Respond with the following and CC in yourself:
By email to: enquiries@bwlegal.co.uk
Date: [Insert Today’s Date]
Dear Sirs,
Re: Letter of Claim dated 14 April 2025
Your Client: UK Car Park Management Ltd
PCN Ref: [Insert Reference]
Vehicle Registration: [Insert VRM]
Registered Keeper: [Updated Legal Name]
I write further to your unsatisfactory reply to my response under the Pre-Action Protocol for Debt Claims.
Despite being provided with a signed Letter of Authority and formal notification of a legal name change, you have failed to substantively address any of the issues raised. You have not provided the requested documents, nor have you answered the reasonable and relevant questions necessary to understand the basis of the claim.
Instead, you have:
• Refused to disclose the landowner contract on the flawed basis of “commercial sensitivity,” which is not a valid exemption under the Protocol or relevant case law;
• Ignored all 8 information/documentation requests made in accordance with paragraph 5.1 of the Pre-Action Protocol;
• Demanded an arbitrary “password” to process correspondence, despite already being in lawful possession of the Letter of Authority and deed poll, thereby frustrating legitimate communication.
The required information was, and remains, as follows:
1. Clarification on whether the £70 represents a “Debt Recovery” fee, and if so, whether it is inclusive or exclusive of VAT;
2. Clarification on whether the principal PCN sum is claimed as a contractual charge (consideration), or as damages for breach of contract;
3. A copy of the original Parking Charge Notice;
4. Copies of all photographic evidence relied upon, especially those purporting to show no permit was displayed;
5. A clear image of the signage setting out the full terms and conditions at the site on the date of the alleged contravention;
6. Evidence that signage was in place and visible from the specific bay where the vehicle was parked;
7. A full, unredacted copy of the contract or agreement between your client and the landowner or lawful occupier, confirming your client’s legal authority to issue and enforce charges at the site;
8. Evidence that the leaseholder or freeholder of the bay in question permitted enforcement by your client.
Your client is a serial litigant and should be fully aware, as you should also be, that the Practice Direction – Pre-Action Conduct (paragraphs 6(a)–6(c)) and the Pre-Action Protocol for Debt Claims require this material to be provided before proceedings are commenced.
If proceedings are issued without your client complying with these obligations, I will invite the court to:
• Stay the claim under paragraph 15(b) of the Practice Direction;
• Strike out any inflated or unsubstantiated elements of the claim;
• Impose costs sanctions under CPR 27.14(2)(g) for unreasonable pre-action conduct.
These procedural and evidential failings will be brought to the court’s attention with reference to the authorities of:
• Webb Resolutions Ltd v Waller Needham & Green [2012] Webb Resolutions Ltd v Waller Needham & Green EWHC 3529 (Ch) (https://www.bailii.org/ew/cases/EWHC/Ch/2012/3529.html);
• Daejan Investments Ltd v The Park West Club Ltd [2003] EWHC 2872 (https://www.bailii.org/ew/cases/EWHC/TCC/2003/2872.html);
• Charles Church Developments Ltd v Stent Foundations Ltd [2007] EWHC 855 (https://www.bailii.org/ew/cases/EWHC/TCC/2007/855.html).
Unless and until the requested information is provided, no further correspondence will be entered into. Should your client choose to litigate without first complying, it does so at risk.
Yours faithfully,
[Your Name]
(On behalf of the Registered Keeper)
Use the old name (the one on the LoC) — because BW Legal will only deal with the person named in their records or someone with formal authority.
BUT — include both:
• A Letter of Authority from the Keeper (signed in their current, correct name)
• A short statement enclosing the deed poll and requesting that BW Legal update their records accordingly
This keeps it legally correct, doesn’t create confusion at this stage, and ensures that the court claim (when it comes) is issued in the Keeper’s correct name.
