Free Traffic Legal Advice

Live cases legal advice => Private parking tickets => Topic started by: helenwhite00 on June 25, 2025, 05:11:27 am

Title: Re: Letter of Claim - DCB Legal
Post by: b789 on January 02, 2026, 12:36:24 am
As I already advised, mediation is NOT part of the judicial process and the mediator is not legally trained. No judge is involved. The whole mediation call is a complete waste of everyones time. You DO NOT try and negotiate any settlement. Simply ask the questions as advised above and offer £0. It will be over in minutes.

You will NOT be paying a penny to anyone. I can assure you that once the claim is transferred to your local county court, if the procedural judge does not strike the claim out, DCB Legal will discontinue just before they are required to pay the £27 trial fee. That will then be the end of the matter.

Do not scupper that outcome by trying to overthink this. We have over 750 discontinuations from DCB Legal over the last couple of years. No claim for under £600 ever reaches a hearing. If not struck out, they WILL discontinue.
Title: Re: Letter of Claim - DCB Legal
Post by: helenwhite00 on January 02, 2026, 12:04:06 am
As always thanks for the advice in the last post and Happy  New Year 🎉

I have received my mediation date now of 9th January.  Do I consider any offers to settle in that (e.g.agree to pay have for the additional admin costs so £35) do I just say that I have already paid and so am not willing to pay twice and so will go to court if needed…?

Thanks,
Helen
Title: Re: Letter of Claim - DCB Legal
Post by: b789 on December 10, 2025, 03:57:47 pm
You are way overthinking this. You’re reading far too much into that complaint response.

Let me be absolutely clear: this case is not heading for a hearing. Not in any realistic universe. DCB Legal’s business model on single private parking claims is simple:

• Fire off bulk, low-quality claims with slurry template Particulars of Claim.
• Hoover up easy default judgments and scared people who pay when they see “court”.
• Where a defendant files a competent defence and follows the process, quietly discontinue before the trial fee is due.

That is what they do. Over and over again. We only scratch the very tip of the iceberg and we have sight of well over 700 discontinuances over the last couple of years.

On this forum, for properly defended single-PCN claims run by DCB Legal, the pattern is effectively 100%: they fold before a hearing. The statistical chance of your defended claim, with a CPR 16.4 defence and the Mazur/Ensall issue flagged, actually reaching a final hearing is not just “low” – it is vanishingly small. I am talking well under 1 in 1,000 based on what we know and experience.

That’s why I say – and stand by – that if this ever gets as far as a hearing, I’ll eat my hat and help you with your witness statement. I am that confident it won’t happen.

A few specifics:

• Their line about “we intend to proceed” and “we are reviewing our processes” is pure face-saving. They cannot write “you’ve nailed us on Mazur and we’re backing off”; they have to maintain the pretence that everything is fine and they’re marching resolutely towards trial.
Mazur and the Legal Services Act point are already doing their job by sitting on the court file and with the SRA. You’ve raised legitimate issues. Their boilerplate attempt to brush it off doesn’t make those issues disappear.
• The £100 you paid to DRP absolutely counts. DRP were acting as the client’s agent. Payment to an authorised agent is payment to the principal. At witness statement stage (if we even get that far) you will:

• Exhibit the DRP demand for £100 for this exact PCN; and
• Exhibit your bank statement showing £100 paid to DRP; and
• Explain that the principal sum was paid long before proceedings and what’s now being chased is made-up add-ons and duplication.

As for what you do now:

• You do not need to reply to that “complaint closed” email at all.
• You have already:

• Filed your defence focused on their defective Particulars of Claim, and
• Emailed the court about the Mazur/Ensall issue, and
• Reported the matter to the SRA.

Those boxes are ticked. Nothing you say to a “Complaints and Compliance Associate” will alter the trajectory of the claim.

The next meaningful step will come from the court, not from DCB Legal. When the court sends you the Notice of Allocation and directions (naming your local court and giving a trial fee deadline), post that up.

But I repeat, so you don’t lose sleep over this: on a defended, single-ticket Euro Car Parks claim run by DCB Legal, with this defence on file and the Mazur/SRA issues raised, the realistic probability of you ever sitting in front of a judge is effectively zero.
Title: Re: Letter of Claim - DCB Legal
Post by: helenwhite00 on December 10, 2025, 12:15:22 pm
Dear Helen Elizabeth White,
 
I write further to our correspondence dated 03/12/2025 in acknowledgement of your complaint. I have conducted a full review of the issues raised within your complaint and the outcome of this review is detailed below.
 
For context, your file relates to an unpaid Parking Charge issued on the 19/10/2023 at Hill Street – Birmingham due to the P&D/permit purchased did not cover the date and time of parking. DCB Legal were instructed on 03/06/2025 by our Client, Euro Car Parks Limited as all previous attempts to recover payment were unsuccessful and no successful appeal was lodged.
 
Upon instruction, DCB Legal issued a formal Letter of Claim in accordance with the Pre-Action Protocol. We received no payment; hence, a Claim was issued against you on the 16/09/2025 under Claim Number XXXXXXXX. You filed a Defence dated 30/09/2025.
 
For clarity, all employees of DCB Legal operate under the oversight and supervision of its qualified Solicitors and all processes/files are reviewed and approved by our Solicitors before any legal action is taken.
 
In respect to your reference to the Legal Services Act 2007 and the recent well-known case law of Mazur v Charles Russell Speechlys, we can confirm that in line with standard practices, DCB Legal is currently reviewing its operational processes with a view to ensuring continued compliance within the supervisory framework and regulatory requirements. We are aware that we are not the only Solicitors firm to be reviewing its processes, and this affects activities across the legal industry.
 
Due to the above, the Claim Form has been served in line with the Legal Service Act, as such your comments bear no relevance to your case.
 
Due to the above review and the history of your file, DCB Legal will not be upholding your complaint. If payment is made of the Claim balance of £281.76, then legal proceedings will cease. Failure to make payment will result in the continuation of legal proceedings.
 
