Free Traffic Legal Advice

Live cases legal advice => Private parking tickets => Topic started by: Dandalf on August 09, 2025, 05:33:14 pm

Title: Re: BaySentry Solutions Ltd - No parking permit
Post by: b789 on October 26, 2025, 03:33:48 pm
The very good news is that because this claim has been filed by DCB Legal, as long as it is defended, it will in due course,mine discontinued just before they are required to pay the £27 trial fee, after it has been allocated to your local county court.

I will not be dealing with the lease or their rights at this stage as the standard statutory failures in their Particulars of Claim (PoC) are enough to win. In the highly unlikely event that this were to ever proceed to a hearing (less than 1% chance) you can introduce the lease failures as rebuttal points to their witness statement, which is extremely unlikely to happen.

With an issue date of 15th October you have until 4pm on Monday 3rd November to submit your defence. If you submit an Acknowledgement of Service (AoS) before then, you would then have until 4pm on Monday 17th November 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

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: BaySentry Solutions Ltd - No parking permit
Post by: b789 on October 26, 2025, 03:22:19 pm
I will come back to this and provide the deadlines and how to respond to the claim. However, just to put your mind at ease, there is zero chance of getting a CCJ and it will not affect your “credit file” even if you were to receive one, as long as it is paid in full within 30:days of judgment.

Nothing we advise on here will affect your credit record. Here is some education about how CJJs happen:

Quote
A County Court Judgment (CCJ) does not just happen—it follows a clear legal process. If someone gets a Parking Charge Notice (PCN) from a private parking company, here's what happens step by step:

1. Parking Charge Notice (PCN) Issued

• The parking company sends a letter (Notice to Keeper) demanding money.
• This is not a fine—it’s an invoice for an alleged breach of contract.

2. Opportunity to Appeal

• The recipient can appeal to the parking company.
•If rejected, they may be able to appeal to POPLA (if BPA member) or IAS (if IPC member).
• If an appeal is lost or ignored, the parking company demands payment.

3. Debt Collection Letters

• The parking company might send scary letters or pass the case to a debt collector.
• Debt collectors have no power—they just send letters and can be ignored.
No CCJ happens at this stage.

4. Letter Before Claim (LBC)

• If ignored for long enough, the parking company (or their solicitor) sends a Letter Before Claim (LBC).
• This is a warning that they may start a court case.
• The recipient has 30 days to reply before a claim is filed.
No CCJ happens at this stage.

5. County Court Claim Issued

• If ignored or unpaid, the parking company may file a claim with the County Court.
• The court sends a Claim Form with details of the claim and how to respond.
• The recipient has 14 days to respond (or 28 days if they acknowledge it).
No CCJ happens at this stage.

6. Court Process

• If the recipient defends the claim, a judge decides if they owe money.
• If the recipient ignores the claim, the parking company wins by default.
No CCJ happens yet unless the recipient loses and ignores the court.

7. Judgment & Payment

• If the court rules that money is owed, the recipient has 30 days to pay in full.
• If they pay within 30 days, no CCJ goes on their credit file.
• If they don’t pay within 30 days, the CCJ stays on their credit file for 6 years.

Conclusion

CCJs do not appear out of thin air. They only happen if:

• A parking company takes the case to court.
• The person loses or ignores the case.
• The person fails to pay within 30 days.

If you engage with the process (appeal, defend, or pay on time), no CCJ happens.
Title: Re: BaySentry Solutions Ltd - No parking permit
Post by: Dandalf on October 26, 2025, 01:40:56 pm
In England and Wales a tenant has no automatic right to a free copy of the head lease from the letting agent, and the agent has no general statutory duty to supply it. However, if your tenancy agreement purports to bind you to comply with terms of the head lease (or the parking rules arise under that head lease), it is reasonable to request the relevant extracts. Many agents/landlords will provide those parts (rights granted, regulations, plans).