Here is the slightly altered response to the LoC:
[Parents Name]
[Address]
[Date]
BW Legal
Enterprise House
Apex View
Leeds
LS11 9BH
By email to: enquiries@bwlegal.co.uk
Dear Sirs,
Re: Letter of Claim dated 14 April 2025
Client: UK Car Park Management Ltd
PCN Ref: [Insert Reference]
Registered Keeper: [Old Name on PCN]
I write on behalf of the Registered Keeper in relation to your Letter of Claim dated 14 April 2025. Please find attached a signed Letter of Authority confirming I am authorised to act in this matter.
I confirm that the correct address for service is:
[Insert Current Postal Address]
Please update your records and erase any outdated addresses in accordance with data protection legislation.
The alleged debt is fully disputed and any claim will be robustly defended. The sum claimed has been grossly inflated and appears to include a disproportionate and unjustified amount, which the Government has described as “extorting money from motorists.”
In accordance with the Pre-Action Protocol for Debt Claims, I request the following information and documentation:
1. Does the additional £70 represent a “Debt Recovery” fee? If so, is it inclusive of VAT? If it is, why is the alleged debtor being asked to bear your client’s VAT liability?
2. Is the principal PCN sum claimed as a contractual charge (consideration), or as damages for breach of contract?
3. A copy of the original Parking Charge Notice;
4. Copies of all photographic evidence relied upon, particularly those purporting to show no permit was displayed;
5. A clear image of the signage showing the full terms and conditions in force at the location on the date in question;
6. Evidence that the signage was visible from the specific bay where the vehicle was parked;
7. A full, unredacted copy of your client’s contract with the landowner or lawful occupier confirming their authority to issue and enforce PCNs at the site;
8. Evidence that any leaseholder or freeholder of the bay in question permitted your client to enforce terms or issue charges.
I also wish to advise you that the Registered Keeper has since changed their legal name. A copy of the deed poll is enclosed for your records. Please ensure your records reflect this, and that any proceedings are brought against the correct legal name of the individual concerned.
Should your client proceed with a claim without supplying the requested documents, this will be brought to the attention of the court and will be cited in any application for costs under the CPR for unreasonable conduct.
Yours faithfully,
[Parents Name]
(On behalf of the Registered Keeper)
I have had a response- do i need to do anything more?
[attachment deleted by admin]
That auto-response from BW Legal is not a genuine email bounce. A true "bounce" (either hard or soft) would be generated by a mail server, not by a noreply autoresponder. This message confirms that the email was received by their system, but they are choosing not to acknowledge or process it, which is an entirely different matter.
The key phrases:
"Your email has not been received"
"It is being returned as undelivered"
are misleading. If the message were undelivered, your email client or server would have issued a Delivery Status Notification (DSN) or Non-Delivery Report (NDR). Instead, this is just a standard template intended to deter direct email communication.
This practice raises legitimate concerns about transparency and accessibility, especially for debt-related matters where secure and provable communication is vital. There is also be an argument that such conduct breaches the SRA Standards and Regulations, including the Code of Conduct for Solicitors.
Try resending to disputeresolution@bwlegal.co.uk instead, making sure you CC in yourself.
Use the old name (the one on the LoC) — because BW Legal will only deal with the person named in their records or someone with formal authority.
BUT — include both:
• A Letter of Authority from the Keeper (signed in their current, correct name)
• A short statement enclosing the deed poll and requesting that BW Legal update their records accordingly
This keeps it legally correct, doesn’t create confusion at this stage, and ensures that the court claim (when it comes) is issued in the Keeper’s correct name.
Here is the slightly altered response to the LoC:
[Parents Name]
[Address]
[Date]
BW Legal
Enterprise House
Apex View
Leeds
LS11 9BH
By email to: enquiries@bwlegal.co.uk
Dear Sirs,
Re: Letter of Claim dated 14 April 2025
Client: UK Car Park Management Ltd
PCN Ref: [Insert Reference]
Registered Keeper: [Old Name on PCN]
I write on behalf of the Registered Keeper in relation to your Letter of Claim dated 14 April 2025. Please find attached a signed Letter of Authority confirming I am authorised to act in this matter.
I confirm that the correct address for service is:
[Insert Current Postal Address]
Please update your records and erase any outdated addresses in accordance with data protection legislation.