DCB Legal are meeting their legal obligations and are continuing to act professionally, as such we consider your complaint file closed. Payment can be made via bank transfer to our designated client account: -
 
•                     Account Name: DCB Legal Ltd Client Account
•                     Sort Code: 20-24-09
•                     Account Number: 60964441
 
You must quote the correct case reference 711200094142ECPL when making payment. If you do not, we may be unable to correctly allocate the payment. If further action is taken by us as a result of an incorrect reference being quoted, you will be liable for any further fees or costs incurred.
 
Alternatively, you can contact DCB Legal Ltd on 0203 434 0424 to make payment over the telephone or online at https://dcblegal.co.uk/response/pay-online/
 
 
Kind Regards,
 
Rhiannon Marsh
Complaints and Compliance Associate
DCB Legal Ltd
Title: Re: Letter of Claim - DCB Legal
Post by: helenwhite00 on December 10, 2025, 12:12:56 pm
I received below email response from DCB Legal (email in next post) today and so do I respond to them and what is any other further follow-up do I do in relation to this….?
 
Also below response is not just a cut and paste, they are responding to my specific case and so it does sound like they intend to proceed take it to court and so if they send a solicitor for that I will not know how to respond to questions and their responses as with the written correspondence I can ask for advice on this forum but won’t be able to do that in court….?
 
Finally they keep saying I haven’t paid and keep ignoring the communications I sent them detailing the £100 paid, so I am guessing they with argue they never received that money as it didn’t go directly to them but another company (Debt Recovery Plus) they used so will it be enough that I can show from my bank statement the money was paid to Debt Recovery Plus as they had sent me a letter relating to this matter…?
 
Thanks,
Helen
Title: Re: Letter of Claim - DCB Legal
Post by: helenwhite00 on December 01, 2025, 04:03:32 pm
Hi and thanks again for the help.

I sent the DQ on Friday to DQ.CNBC@justice.gov.uk and info@dcblegal.co.uk.

Had sent the other 3 emails re. Sarah Ensall a few days earlier as soon as I got back.

Will let you know as soon as I hear anything more.

Thanks,
Helen.
Title: Re: Letter of Claim - DCB Legal
Post by: b789 on November 27, 2025, 02:30:21 pm
Did you send the last 3 emails I advised?

H1. When do you mention that you already paid £100?

Still not yet.

The defence you filed is deliberately confined to the defective Particulars of Claim (CPR 16.4 issue). At this stage you do not add facts or start arguing about payment. The right place for the £100 point is your witness statement and evidence bundle, if the claim ever gets that far. That’s when you will:

– Exhibit the DRP letter showing the £100 figure
– Exhibit your bank statement showing the £100 payment
– Explain in a short narrative that the “principal” sum was paid months ago and the only thing now pursued is an invented add-on

Nothing about that needs to go on the N180.

2. Does getting an N180 mean it will definitely go to a hearing?

No. The N180 is just the next procedural step (Directions Questionnaire). It means the claim has moved past the acknowledgement/defence stage and the court is now deciding:

– Which track (small claims – it will be)
– Which local court
– Whether to list a hearing, and roughly when

Over 99% of private parking claims are discontinued by DCB Legal after after directions are given, especially where a proper defence has been filed. You must assume it might go to a hearing (highly unlikely) and complete everything properly, but it is more likely than not – that they will discontinue later once they realise you’re not an easy win.

3. If it does go to a hearing, will you get help with what to say?

Yes.

If it reaches the witness statement stage, you will:

– Draft a short, clear witness statement telling your side
– Include the fact and proof of the £100 payment
– Attach key exhibits (DRP letter, payment proof, any earlier correspondence)

You won’t be left to guess what to say. Post back here when the court sends you the Notice of Allocation and directions (with the WS deadline) and we can walk you through the WS and evidence step by step.

4. What do you do about dates you can’t attend on the N180?

On the N180 there is a box asking about dates in the next few months when you definitely cannot attend a hearing (holidays, booked exams, immovable work commitments, etc.).

– If you already know any fixed dates you cannot do, list them now.
– If you genuinely don’t yet know your study/work pattern, you can leave that section blank for now.

If the court later lists a hearing on a date you cannot attend (because of exams, a fixed work rota, pre-booked holiday etc.), you can then write to the allocated court as soon as you know asking for the date to be moved, explaining why and attaching evidence if possible. It’s not ideal to rely on a change later (it may involve an application and fee), so do include any known “blackout” dates now, but don’t worry if you can’t predict everything.

Quick reminder for the N180 itself:

– Small claims track: Yes
– Your local court: request your nearest one
– Mediation: mandatory only to "attend" the call
– Witnesses: put “1 – the Defendant
– Sign by simply typing your full name and date it
– Email a copy to the court (CNBC) and a copy to DCB Legal before the deadline.

You've already been advised on how to complete and where to email the N180.
Title: Re: Letter of Claim - DCB Legal
Post by: helenwhite00 on November 26, 2025, 05:38:23 pm
I been away for 12 days and the form N180 form had arrived when I got back ands needs to be emailed before the 1st of December but had a few questions:

When do I provide the information that I have already paid at least part of the amount…?

Does this mean the case may now go to court or is it still unlikely to get that far…?

If it does get that far I have no idea what I should ask or follow-up to responses but hoping if needed someone on here can help with that.

There will be dates due to work I can’t make but as timelines on my study still being sorted I don’t know when these will be so can I update availability dates later…?

Thanks as always,
Helen.
Title: Re: Letter of Claim - DCB Legal
Post by: b789 on November 13, 2025, 04:03:31 pm
Send all the following emails...

To info@dcblegal.co.uk and CC yourself:

Quote
Subject: Claim [claim number] – Notice of escalation following continued non-response

Dear Sir/Madam,

I refer to my emails of 28 September 2025 and 3 November 2025 concerning the N1SDT Claim Form signed “Sarah Ensall – Head of Legal”, requesting confirmation of her authorisation or exemption under the Legal Services Act 2007 to conduct litigation.
You have failed to respond to either email.

As warned, I have now taken the following actions:

Court notification – Both previous emails and this correspondence have been provided to the Court with a request that the issue of the signer’s authority be considered at the appropriate stage. I have invited the Court to treat your failure to engage as unreasonable conduct and to consider a costs order under CPR 27.14(2)(g).
Regulatory escalation – A formal complaint has been submitted to the SRA concerning the potential unauthorised conduct of litigation, including the filing and signing of a Claim Form by a person whose authorisation or exemption has not been confirmed despite repeated requests.

