please?
[attachment deleted by admin]
-
Wait for DCB Legal's response and subsequent N1SDT Claim Form that will follow. One step at a time.
I’ve received the N1SDT claim form today. Should I fill out the acknowledgment of service form and submit my defense later? What advice can you give me to defend the claim?
Thank you
[attachment deleted by admin]
-
When you say you informed the DVLA of the address change, did you do that separately for both your drivers licence and for the V5C? One does not automatically update the other.
Yes I updated the V5C as well, like I say they must’ve applied for my data before it was all updated.
-
The operator can only request your Keeper data from the DVLA once. They cannot go back again later. If your address was not correct at the date they applied for your data then that's it for them. Before any claim is issued, they are required to do a credit reference search for an alternative address if they've not had any response to the original PCN.
When you say you informed the DVLA of the address change, did you do that separately for both your drivers licence and for the V5C? One does not automatically update the other.
-
I have the original PCN and the usual chain of follow on letters.
And these would be what and when?
PCN was received in April 2020, then nothing til the debt recovery letters started in Dec 2024. I moved address a month before the alleged offense but the DVLA provided them with the old address. I did inform the DVLA of the change well before the PCN was issued, DCBLegal are implying I didn’t do this. Maybe the DVLA didn’t get chance to update it before they requested it. I do remember the whole country coming to a halt in March 2020. Except of course for the grabbing parking companies!
-
The signs were separate but in the same carpark, I just put them together on the photo.
Neither states '0' minutes, neither are they consistent.
I have the original PCN and the usual chain of follow on letters.
And these would be what and when?
I like to think that if this was pursued by the claimant then you would have a substantive defence against the alleged breach.
-
there than paraphrasing the response from DCB Legal, you could provide the full content.
I will post the response if it helps…
[attachment deleted by admin]
-
CPR – Rules and Directions (https://www.justice.gov.uk/courts/procedure-rules/civil/rules)
-
Thanks for the advice. What is the CPR 16.4 you mention?
-
Rather than paraphrasing the response from DCB Legal, you could provide the full content.
There rest of the advice about waiting for the inevitable N1SDT Claim Form still stands.
There is no reason to go into the minutiae of any details as the defence will be solely based on the failure of the claimant to comply with CPR 16.4. Don't waste any more effort as this will never reach a hearing and will either be struck out oro discontinued.
-
The signs were separate but in the same carpark, I just put them together on the photo. The original PCN was sent in April 2020 to an address that I moved from a month earlier. It was forwarded to me by the new occupant. DVLA were informed as soon as the address changed but it was the start of the pandemic and first lockdown so maybe there was a delay in updating the details. The PCN was ignored and I heard nothing else until December 2024. A series of debt recovery letters started, all of which were ignored until I received the letter of claim.
-
The two side-by-side signs in your photo are contradictory e.g. one states 60 minutes while the other states 2 hours etc.
Were they situated together or have you created this using photoshop techniques?
So you received the PCN...and then did what?
If nothing, then the 'unreasonable behaviour' to which your LoC response referred would likely be applied to you.
What's the timeline of notices, letters and general correspondence over the 5 years?
IMO, your strongest argument is that 6 years is not a target, it's a ceiling and that if the creditor possessed all the necessary evidence to pursue the keeper in a timely manner then this case should have been brought earlier.
-
Hi, I’ve received a response from DCBLegal to my last communication as above. It’s a very long email full of legal waffle basically justifying their intention to persue the claim and giving me 30 days to pay. They claim the signage said the allowed parking was 0 minutes, it didn’t, It was 5 years ago but I have photos from then showing that to be untrue. Shall I ignore it and wait for the claim?
-
Ok thanks, I’ll come back for advice then.
-
Wait for DCB Legal's response and subsequent N1SDT Claim Form that will follow. One step at a time.
-
This response as advised by a member …
By email to: info@dcblegal.co.uk
31/03/2025
Dear Sirs,
Re: Letter of Claim dated 20th March 2025
I refer to your Letter of Claim.
I confirm that my address for service at this time is as follows, and I request that any outdated address be erased from your records to ensure compliance with data protection
(My address)
Please note that the alleged debt is disputed, and any court proceedings will be robustly defended.
I note that the sum claimed has been increased by an excessive and unjustifiable amount, which appears contrary to the principles established by the Government, who described such practices as “extorting money from motorists.” Please refrain from sending boilerplate responses or justifications regarding this issue.
Under the Pre-Action Protocol for Debt Claims, I require specific answers to the following questions:
1. Does the additional £70 per PCN represent what you describe as a “Debt Recovery” fee? If so, is this figure net of or inclusive of VAT? If inclusive, I trust you will explain why I, as the alleged debtor, am being asked to cover your client’s VAT liability.
2. Regarding the principal sum of the alleged Parking Charge Notice (PCN): Is this being claimed as damages for breach of contract, or will it be pleaded as consideration for a purported parking contract?
I would caution you against simply dismissing these questions with vague or boilerplate responses, as I am fully aware of the implications. By claiming that PCNs are exempt from VAT while simultaneously inflating the debt recovery element, your client – with your assistance – appears to be evading VAT obligations due to HMRC. Such mendacious conduct raises serious questions about the legality and ethics of your practices.
I strongly advise your client to cease and desist. Should this matter proceed to court, you can be assured that these issues will be brought to the court’s attention, alongside a robust defence and potentially a counterclaim for unreasonable conduct.
Yours faithfully,
-
As I mentioned, I responded to the letter of claim on 31/03/25.
..and said what?
Pl post a copy.
-
Hi
I’ve uploaded the original PCN from 2020 and the letter of claim from DCBLegal. I’ve added a couple of pictures of the confusing signage, and the non existing signage at one of the entrances of the car park (as it was at the time) The other entrance had a sign indicating the use of ANPR but nothing about the conditions of parking. This car park remained open during the lockdown, they could’ve closed it or put up signage saying no parking was allowed, instead they continued to send out PCNs to everyone who used it saying the permitted parking time was 0 mins.
As I mentioned, I responded to the letter of claim on 31/03/25. What will happen next and how can I defend this if they continue with the court claim? Thank you.
[attachment deleted by admin]
-
I will upload any docs and photos when I've worked out how
READ THIS FIRST - Private Parking Charges Forum guide (https://www.ftla.uk/private-parking-tickets/read-this-first-private-parking-charges-forum-guide/)
-
Hi,
As the registered keeper, I received a letter of claim from dcb legal on 20/03/25. The parking charge is from G24 and dates back to April 2020, during lockdown. I have the original PCN and the usual chain of follow on letters. I refused to pay after reading the advice on here so I have responded to the LOC with the same template letter that other posters were advised to send. I believe I have grounds to defend the charge, I have photos of the carpark signage from 2020, I will upload any docs and photos when I've worked out how but in the meantime, can anyone advise me on what to expect next in the process. Thanks