The alleged debt is fully disputed and any claim will be robustly defended. The sum claimed has been grossly inflated and appears to include a disproportionate and unjustified amount, which the Government has described as “extorting money from motorists.”
In accordance with the Pre-Action Protocol for Debt Claims, I request the following information and documentation:
1. Does the additional £70 represent a “Debt Recovery” fee? If so, is it inclusive of VAT? If it is, why is the alleged debtor being asked to bear your client’s VAT liability?
2. Is the principal PCN sum claimed as a contractual charge (consideration), or as damages for breach of contract?
3. A copy of the original Parking Charge Notice;
4. Copies of all photographic evidence relied upon, particularly those purporting to show no permit was displayed;
5. A clear image of the signage showing the full terms and conditions in force at the location on the date in question;
6. Evidence that the signage was visible from the specific bay where the vehicle was parked;
7. A full, unredacted copy of your client’s contract with the landowner or lawful occupier confirming their authority to issue and enforce PCNs at the site;
8. Evidence that any leaseholder or freeholder of the bay in question permitted your client to enforce terms or issue charges.
I also wish to advise you that the Registered Keeper has since changed their legal name. A copy of the deed poll is enclosed for your records. Please ensure your records reflect this, and that any proceedings are brought against the correct legal name of the individual concerned.
Should your client proceed with a claim without supplying the requested documents, this will be brought to the attention of the court and will be cited in any application for costs under the CPR for unreasonable conduct.
Yours faithfully,
[Parents Name]
(On behalf of the Registered Keeper)
We need a close up of the sign so we can read the wording on it. Can you confirm that the vehicle is registered in your son's name and everything is addressed to him?
If you intend to respond on his behalf, then you will need a Letter of Authority signed by your son. I suggest you get him to sign the following and then include it with the next letter which is the response to the LoC:
To whom it may concern,
I, [Full Name of Registered Keeper], of [Address], confirm that I authorise my [mother / parent / named individual], [Full Name of Representative], to act on my behalf in all matters relating to the Parking Charge Notice referenced in your Letter of Claim dated 14 April 2025, issued by UK Car Park Management Ltd.
This authority includes, but is not limited to, corresponding with your firm, requesting information or documentation, and submitting responses or complaints on my behalf.
Signed: ________________________ Date: _______________
[Full Name of Registered Keeper]
And this is the response to the LoC you can then send:
BW Legal
Enterprise House
Apex View
Leeds
West Yorkshire
LS11 9BH
By email to: enquiries@bwlegal.co.uk
Dear Sirs,
Re: Letter of Claim dated 14 April 2025
Client: UK Car Park Management Ltd
PCN Ref: [Insert Reference]
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 obligations:
[Insert Correct Postal 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 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?
Furthermore, in order to understand the legal basis for your client's claim and to allow for a considered response, I require the following documentation and evidence:
a. A copy of the original Parking Charge Notice issued;
b. All photographs taken by or on behalf of your client, including those purportedly showing that no permit was displayed;
c. A close-up photograph of the signage at the location as it appeared on the material date, showing all terms and conditions relied upon;
d. Evidence that signage was in place and visible from the specific bay in which the vehicle was parked;
e. A full, unredacted copy of the contract or agreement between your client and the landowner or lawful occupier, demonstrating the authority to issue and enforce parking charges at the site;
f. Evidence that the lease or freehold interest in the relevant bay permits the imposition and enforcement of third-party parking terms by your client.
I would caution you against simply dismissing these questions with vague or generic responses. I am fully aware of the implications of your client’s model. By claiming that PCNs are not subject to VAT while inflating a supposed “debt recovery” element, your client – with your assistance – appears to be evading tax obligations that may be due to HMRC. That 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, these issues will be brought to the court’s attention, alongside a robust defence and potential counterclaim for unreasonable conduct.
Yours faithfully,
[Your Name]
(on behalf of the Registered Keeper)
You send the response as an email to enquiries@bwlegal.co.uk and you also CC in yourself. Make sure that you also send the Letter of Authorisation.