For completeness, I remain willing to receive your confirmation as to Ms Ensall’s authorised status or exemption under Schedule 3 of the Legal Services Act 2007, together with her SRA or CILEX number and practising status, should you wish to belatedly provide it.

Yours faithfully,

[Full name]

The following as a PDF attachment in an email to the court at CaseProgression.CNBC@justice.gov.uk and CC DCB Legal and yourself:

Quote
Subject: Claim [claim number] – Notice Regarding Signer’s Authority to Conduct Litigation

Dear Sir/Madam,

I write as the Defendant in this matter.

On 28 September 2025, I emailed the Claimant’s solicitors, DCB Legal Ltd, requesting confirmation that the individual who signed the N1SDT Claim Form (“Sarah Ensall – Head of Legal”) is authorised or exempt under the Legal Services Act 2007 to conduct litigation. Preparing and signing an N1SDT is conduct of litigation, as confirmed in Mazur & Anor v Charles Russell Speechlys LLP [2025] EWHC 2341 (KB).

I received no response.

On 3 November 2025, I sent a formal reminder giving DCB Legal three further days to respond.

No reply was received.

In accordance with my warning to them, I now formally place this correspondence before the Court. I respectfully invite the Court to note:

1. The Claimant’s solicitors have failed to provide any confirmation that the signer of the Claim Form is authorised or exempt to conduct litigation.
2. This raises a legitimate issue under the Legal Services Act 2007 concerning potential unauthorised conduct of litigation.
3. I ask the Court, at the appropriate stage, to take this into account when considering compliance and conduct.
4. I also ask the Court to consider whether the Claimant’s prolonged failure to engage with reasonable procedural enquiries amounts to unreasonable conduct for the purposes of CPR 27.14(2)(g), including the costs I have incurred in dealing with this issue as a litigant in person at the rate of £24 per hour.

I confirm that I have simultaneously raised this issue with the Solicitors Regulation Authority.

Yours faithfully,

[Full name]
[Address]
[Email]

In the email, add this to the body:

I am the Defendant in the above claim. Please place the attached notice on the court file.

And to the SRA at report@sra.org.uk and CC yourself:

Quote
Subject: Regulatory Complaint – Potential Unauthorised Conduct of Litigation by DCB Legal Ltd (Claim [claim number])

Dear SRA Investigations,

I wish to raise a regulatory complaint concerning potential unauthorised conduct of litigation by DCB Legal Ltd.

Background
DCB Legal Ltd filed and served a Claim Form (Form N1SDT) in claim [claim number]. The Claim Form was signed by “Sarah Ensall”, described as “Head of Legal”. The form purports to have been signed on behalf of the Claimant’s solicitor.

Preparing, signing, filing or serving an N1SDT constitutes “conduct of litigation”, a reserved legal activity under the Legal Services Act 2007 (LSA 2007). The High Court confirmed in Mazur & Anor v Charles Russell Speechlys LLP [2025] EWHC 2341 (KB) that unqualified employees may assist solicitors but cannot themselves conduct litigation unless authorised or exempt.

Attempts to clarify authorisation

On 28 September 2025, I wrote to DCB Legal requesting confirmation that Ms Ensall is authorised or exempt to conduct litigation, and asked for her SRA or CILEX practising details.

No reply was received.

On 3 November 2025, I sent a formal reminder allowing three further days for a response.

No reply was received.

Both emails are attached.

Reason for complaint
DCB Legal have:

• Filed a Claim Form signed by a person whose authorisation or exemption has not been confirmed.
• Failed to provide any clarification despite two written requests.
• Provided no evidence that the individual signing the claim form has the required authorisation, practising certificate, or statutory exemption under Schedule 3 LSA 2007.

This raises a potential breach of:

• The Legal Services Act 2007 (conducting a reserved legal activity without authorisation or exemption);
• SRA Principles (integrity, accountability, transparency);
• SRA Code of Conduct for Firms (particularly paragraphs 2.1 and 8.1).

I ask the SRA to determine:

1. Whether Ms Ensall is authorised or exempt to conduct litigation;
2. Whether the filing and signing of the N1SDT constituted unauthorised conduct of litigation;
3. Whether DCB Legal and/or any individual has breached the SRA Principles or Code of Conduct.

Please let me know if further documents or clarification are required.

Yours faithfully,

[Full name]
[Postal address]
[Email]
Title: Re: Letter of Claim - DCB Legal
Post by: helenwhite00 on November 12, 2025, 11:01:53 pm
Thanks once again for the info.

I haven’t yet received my own N180, once I do will let you know if any questions.

I did send the follow-up email to DCB Legal on Sarah Ensall last Tuesday but they have not responded so can you let me know how I take this forward with the court…?

Thanks,
Helen.
Title: Re: Letter of Claim - DCB Legal
Post by: b789 on November 03, 2025, 11:51:45 pm
Stop trying to read something into their N180 that isn' there. It is all normal and you will be filing your own.

When you receive your own N180 or your MCOL history shows yours has been sent, just follow this advice:

Having received your own N180 (make sure it is not simply a copy of the claimants N180) or been notified on MCOL that yours has been sent, do not use the paper form. Ignore all the other forms that came with it. you can discard those. Download your own N180 DQ 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.

As DCB Legal have not responded to the email, send the following chaser and let us know if they do not respond within 7 days:

Quote
Subject: Claim [claim number] – Non-response to 28 September correspondence

Dear Sir/Madam,

I wrote to you on 28 September 2025 regarding the N1SDT Claim Form signed “Sarah Ensall – Head of Legal”, requesting confirmation of her authorisation or exemption under the Legal Services Act 2007 to conduct litigation.

You have failed to respond within the seven-day period specified. Please treat this as a formal reminder. Unless a full written response is received within three working days, I will place both emails before the Court and refer the non-compliance to the SRA as part of a regulatory complaint concerning potential unauthorised conduct of litigation.