If they won’t, the practical route is to obtain an official copy from HM Land Registry yourself. It’s inexpensive and avoids delay.

Hello, me again!

A few updates:


Amongst the list of 'particulars of claim' on the N1SDT, the defendant is pursued as the keeper or the driver of the vehicle.
To be absolutely clear here, the driver is not the owner/keeper of the vehicle. But they do have ability to drive the vehicle (full license and included on the insurance) but they were not the driver at the time of the incident occurring.
Does this change anything?


To put minds at rest, the defendant is obviously scared of receiving some kind of CCJ or mark against their credit file should this go to court etc. Under what circumstances would a CCJ on the credit file be given as obviously want to avoid that but also fight these scumbags if possible and you believe worthwhile?


Could you please advise on next steps, given the 1. Title registry attached, 2. the N1SDT and particulars of the case, 3. and fear of CCJ?

Thank you so much as always for helping!
Title: Re: BaySentry Solutions Ltd - No parking permit
Post by: b789 on September 09, 2025, 06:24:52 pm
In England and Wales a tenant has no automatic right to a free copy of the head lease from the letting agent, and the agent has no general statutory duty to supply it. However, if your tenancy agreement purports to bind you to comply with terms of the head lease (or the parking rules arise under that head lease), it is reasonable to request the relevant extracts. Many agents/landlords will provide those parts (rights granted, regulations, plans).

If they won’t, the practical route is to obtain an official copy from HM Land Registry yourself. It’s inexpensive and avoids delay.
Title: Re: BaySentry Solutions Ltd - No parking permit
Post by: Dandalf on September 09, 2025, 02:40:08 pm
You can safely ignore all debt recovery letters. Debt collectors are powerless to actually do anything except to try and persuade the low-hanging fruit on the gullible tree to pay up out of ignorance and fear.

Okay that's a relief to know, thank you for the response.

Should the tenant be paying for the headlease from land registry at this point or should this be something the Letting Agent has to supply?
We're still stumped on who has what obligations.

To be clear also regarding this case, the tenant is not the owner of the vehicle.
Title: Re: BaySentry Solutions Ltd - No parking permit
Post by: b789 on September 04, 2025, 09:56:22 am
You can safely ignore all debt recovery letters. Debt collectors are powerless to actually do anything except to try and persuade the low-hanging fruit on the gullible tree to pay up out of ignorance and fear.
Title: Re: BaySentry Solutions Ltd - No parking permit
Post by: Dandalf on September 03, 2025, 06:08:25 pm
I have reviewed the tenancy agreement and here are the key points relevant to whether the landlord, their agent, or a third-party parking company could require the display of a parking permit and issue PCNs:

1. No express clause about parking permits or parking enforcement

• The agreement does not contain any clause authorising the landlord, their agent, or a third party to require the display of a parking permit, nor does it mention parking charges, penalties, or PCNs.

2. References to "parking permits"

• Clause 1.8.4.2 requires the tenant to return "all keys, access devices, remote controls and parking permits" at the end of the tenancy.
• Clause 4.3.14 repeats that all "keys, access devices, remote controls and parking permits" are to be returned at the end of possession.

These references only confirm that a parking permit may exist; they do not create an obligation to display one, nor do they authorise enforcement action for non-display.

3. Tenant obligations and covenants

• The agreement obliges the tenant to observe covenants in any headlease (Clause 4.3.25) but specifically excludes rent and service charge payments.



Unless the headlease itself requires permit display and empowers third-party enforcement, this clause does not grant such rights.

4. Third party rights

• Clause 1.9 explicitly states that “no clause of this agreement may be enforced by any third party, other than the Landlord’s Agent, pursuant to the Contracts (Rights of Third Parties) Act 1999.”

This prevents a third-party parking company from relying on the tenancy agreement itself to enforce PCNs.

5. Quiet enjoyment

• Clause 5.2 guarantees the tenant “quiet enjoyment of the Property during the tenancy without any unlawful interruption from the Landlord or any person lawfully claiming under or in trust for the Landlord.”

