FFS!!!! That timetable is the worst of both worlds for a defendant when you’re dealing with a serial discontinuer like DCB Legal.
What the court has done (and why it’s a problem)
• Hearing: 18 February 2026
• Claimant’s trial fee deadline: 21 January 2026
• Both parties’ WS/evidence deadline: 15 December 2025
So you, as defendant, must:
• Do all the heavy lifting (WS, exhibits, case law bundle) before Christmas 2025
• While the claimant still hasn’t even shown they’re serious enough to pay the trial fee in January 2026
Given DCB Legal’s history of:
• Filing weak claims
• Dragging defendants through the directions stages
• Then discontinuing at the eleventh hour when trial fee / real work is due
…it is entirely rational to say this timetable loads the burden onto the defendant and encourages exactly that abusive pattern.
You have two options:
Option 1:
You can apply under CPR 3.3(5) / CPR 23 to vary the directions, on the basis that they are disproportionate and unfair to the defendant. The simple request is:
That the deadline for exchange of witness statements and documents be moved to a date after the claimant’s trial fee deadline (e.g. 14 days after 21 January 2026), so that the defendant is not forced to incur unnecessary costs where the claimant does not pay the fee and the claim is automatically struck out.
However, that will already incur an extra cost to submit an N244 application.
Option 2:
If you decide you don’t want the hassle/cost of an N244:
Write a short letter/email to the court (headed with the claim number) saying:
• You note the listing order
• You are concerned about disproportionate costs being front-loaded onto a litigant in person where the claimant may not even pay the trial fee
• You respectfully invite the court, of its own initiative under CPR 3.3, to move the WS deadline to after the trial fee date
• If the court declines, you will comply but reserve the right to seek wasted/indemnity costs if the claimant discontinues after you’ve prepared your WS.
I would suggest you go for option 2. If the court declines or insists on an N244 application, just wait until you receive the claimants WS, which is highly unlikely going to happen.
Courts do sometimes move the WS deadline to after the trial fee date if you ask clearly and reasonably and keep it short. There’s no guarantee. A “procedural” DJ may just shrug and say “these are standard small-claims directions”.
But you are absolutely not being unreasonable to say: “If the claimant won’t even pay £27 to continue, I shouldn’t have to burn hours drafting a detailed WS before that’s known.”
I suggest you email the following to the court at civil.romford.countycourt@justice.gov.uk and CC DCB Legal at info@dcblegal.co.uk and yourself:
Subject: Claim [CLAIM NUMBER] – Request to Vary Directions (Witness Statement Deadline)
Claim No: [XXXXX]
Between: G24 Ltd
and
[Defendant]
TO: The Court Manager
Romford County Court
Dear Sir or Madam,
Re: Listing and directions – request to vary witness statement deadline
I write as the Defendant in the above matter, regarding the recent order listing the hearing for 18 February 2026.
The order provides that the parties must file and serve their witness statements and documents by 15 December 2025, and that the Claimant must pay the trial fee of £27 by 21 January 2026.
I respectfully ask the Court to reconsider this timetable. As a litigant in person, preparing a witness statement and evidence bundle is a significant amount of work and time. Under the current order, I am required to complete this work more than a month before it is known whether the Claimant intends to proceed and will pay the trial fee. In a low-value small claim, this front-loads the burden and risks unnecessary expense.
In particular, I draw the Court’s attention to the fact that the Claimant is represented by DCB Legal Ltd, a bulk-litigation firm in private parking matters. I have been following a long-running public thread on the MoneySavingExpert consumer forum where defendants post copies of Notices of Discontinuance (Forms N279) in parking claims conducted by DCB Legal. Over a little more than two years that thread has recorded in excess of 700 such discontinuances, each evidenced by a redacted N279. Whilst I do not suggest this is a definitive or complete dataset, it does, in my respectful submission, demonstrate a clear pattern: defended small claims issued by this firm are overwhelmingly likely to be discontinued before trial, always shortly before the trial fee falls due. If the Court would find it of assistance, I can provide a small sample of those N279s by way of illustration.
Against that background, requiring a litigant in person to complete a full witness statement and evidence bundle before the Claimant has even demonstrated a genuine intention to pursue the claim by paying the modest trial fee is, in my respectful submission, disproportionate and contrary to the overriding objective in CPR 1.1. It effectively facilitates a pattern whereby the represented party can put defendants to unnecessary work and then discontinue at the last moment without having to undertake equivalent preparation.
In light of this, I invite the Court, of its own initiative under CPR 3.3, to vary the directions so that the deadline for exchange of witness statements and documents is set after the trial fee date. For example:
“The parties shall file and serve their witness statements and all documents on which they intend to rely no later than 4 February 2026.”
(being 14 days after the trial fee deadline of 21 January 2026).
If the Court is not minded to adopt that exact date, I would be grateful if some alternative date after the trial fee deadline could be set, so that I am not required to incur the time and effort of preparing a full witness statement bundle in circumstances where, on past form, this particular Claimant’s solicitors are very likely to discontinue if they do not even pay the trial fee.
If the Court declines to vary the order, I will of course endeavour to comply with the existing timetable. However, I wished to raise this concern at the earliest opportunity.
A copy of this email has been sent to the Claimant’s solicitors, DCB Legal Ltd.
Thank you for your consideration.
Yours faithfully,
[Defendant’s name]
[Address]
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.
With an issue date of 24th April, you have until 4pm on Tuesday 13th May to submit your defence. If you submit an Acknowledgement of Service (AoS) before then, you would then have until 4pm on Tuesday 27th May 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 and relevant transcripts that go 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 send all the documents as a single PDF attachment (in the order of 'defence', 'draft order' and then the 2 'transcripts') 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(1)(a).
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 cites the cases of CEL v Chan 2023 [E7GM9W44] and CPMS v Akande 2024 [K0DP5J30], which are persuasive appellate decisions. In these cases, claims were struck out due to identical failures to comply with CPR 16.4(1)(a). Transcripts of these decisions are attached to this Defence.
5. 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.(1)(a). 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) Failed to 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.
6. 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(1)(a).
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/zc23txk7poctyyxiv2ytx/Strikeout-order-1-a-v2.1.pdf?rlkey=pancly3z6zwqt2cra5rvvh3ls&st=nq7a58tz&dl=0)
CEL v Chan Transcript (https://www.dropbox.com/scl/fi/nb9ypbecuurpmln00dily/CELvChan-appeal-transcript.pdf?rlkey=7mpuvpmpe45s2zbhch21om1ez&st=i8dnbod3&dl=0)
CPMS v Akande Transcript (https://www.dropbox.com/scl/fi/y631olc61z1slr6xfrdsk/CPM-v-AKANDE.pdf?rlkey=kltpojedcxiwarxr0sdfyjo05&st=qi4lv3fv&dl=0)
If you want an editable MS Word file with everything in a single document which you can then save/export as a single PDF file when ready to send, use this:
MS Word .docx file for defence [CPR 16.4(1)(a)] (https://www.dropbox.com/scl/fi/krubcbnf27bsis66pq4yg/Short-defence-strikeout-CPR16.4-1-a-3.docx?rlkey=z87f3h8is3hgnp7sqr8plsz99&st=ldawlubu&dl=0)