Yours faithfully,

[Full name]
Title: Re: Letter of Claim - DCB Legal
Post by: helenwhite00 on November 03, 2025, 11:16:31 pm
And link to questionnaire DCB legal attached:

https://helen-white.imgbb.com/


Looks from that DCB Legal either want moderation or for a judge to rule on submitted evidence without an in person hearing.


They also have not responded at all to the email I sent re. Sarah Ensall having signed as an unauthorised person.

Hence if you could advise again on next steps…?
Title: Re: Letter of Claim - DCB Legal
Post by: helenwhite00 on November 03, 2025, 11:05:11 pm
So today I received the following email from bulklitigation@dcblegal.co.uk:


Good Morning

Having reviewed the content of your defence, we write to inform you that our client intends to proceed with the claim.

In due course, the Court will direct both parties to each file a directions questionnaire. In preparation for that, please find attached a copy of the Claimant's, which we confirm has been filed with the Court.

Without Prejudice to the above, in order to assist the Court in achieving its overriding objective, our client may be prepared to settle this case - in the event you wish to discuss settlement, please call us on 0203 434 0433 within 7 days and make immediate reference to this correspondence.

If you have provided an email address within your Defence, we intend to use it for service of documents (usually in PDF format) hereon in pursuant to PD 6A (4.1)(2)(c). Please advise whether there are any limitations to this (for example, the format in which documents are to be sent and the maximum size of attachments that may be received). Unless you advise otherwise, we will assume not.

 
Kind Regards,
Litigation Support
DCB Legal Ltd



Title: Re: Letter of Claim - DCB Legal
Post by: helenwhite00 on September 30, 2025, 11:22:20 pm
Ok think I got it.

I have created a PDF of the defence provided and just added info advised such as claim number and signature.

Then I have combined this with the draft order that did not need any updates and mailed PDF as per instructions.

I have also mailed DCB legal re. authority to conduct litigation.

Will let you know once I hear anything back.

Thanks,
Helen.
Title: Re: Letter of Claim - DCB Legal
Post by: b789 on September 29, 2025, 11:15:48 am
NO!!! You don't need any "scanner"!

Create the defence as a PDF file. You can use something like Word or (if on a Mac) Pages, or any basic word processor to copy and paste what I provided above and just fill in the placeholders where necessary with your full name and the claim number. The draft order I linked to does not require any editing and is already in PDF format.

There is no ned to sign anything being submitted electronically. Simply typing your full name for the signature is sufficient.

When you have edited the defence as necessary, simply save it or export it as a PDF file. Then, you simply email to the address provided with both those PDF files (the defence and the draft order) attached to the email. End of!

Ideally, you should try and merge both PDF files into a single PDF but if you don't know how, then as two separate documents will not matter too much.
Title: Re: Letter of Claim - DCB Legal
Post by: helenwhite00 on September 29, 2025, 01:03:24 am
Thanks again for the information and as I don’t have a PDF scanner have found the online version of N9B form that I assume I can use:

(https://www.moneyclaimsuk.co.uk/PDFForms/N9B.pdf)

Then I fill this in and include along with defence form that I sign as above and convert to PDF.

Thanks,
Helen
Title: Re: Letter of Claim - DCB Legal
Post by: b789 on September 28, 2025, 11:31:50 am
If you cannot get into your MCOL portal, then follow the following advice:

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 [claimant] v [your full name] Claim no.: [claim number]."

Quote
IN THE COUNTY COURT
Claim No: [Claim Number]

BETWEEN:

Euro Car Parks 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)

As for the fact that the Claim Form has been signed by an unauthorised person, send the following email to info@dcblegal.co.uk and CC yourself:

Quote
Subject: Claim [claim number] – N1SDT Claim Form signed by 'Head of Legal', authority to conduct litigation

Dear Sir/Madam,

I refer to the Claim Form with the Particulars of Claim (Form N1SDT) filed/served in this claim. It is signed “Sarah Ensall”, position “Head of Legal”, and purports to be signed on behalf of the claimant’s solicitor.

Please confirm by return:

Ms Ensall's, capacity, and whether they are an authorised person within the meaning of the Legal Services Act 2007 with current rights to conduct litigation (provide SRA/CILEX number and practising status). If not authorised,
The precise exemption relied upon under Schedule 3 of the Legal Services Act 2007 that permits that individual to conduct litigation and sign the NSDT in these proceedings (enclose the sealed court order or the specific statutory provision, as applicable).

For the avoidance of doubt:

• Preparing, signing, filing or serving an N1SDT is conduct of litigation.
• Following Mazur v Charles Russell Speechlys LLP, 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, file and serve a compliant N1SDT personally signed by an authorised person, with their full name clearly stated.

Costs and regulatory notice:

If the N1SDT was signed by a person not authorised or exempt, or must be re-filed/served to correct the signer’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, conducting 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 SRA without further notice and reserve all rights to place this correspondence before the Court.

Yours faithfully,

[Full name]
[Postal address]
[Email]
Title: Re: Letter of Claim - DCB Legal
Post by: helenwhite00 on September 27, 2025, 09:15:34 pm
Thank you and yes the claim is signed as per link below by Sarah Ensall:
https://imgur.com/a/umyJS2Y

Also I have gone to look at the claim online, also picture should be in above link, as online portal does not seem to recognise claim number.

Does this mean I need to submit paper forms and if so can I submit a separate sheet fr defence so I can copy and paste information directly from your post?

Thanks,
Helen
Title: Re: Letter of Claim - DCB Legal
Post by: b789 on September 27, 2025, 11:55:43 am
No need, at this point. This will never get as far as a hearing. If it ever did, which it won't, they would have to give a witness statement which is where you can challenge anything they claim. For now, the Particulars of Claim (PoC) are defective.

The PoC must give a concise reason for the claim and you must be able to understand the claim fully from those PoC. You have to imagine that you know nothing at all about this claim and the very first you know about it is the PoC.

They cannot argue that you should have known about it from previous correspondence. The actual PoC must give enough information for you to be able to plead a defence. If you read the defence provided (authored with the assistance of a long serving district judge) you will see that the only defence that can be made is that a proper defence cannot be pleaded because of the defective PoC which are in breach of CPR 16.4.