Any third-party enforcement interfering with parking rights could be challenged as a breach of this covenant, unless clearly authorised.

Conclusion

The tenancy agreement does not grant authority for the landlord, their agent, or a third-party parking operator to require permit display or issue PCNs for failure to display.

• The only mentions of “parking permits” are administrative (returning them at tenancy end).
• Enforcement rights by a third party are explicitly excluded.
• Unless the headlease (not provided here) contains a parking enforcement covenant, no lawful basis exists in this agreement for a third-party operator to impose or enforce PCNs.

So, without seeing the headless, it is not conclusive. However, you should be aware of the following points:

• Your tenancy imports headlease covenants only if provided, and they exclude rent/service charge obligations. If you haven’t been given the headlease, you cannot be bound by unnotified permit obligations.
• Even if the headlease says “subject to regulations”, courts require regulations to be reasonable and consistent with the grant. A right to park is not extinguished by a failure to display a flimsy permit.
• Contracts (Rights of Third Parties) Act 1999 exclusion (Clause 1.9) blocks a parking company from claiming direct enforcement rights under this tenancy.
• Any PCN regime imposed on a lawful tenant with parking rights is likely to be an unlawful derogation from grant and/or breach of quiet enjoyment.

I think it would be wise to try and get sight of the headlease.

b789 correctly notes that there aren't any clauses that would seem to create any agreement with BaySentry. The only thing that gives me some reservation is that none of what you have shown us would seem to conclusively provide a right to park. The mention of parking permits would certainly allude to parking being included in your lease, but ideally something confirming that parking is provided would do no harm.

Are the bays numbered, or are there just a series of spaces, of which any may be used? If the latter, the references to use of 'common parts' might be of relevance.


Hi both/all,

Along with the Letting Agent not supplying the head lease (as detailed in post above) the tenant has now received a letter from DCBL (Direct Collection Bailiffs Ltd) with a "final reminder".

What are the appropriate next steps?

Many thanks,
Dam
Title: Re: BaySentry Solutions Ltd - No parking permit
Post by: Dandalf on August 29, 2025, 08:14:26 pm
Hi all - happy Friday!


So the tenant reached out to their Letting Agent who then had to request the headlease from someone else (unknown except abbreviation "PBM" in reply). Once the Letting Agent received a reply from "PBM" they've forwarded it to the tenant:

I am presuming they means their lease rather than the Head Lease, we don’t hold individual copies but their lawyer will have access to the land registry site and all leases will be able to be downloaded.


Is this an acceptable response, should they be providing the headlease? It seems like something they should provide upon request, plus it looks as if the tenant would have to purchase their own lease from Land Registry otherwise?


Thanks for all help as always.
Cheers,
Dan
Title: Re: BaySentry Solutions Ltd - No parking permit
Post by: Dandalf on August 18, 2025, 06:24:21 pm
Thanks for your detailed responses, both.

I didn't even know what a headlease was, I had to Google it. I'll ask the tenant to request it from the Letting Agent so we have more information.

Yeah, the bays are numbered with one bay assigned to each house or flat.


Best wishes,
Danny
Title: Re: BaySentry Solutions Ltd - No parking permit
Post by: DWMB2 on August 18, 2025, 06:07:52 pm
I think it would be wise to try and get sight of the headlease.

b789 correctly notes that there aren't any clauses that would seem to create any agreement with BaySentry. The only thing that gives me some reservation is that none of what you have shown us would seem to conclusively provide a right to park. The mention of parking permits would certainly allude to parking being included in your lease, but ideally something confirming that parking is provided would do no harm.