These bulk litigation companies could, if they wanted to, submit further more detailed PoC within 14 days of service of the claim. They choose not to. They are relying on the hope that you are low-hanging fruit on the gullible tree and can be intimidated into paying up out of ignorance and fear. Sadly, the vast majority of recipients of a claim will either bury their heads in the sand or screw up on how to respond and the Claimant gets a judgement in default. These bulk litigators issue hundreds of thousands of these small claims every year.

Of the minority of cases that manage to find their way here for advice, preferably before any response has been made, we successfully advise almost every single one to a successful conclusion. In the majority of cases, it ends with a discontinuation. Some are struck out and of the very few that ever get as far as a hearing in front of a judge, most of those are won.

So, for now, just do as advised and if it ever gets to the point you need to mention the fact that you paid £100, I will eat my hat and assist you on how to put that point across in your witness statement.

Can you please confirm whether the N1SDT Claim Form with the PoC was signed by Sarah Ensall as 'Head of Legal'? IF so, I have further advice for you which will put DCB Legal on the back foot. She is not authorised to conduct litigation and is in breach of the Legal Services Act 2007, which is a criminal offence. You can require them to cure the defect by having the claim reissued once signed by someone who is authorised to conduct litigation and also report them to the SRA for the LSA breach. This is all due to a very recent binding high court appeal case that finally confirmed that anyone conducting litigation must be authorised, as it is a reserved legal activity. Up until now, these firms have been using unauthorised individuals who think that they can conduct litigation under the supervision of their solicitor. They cannot.
Title: Re: Letter of Claim - DCB Legal
Post by: helenwhite00 on September 26, 2025, 06:03:50 pm
Thank you for the information and I will use it and submit the electronic form this weekend.

I did have one question, should I not put anywhere in the defence that I have already actually paid £100 as if it did go any further I would want to use that…?

Thanks,
Helen
Title: Re: Letter of Claim - DCB Legal
Post by: b789 on September 24, 2025, 12:23:05 pm
With an issue date of 16th September you have until 4pm on Monday 6th October to submit your defence. If you submit an Acknowledgement of Service (AoS) before then, you would then have until 4pm on Monday 20th October to submit your defence.

You only need to submit an AoS if you need extra time to prepare 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

DO NOT use the paper forms in the claim pack.

Until very recently, we never advised using the MCOL to submit a defence. However, due to recent systemic failures within the CNBC, we feel that it is safer to now submit a short defence using MCOL as it is instantly submitted and entered into the "system". Whilst it will deny the use of some formatting or inclusion of transcripts etc. these can always be included with the Witness Statement (WS) later, if it ever progresses that far.

You will need to copy and paste it into the defence text box on MCOL. It has been checked to make sure that it will fit into the 122 lines limit.

Quote
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 adequately 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 PD 16, para 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 submits that courts have previously struck out materially similar claims of their own initiative for failure to adequately comply with CPR 16.4, particularly where the Particulars of Claim failed to specify the contractual terms relied upon or explain the alleged breach with sufficient clarity.

5. In comparable cases involving modest sums, judges have found that requiring further case management steps would be disproportionate and contrary to the overriding objective. Accordingly, strike-out was deemed appropriate. 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 due to the Claimant’s failure to adequately comply with CPR 16.4, rather than permitting an amendment. The Defendant proposes that the following Order be made:

Draft Order:

Of the Court's own initiative and upon reading the particulars of claim and the defence.

AND the court being of the view that the particulars of claim do not adequately comply with CPR 16.4(1)(a) because: (a) they do not set out the exact wording of the clause (or clauses) of the terms and conditions of the contract which is (or are) relied on; and (b) they do not adequately set out the reason (or reasons) why the claimant asserts that the defendant was in breach of contract.

AND the claimant could have complied with CPR 16.4(1)(a) had it served separate detailed particulars of claim, as it could have done pursuant to PD 7C, para 5.2, but chose not to do so.

AND upon the Court determining, having regard to the overriding objective (CPR 1.1), that it would be disproportionate to direct further pleadings or to allot any further share of the Court’s resources to this claim (for example by ordering further particulars of claim and a further defence, with consequent case management).

ORDER:

1. The claim is struck out.

2. Permission to either party to apply to set aside, vary or stay this order by application on notice, which must be filed at this Court not more than 7 days after service of this order, failing which no such application may be made.
Title: Re: Letter of Claim - DCB Legal
Post by: helenwhite00 on September 23, 2025, 10:50:32 pm
Thank you and claim form / link to it

https://imgur.com/a/v9lQiPY (https://imgur.com/a/v9lQiPY)

If forum could help me with what I should put for my defence (and do I tick the box I am disputing it as already paid as in that case you just add the payment details and don’t fill in the other defence section?)
 
Also I best to do it online or fill in the paper forms and send back?

Thanks,
Helen
Title: Re: Letter of Claim - DCB Legal
Post by: DWMB2 on September 23, 2025, 10:43:37 pm
So first thing is can someone advise how I can attach?
See this guide: READ THIS FIRST - Private Parking Charges Forum guide (https://www.ftla.uk/private-parking-tickets/read-this-first-private-parking-charges-forum-guide/)
Title: Re: Letter of Claim - DCB Legal
Post by: helenwhite00 on September 23, 2025, 10:42:29 pm
Further to above, I have now received the court documents and have taken a photo of the main claim form page with the parts noted in above response redacted.

However I can’t see any option to attach it as under attachments and other options I only have notify me of replies, return to his topic and dont use smilies no actual attachment option…?

So first thing is can someone advise how I can attach?

Thanks,
Helen.
Title: Re: Letter of Claim - DCB Legal
Post by: helenwhite00 on August 11, 2025, 10:08:31 am
Ok thank you again, feeling better after reading all info posted and I won’t do anything more now until I the  N1SDT Claim form or further correspondence.
Title: Re: Letter of Claim - DCB Legal
Post by: b789 on August 10, 2025, 12:24:00 pm
DCB Legal’s “reply” is just a padded-out template that skirts around most of the requests in your Letter of Claim rebuttal.

Key points from what’s happened so far:

• They’ve ignored the partial payment issue — this is important because they’ve not acknowledged the fact the balance they are claiming is disputed and already reduced. That omission can be used later to show unreasonable conduct.
• They’ve cherry-picked what to disclose — they admit refusing some items on grounds of “disproportionate and/or not relevant”, but that will play badly if they later try to rely on evidence they’ve withheld.
• Their “Britannia v Semark-Julien” citation is misleading — that County Court appeal only dealt with the £60–£70 add-on not being automatically struck out, it didn’t give operators a blank cheque to add it. It has no binding effect and is still contrary to the MLCHG’s stance and the Private Parking (Code of Practice) Act 2019.
• They’ve framed it as a breach-of-contract claim — that will be used to pin them to later, especially with their usual defective Particulars of Claim (PoC).
• They’ve conceded the £70 add-on is not VAT-inclusive — which confirms it’s not a genuine service cost but an arbitrary sum (another angle for abuse of process).
• No signage proof — they’ve admitted sending only “images of the signs” without a site plan or contemporaneous photos from the material date, which was one of your explicit requests under the Protocol.

Given your concern about avoiding court, paying now would mean you lose the ability to challenge and you’d be rewarding them for ignoring the Protocol. When the claim is issued and defended properly using our template, the likelihood of it reaching a hearing is vanishingly small — and even if it did, the risks are limited to the claimed sum plus capped court costs, not scary criminal penalties.

You don’t have to give them a phone number — keep everything in writing, preferably email, for a clear paper trail.

Just file that response from the utter incompetents at DCB Legal and you now wait for the N1SDT Claim Form to arrive in the post. When you receive it, we only need to see the main claim form page with the Particulars of Claim (PoC). Only redact your personal info, the claim number and the MCOL password. Leave everything else visible, especially ALL dates. We will provide you with precise details and deadlines on how to respond.

I remind you that no one who follows this advice goes to court or pays a penny to ECP.
Title: Re: Letter of Claim - DCB Legal
Post by: helenwhite00 on August 10, 2025, 12:20:19 am
Hi All,

Thanks again for the advice and hence I won’t be paying as I definitely dont want to pay twice so my next question is do I respond to their latest letter or just was for the court papers and then come back here once they arrive to get advice on how to proceed with them…?

Thanks,
Helen
Title: Re: Letter of Claim - DCB Legal
Post by: b789 on August 09, 2025, 09:30:42 am
No one who follows the advice goes to court over a claim issued by DCB Legal. The whole process is designed to get the low-hanging fruit on the gullible tree to pay up out of ignorance and fear. You appear to be a classic example of this by your insistence on paying further into the scam and therefore becoming a part of the problem rather than just standing up for your rights.

The odds of you actually going to court, which you appear to imagine is something along the lines of wigs and robes and the Old Bailey, is nothing to be feared. If you really want to see what "court" in a. civil matter involves, even though you have a less than 0.1% chance of even having to attend, have a look at this short video:

https://youtu.be/n93eoaxhzpU?feature=shared

This is not a criminal matter. It is a civil matter and the whole process id different. However, all that is not even relevant because the actual odds of ANY claim issued by DCB Legal seeing the inside of a courtroom is less than 0.1%.

You can defend any claim issued by them with a nursery rhyme for anyone cares and you can guarantee that they will discontinue before they have to pay the £27 trial fee. I have a standing bet for anyone here to take my offered odds of 100:1 that any single PCN claim issued by the utter incompetents at DCB Legal, that is defended using the advice given here will not continue beyond the trial fee deadline that will be issued by the court later in the process. No one has taken me up on the offer. If you do a search of the forum, you may see why.

It is your money and I don't doubt that you have plenty to spare in order to waste it by funding a scam that has been explained to you, but please don't waste our time after we have advised you on how this process works. We are not wet behind the ears keyboard warriors. We have been providing advice that leads to a success rate in defeating these unfair PCNs for many years.

As for your question about providing your phone number, of course you do not have to provide it and you are actively advised not to do so. Just make sure that all correspondence is conducted by email, as it is instant and you have proof of sending/delivery.

Their response to your response to the LoC is boilerplate and means nothing. They ARE going to issue the N1SDT Claim Form. When they do, just show it to us and we will advise on any deadlines and provide you with instructions on how to acknowledge it and also provide you with the defence. They will, in due course see the claim struck out or they will discontinue.
Title: Re: Letter of Claim - DCB Legal
Post by: jfollows on August 09, 2025, 07:52:47 am
If you follow the advice you will get here, you will not go to court.

You will receive court paperwork, attend a meaningless telephone mediation session, submit a defence, and have the case allocated to a court local to you.

On the day the court fee needs to be paid, DCB Legal will discontinue.

You came here for advice, so either you can take it knowing that we know what we’re talking about, or you can fall for the threats from DCB Legal, cave in and pay up. Why do you think they do what they do? But if you’re going to do this, then please tell us and we won’t need to help you any more.

You’ve already fallen for debt collectors and paid them £100.
Title: Re: Letter of Claim - DCB Legal
Post by: helenwhite00 on August 09, 2025, 12:42:36 am
Hi All,

Further to above I have now received the following response from DCB Legal so please can anyone advise how I should respond to this, is there a standard response….?

As previously noted I don’t want to go to court so again I wonder if it is easier (as I have the funds) to pay this to avoid going to court, which I know based off info in this forum unlikely but always possible, however I have already paid £100 (which I note they have not commented on) and I would rather not pay twice either.

Additionally I don’t want to provide my phone number as don’t want them calling me and think everything should be in writing…

Hence any further advice would be much appreciated.

Thanks in advance.

Note: They also included pictures of the car / number plate and the final letter from Euro Car Parks before they passed it onto debt collection, however they did not provide any proof of signage and although they provided my entry and exit time no details of how long I actually overstayed.




Dear Helen Elizabeth White,

 

We write in response to your correspondence received in our office dated 27th June 2025.   

 

We have made a record of the contents of your correspondence and noted this on your file accordingly. We now respond to the same as follows.