Are the bays numbered, or are there just a series of spaces, of which any may be used? If the latter, the references to use of 'common parts' might be of relevance.
Title: Re: BaySentry Solutions Ltd - No parking permit
Post by: b789 on August 18, 2025, 05:54:56 pm
I have reviewed the tenancy agreement and here are the key points relevant to whether the landlord, their agent, or a third-party parking company could require the display of a parking permit and issue PCNs:

1. No express clause about parking permits or parking enforcement

• The agreement does not contain any clause authorising the landlord, their agent, or a third party to require the display of a parking permit, nor does it mention parking charges, penalties, or PCNs.

2. References to "parking permits"

• Clause 1.8.4.2 requires the tenant to return "all keys, access devices, remote controls and parking permits" at the end of the tenancy.
• Clause 4.3.14 repeats that all "keys, access devices, remote controls and parking permits" are to be returned at the end of possession.

These references only confirm that a parking permit may exist; they do not create an obligation to display one, nor do they authorise enforcement action for non-display.

3. Tenant obligations and covenants

• The agreement obliges the tenant to observe covenants in any headlease (Clause 4.3.25) but specifically excludes rent and service charge payments.

Unless the headlease itself requires permit display and empowers third-party enforcement, this clause does not grant such rights.

4. Third party rights

• Clause 1.9 explicitly states that “no clause of this agreement may be enforced by any third party, other than the Landlord’s Agent, pursuant to the Contracts (Rights of Third Parties) Act 1999.”

This prevents a third-party parking company from relying on the tenancy agreement itself to enforce PCNs.

5. Quiet enjoyment

• Clause 5.2 guarantees the tenant “quiet enjoyment of the Property during the tenancy without any unlawful interruption from the Landlord or any person lawfully claiming under or in trust for the Landlord.”

Any third-party enforcement interfering with parking rights could be challenged as a breach of this covenant, unless clearly authorised.

Conclusion

The tenancy agreement does not grant authority for the landlord, their agent, or a third-party parking operator to require permit display or issue PCNs for failure to display.

• The only mentions of “parking permits” are administrative (returning them at tenancy end).
• Enforcement rights by a third party are explicitly excluded.
• Unless the headlease (not provided here) contains a parking enforcement covenant, no lawful basis exists in this agreement for a third-party operator to impose or enforce PCNs.

So, without seeing the headless, it is not conclusive. However, you should be aware of the following points:

• Your tenancy imports headlease covenants only if provided, and they exclude rent/service charge obligations. If you haven’t been given the headlease, you cannot be bound by unnotified permit obligations.
• Even if the headlease says “subject to regulations”, courts require regulations to be reasonable and consistent with the grant. A right to park is not extinguished by a failure to display a flimsy permit.
• Contracts (Rights of Third Parties) Act 1999 exclusion (Clause 1.9) blocks a parking company from claiming direct enforcement rights under this tenancy.
• Any PCN regime imposed on a lawful tenant with parking rights is likely to be an unlawful derogation from grant and/or breach of quiet enjoyment.
Title: Re: BaySentry Solutions Ltd - No parking permit
Post by: Dandalf on August 18, 2025, 02:09:03 pm
Just tell us what the lease says about parking. No need to try and second guess anything. In the majority of these cases, there is nothing in the lease that allows a third party to override what is in the lease.

Once we know what the lease says, we can advise further.

DO NOT say that the permit was displayed as a "convenience"!!! If you have to mention it, then the permit is displayed as a courtesy!

We need to see exact wording for the lease when you find it. Anything it says about parking, including any defined terms such as things that defines where any allocated bays are etc.

Hi all,

I've finally managed to get the recent signed copy (18 June 2025) of the lease from the tenant. I've anonymised the data and attached it here.

The only 3 specific mentions of parking that I can see, are as follows:

1.8.4 Subject to The Deposit Protection Service (The DPS) terms and conditions, the Deposit will be
refunded, less any deductions, once the following have been completed:
1.8.4.2 all keys, access devices, remote controls and parking permits have been returned

4.3.14 Not change the locks (or install additional locks) to any doors in the Property, nor make additional
keys for the locks without Permission. All keys, access devices, remote controls and parking permits are
to be returned when possession of the Property is returned to the Landlord.