 

Prior to the issue of the parking charge, our Client applied to the DVLA for the details of the Registered Keeper of the Vehicle. Your name and address (My address here) were provided. Our Client therefore correctly issued correspondence to you at that address. Having not received payment, address verification was carried out prior to the Letter of Claim being sent. Your address was located and as such the Letter of Claim was issued to you at the traced address, which has remained unchanged.

 

The parking charge was not affixed to the vehicle because our client utilises Automatic Number Plate Recognition (“ANPR”) technology on the land where the parking charge was issued in order to manage the parking. This means that cameras capable of accurately recognising the vehicle registration number of a vehicle are constantly monitoring the entrance and exit to the land.  A photograph is taken of each vehicle as it enters and exits the land. Any vehicle found to have breached the terms of parking will be issued with a parking charge via the post.

 

When parking on private land, the contractual terms of the site are set out on the signs. You are entering a contract and agreeing to the terms by parking and staying on the site. Parking in breach of the terms as stipulated on the signage means that you are then breaking the terms of the contract. The breach in contract would make you liable for a parking charge.

 

The signage on site, is erected in line with our Clients regulators (BPA) in order to allow a reasonable driver to be notified of the terms and conditions operating on the site prior to them parking their vehicle. As such the signage on site, is sufficient given the size and capacity of the car park. Images of the signs are enclosed.

 

The terms and conditions on the signs stated that parking was permitted for vehicles clearly displaying a valid permit/ticket, covering their full time on the site or otherwise a parking charge notice would be issued. A valid permit/ticket was not on display for your full duration on the car park site on the date of contravention and as such the parking charge was issued correctly.
 
You should always be vigilant when entering any land that you are not familiar with or that you know is privately owned and there are parking terms in place. As the driver of the vehicle it is your responsibility at all material times to ensure you understand the terms and conditions operating on the land prior to exiting your vehicle. Furthermore, it is your responsibility to ensure that you have read and understood the terms operating prior to parking your vehicle.   

 

The Notice to Keeper was issued to you on 24th October 2023. You were afforded the opportunity to; appeal the parking charge, transfer liability to the driver (if it was not you) or make payment. Neither a successful appeal, nor an adequate nomination were received, yet payment remains outstanding. 

 

The Reminder Notice was issued to you on 23rd November 2023. This notice reiterated that payment was outstanding and confirmed that legal action may be taken and additional costs incurred if the parking charge was not paid.     

 

In regard to the debt recovery fee of £70.00 being claimed, you would have been made aware of this through the signs available on the car parks site as previously mentioned above. This does not include any VAT. The HMRC ‘VAT Supply and Consideration manual’ (VATSC06140), which was last updated on 02 September 2020, confirmed that parking charge notices falls out of the scope of VAT. There is no requirement for a VAT invoice to be issued to you.       

 

Further to the above, in accordance with the appeal decision made on 29th July 2020 in Britannia Parking Group Ltd v Semark-Julien [2020] EW Mis 12 (CC), it is not correct to propose this claim should be struck out as an ‘abuse of process’ due to the contractual costs claimed.       

 

With reference to the above, this parking charge is being pleaded as a breach of contract to which damages are payable in light of the matters raised in this correspondence.

 

If there are any documents that you have requested, but that are not enclosed with this letter, it is because we have deemed the request to be disproportionate and/or not relevant to the substantive issues in dispute. We respectfully draw your attention to paragraph 2.1(c) of the Protocol and remind you that both parties are expected to act reasonably and proportionately.

 

You may wish to seek independent legal advice in this regard. Our client pursuing this matter through the Small Claims Court is the correct course of action.

 

DCB Legal have been instructed as all previous attempts to resolve the matter have been unsuccessful.

 

You now have 30 days from the date of this email/letter to make payment of £170.00. Failure to make payment will result in a Claim being issued against you without any further reference.


Payment can be made via bank transfer to our designated client account: -

 

Account Name: DCB Legal Ltd Client Account
Sort Code: 20-24-09
Account Number: 60964441
 

You must quote the correct case reference (711200094142ECPL) when making payment. If you do not, we may be unable to correctly allocate the payment. If further action is taken by us as a result of an incorrect reference being quoted, you will be liable for any further fees or costs incurred.

 

We would ask that you kindly furnish us with your most up to date telephone number and email address, this can be emailed to us at info@dcblegal.co.uk.

 

Alternatively, you can contact DCB Legal Ltd on 0203 838 7038 to make payment over the telephone or online at https://dcblegal.co.uk/response/pay-online/.

Kind Regards,
 
<Name>
Administration Associate
DCB Legal Ltd
Title: Re: Letter of Claim - DCB Legal
Post by: helenwhite00 on June 25, 2025, 04:55:36 pm
Thank you so much for your response and the great information, much appreciated 🤩.

I have not yet sent my response and so will use your letter and email it to info@dcblegal.co.uk and will update once I hear back from them.

Reading your response as well, you are so right and can’t believe how idiotic I was not thinking about what I was posting online 😳
Title: Re: Letter of Claim - DCB Legal
Post by: b789 on June 25, 2025, 11:38:33 am
No idea where you got any previous advice but whoever gave it to you has SNAFU'd this for you. A classic example of the low-hanging fruit on the gullible tree paying up out of ignorance and fear. I just hope you haven't yet sent that response to the Letter of Claim (LoC).

Besides showing incredible naivety by not redacting your personal details and bank account details in the attached letter you say you want to send to DCB Legal, you are at extremely high risk of having your identity stolen. I have reported the post to the moderator for them to remove your pdf attachment which is an invitation for someone to steal your identity and empty your bank account!!!!

Thankfully, if you follow the advice, you won't be paying another penny to DCB Legal or their client as we are familiar with the M.O. of DCB Legal.

Use the following as your response to the LoC and you EMAIL it to info@dcblegal.co.uk and you also CC yourself. No attachments or anything else, especially items that contain your personal data and bank account numbers etc!!!!

Quote
Dear Sirs,

Your Letter Before Claim contains insufficient detail of the claim and fails to provide copies of evidence your client places reliance upon and thus is in complete contravention of the Pre-Action Protocol for Debt Claims. I note your attempt to pursue a sum which has already been part-paid and remains disputed. Your LoC fails on multiple procedural counts, and until you correct these failings, this matter is not ripe for litigation. My formal position is set out below.

Because your letter lacks specificity and breaches the requirements of the Pre-Action Protocol for Debt Claims (paragraphs 3.1(a)-(d), 5.1 and 5.2) as well as the Practice Direction - Pre-Action Conduct (paragraphs 6(a) and 6(c)), you must treat this letter as a formal request for all of the documents/information that the protocol now requires your client to provide. Your client must not issue proceedings without complying with that protocol.

As solicitors you must surely be familiar with the requirements of both the Practice Direction and the Pre-Action Protocol for debt claims and your client, as a serial litigator of debt claims, should likewise be aware of them. As you (and your client) must know, the Practice Direction and Protocol bind all potential litigants, whatever the size or type of the claim. Its express purpose is to assist parties in understanding the claim and their respective positions in relation to it, to enable parties to take stock of their positions and to negotiate a settlement, or at least narrow the issues, without incurring the costs of court proceedings or using up valuable court time. It is embarrassing that a firm of Solicitors are sending a consumer a vague and un-evidenced 'Letter of Claim' in complete ignorance of the pre-existing Practice Direction and the Pre-Action Protocol.

I confirm that, once I am in receipt of a Letter Before Claim that complies with the requirements of para 3.1 (a) of the Pre-Action Protocol, I shall then seek advice and submit a formal response within 30 days, as required by the Protocol. Thus, I require your client to comply with its obligations by sending me the following information/documents:

1. An explanation of the cause of action
2. whether they are pursuing me as driver or keeper
3. whether they are relying on the provisions of Schedule 4 of POFA 2012
4. what the details of the claim are; for how long it is claimed the vehicle was parked, how the monies being claimed arose and have been calculated
5. Is the claim for a contractual breach? If so, what is the date of the agreement? The names of the parties to it and provide to me a copy of that contract.
6. If the claim is for a contractual breach, photographs showing the vehicle was parked in contravention of said contract.
7. Is the claim for trespass? If so, provide details.
8. Provide me a copy of the contract with the landowner under which they assert authority to bring the claim, as required by the BPA/IPC Private Parking Single Code of Practice (PPSCoP).
9. a plan showing where any signs were displayed
10. Photographs of the signs displayed (size of sign, size of font, height at which displayed) at the time of any alleged contravention.
11. Provide details of the original charge, and detail any interest and administrative or other charges added
12. Am I to understand that the additional £70 represents what is dressed up as a 'Debt Recovery' fee, and if so, is this nett or inclusive of VAT? If the latter, would you kindly explain why I am being asked to pay the operator’s VAT?
13. With regard to the principal alleged PCN sum: Is this damages, or will it be pleaded as consideration for parking?

I am clearly entitled to this information under paragraphs 6(a) and 6(c) of the Practice Direction. I also need it in order to comply with my own obligations under paragraph 6(b).

If your client does not provide me with this information then I put you on notice that I will be relying on the cases of Webb Resolutions Ltd v Waller Needham & Green [2012] EWHC 3529 (Ch), Daejan Investments Limited v The Park West Club Limited (Part 20) Buxton Associates [2003] EWHC 2872, Charles Church Developments Ltd v Stent Foundations Limited & Peter Dann Limited [2007] EWHC 855 in asking the court to impose sanctions on your client and to order a stay of the proceedings, pursuant to paragraphs 13, 15(b) and (c) and 16 of the Practice Direction, as referred to in paragraph 7.2 of the Protocol.

Until your client has complied with its obligations and provided this information, I am unable to respond properly to the alleged claim and to consider my position in relation to it, and it is entirely premature (and a waste of costs and court time) for your client to issue proceedings. Should your client do so, then I will seek an immediate stay pursuant to paragraph 15(b) of the Practice Direction and an order that this information is provided.

Yours faithfully,

[Your name]

This will end up with a claim being issued but, as I said, if you follow our advice, the claim will either be struck out or discontinued in due course.
Title: Letter of Claim - DCB Legal
Post by: helenwhite00 on June 25, 2025, 05:11:27 am
Hi All, 


Posting for first time in this forum as I have got a letter before claim from DCB legal. 


Backstory is that I paid but overstayed in Birmingham car park in Oct 2023 and initially ignored letters from the actual car park company and then once one came from Debt Recovery Plus, I paid the £100 in April of 2024 but refused to pay the additional £70 for the automated letters as wanted to get the issue resolved and hoped it would do that. 


Didn’t hear anything for around 10 months so thought issue was finished but then got a letter from DCBL (Debt Collection Bailiffs Ltd demanding for full £170) in February 2024, I emailed them explaining the situation and providing bank statement of £100 paid along with the letter from Debt Recovery Plus and had some back and forth but basically did not get resolved and now have gotten a letter before claim from DCB legal. 


I have seen some similar threads, but are mainly when completely refuting responsibility, not seen anything for this sort of scenario.  I believe I am best to respond via email attaching a PDF letter and cc’ing myself so I have drafted a letter as below and any feedback on this before I send would be much appreciated. 


DCB legal they ask in their letter that I complete a reply form and financial statement but I do not want to provide them with any financial information so am I OK not to do this and not to respond to that request in my letter and also is it OK to proceed in this way and not fill in a rely form as I want to send via email with proof of delivery and I also don’t want to add my phone number which is required in the reply form…? 


I obviously don’t want to pay the £100 again and the £70 but I am terrified of going to court as I get really nervous with any sort of public speaking, even if I just have to do a presentation in a virtual meeting so I am not sure if I am best just to pay (as I have the available funds) if DBB Legal choose to go to court and not drop the issues. 


Hence can anyone advise what will happen next and if DBB Legal usually drop these matter or if they will go through with an actual court case (it sounds from forums though they do usually proceed initially but may drop before it gets to actual court appearance…? 


I have also heard of the term right of audience which I think means they have to send a solicitor which would be costly vs, what they could likely claim and so is that correct and could that be a motivation for them to drop it before the actual court appearance if I don’t pay…? 



Attached is letter I have drafted in response to DCB legal.

Thank you.