4.6 END OF TENANCY
4.6.2 Return all keys, access devices, remote controls and parking permits to the Property on the last
day of possession (or sooner by mutual arrangement).


I presume no specific mention of Bay-Sentry or parking spaces etc work in our favour here - what would be the next step(s)?

Appreciate all your help and advice.

Many thanks,
Dan
Title: Re: BaySentry Solutions Ltd - No parking permit
Post by: DWMB2 on August 10, 2025, 04:44:12 pm
We need to see exact wording for the lease when you find it. Anything it says about parking, including any defined terms such as things that defines where any allocated bays are etc.
Title: Re: BaySentry Solutions Ltd - No parking permit
Post by: b789 on August 10, 2025, 03:21:21 pm
Just tell us what the lease says about parking. No need to try and second guess anything. In the majority of these cases, there is nothing in the lease that allows a third party to override what is in the lease.

Once we know what the lease says, we can advise further.

DO NOT say that the permit was displayed as a "convenience"!!! If you have to mention it, then the permit is displayed as a courtesy!
Title: Re: BaySentry Solutions Ltd - No parking permit
Post by: jfollows on August 10, 2025, 07:23:26 am
Have nothing to do with DCBL, but respond appropriately to anything from Bay Sentry or DCB Legal. Ignoring totally is generally not advised. If a housing agent or similar has introduced a third party then they are also responsible, assuming agreement hasn’t been indicated by amending the lease.

These cases often go to a court claim because everyone else involved ignores the primacy of the lease, but knows that a court won’t, so discontinues the case when they see you’re serious.

Subsequently you may want to write to them all saying that you will display the permit for convenience but restate you have no obligation to do so.
Title: Re: BaySentry Solutions Ltd - No parking permit
Post by: Dandalf on August 09, 2025, 05:56:44 pm
Hi,

Thanks for the response - I can check with the tenant and what the lease/equivalent says about parking.

But I agree, nothing to do with them or anyone else really.
As said, it's a private gated community anyway that is not accessible to the general public, so only people with a right to park there can actually access it.

Is the best course of action to reply to them or ignore?

Many thanks,
Dan
Title: Re: BaySentry Solutions Ltd - No parking permit
Post by: jfollows on August 09, 2025, 05:35:33 pm
Your lease or equivalent says or doesn’t say what about car parking?

Have nothing to do with DCBL; if DCB Legal (not the same company) write to you then please let us know.
Title: BaySentry Solutions Ltd - No parking permit
Post by: Dandalf on August 09, 2025, 05:33:14 pm
Hi all,

Vehicle was parked in a gated residential car park in Hull, only accessible by homeowners and guests with passcode for said car park, so obviously everyone that parks here has the required permit provided.

A driver returned to the car one day to find it had been ticketed overnight by BaySentry Solutions Ltd for having no permit. The car does have a permit, although when checking the vehicle it had blown/fallen into the footwell (could still be seen from the exterior of the vehicle if you knew where to look!).

Tenant, not necessarily the driver or vehicle owner, contacted the landlord/housing agent to see if they could rectify as a valid permit was in place, was told had to appeal directly to BaySentry Solutions Ltd.

BaySentry Solutions Ltd was contacted and situation explained, images of the valid parking permit were also attached. BaySentry Solutions Ltd acknowledged the appeal and the valid permit and still demanded £20 for no reason at all.

Tenant has now received another letter from Direct Collection Bailiffs Ltd (DCBL) today (9th August), but dated 31st July, demanding £170 for an unpaid parking charge (https://ibb.co/ym4DPk8G). The letter states we have 14 days to respond but only arrived today, giving us only 5 days.

All help sincerely appreciated in squashing this ridiculous claim when we clearly have the right to park here with a valid permit.

Many thanks,
Dan