Free Traffic Legal Advice

Live cases legal advice => Private parking tickets => Topic started by: CD on December 08, 2025, 09:06:09 pm

Title: Re: MET Parking Services - Alleged Overstay - Southgate Park, Stansted
Post by: InterCity125 on March 05, 2026, 09:05:27 am
Amended.

Title: Re: MET Parking Services - Alleged Overstay - Southgate Park, Stansted
Post by: jfollows on March 05, 2026, 09:02:36 am
Just spelling - KADOE - Keeper At Date Of Event
Title: Re: MET Parking Services - Alleged Overstay - Southgate Park, Stansted
Post by: InterCity125 on March 05, 2026, 08:49:05 am
These are the bulk of the defence points which should be included.

As already advised, please read through some other threads which deal with providing a defence submission.

Please ensure that you are vaguely familiar with the process since it is not entirely complex and is designed for a litigant in person rather than a legal professional.

Give it a few days for others to add further if needed - in my opinion, this is a decent skeleton defence - more can be added in the Witness Statement if needed.

I strongly suspect that the parking operator will NOT want to provide the official plan since such a plan would destroy their business at this location.




Southgate Park Defence Points



That the claim is denied in its entirety and that no debt is owed.

It is acknowledged that I am the Registered Keeper of the vehicle specifically mentioned in the Claim Form.

In the first instance, the vehicle driver is not known by the claimant.

That this is a contract dispute and, as such, there is absolutely no legal requirement for a Registered Keeper to reveal driver details to an unregulated private parking contractor.

As such, I will not be providing any driver details and no presumption can be drawn from me simply exercising my legal right.

That the land, mentioned by he Claimant, at Southgate Park, Stansted is clearly inside the boundary of the Stansted Airport Area.

That all the land inside the Stansted Airport Area is designated, by the Government, as being Land Under Statutory Control and, as such, PoFA 2012 Schedule 4 cannot be used at this particular location as this location is not 'relevant land' as defined under PoFA 2012.

That a Statutory Instrument exists and is legally in place.

That this Statutory Instrument is known as 'The Stansted - London Byelaws'.

That the Statutory Instrument sets out parking controls within the Land Under Statutory Control.

That the 'Statutory Control' mentioned in the term 'Land Under Statutory Control' is the Statutory Instrument and, as such, by definition, the Statutory Instrument covers the entire area of Land Under Statutory Control.

That while the land at Southgate Park is privately owned, it remains within the official Airport Area and therefore remains under the control of the Statutory Instrument.

The Claimant has stated (in previous communications) that the land at Southgate Park is no longer within the designated area under statutory control and that, consequently, PoFA 2012 can in fact be used to establish Keeper Liability at the location.

That I therefore put the Claimant to STRICT PROOF to provide, to the Court, a formal Airport Plan document provided by either the LOCAL AUTHORITY or the GOVERNMENT which shows the claimed revised airport area boundary which specifically excludes the land at Southgate Park.

That the airport plan often used, by the claimant, in the parking appeals process will not be accepted since that plan specifically excludes land not owned by the airport operator - meaning; that even if the land at Southgate Park was inside the Airport Area it would never be shown on that particular plan.

That, as PoFA 2012 cannot be used at Southgate Park, the Claimant is unable to move liability from the unknown driver onto the Registered Keeper.

That, with both the driver unknown and, no keeper liability, there is no legal route by which the Claimant can hold me liable.

The Claim is therefore denied in its entirety.


Additional defence points which the Court should be made aware of;

That the Claimant's issued Parking Charge Notices (PCNs) are in clear breach of the parking operators Code of Practice since the PCNs specifically mention PoFA Keeper Liability.

The operators Code of Practice EXPRESSLY PROHIBBITS operators specifying keeper liability under PoFA 2012 when PoFA cannot apply.

A breach of the Code of Practice is automatically a breach of the operator's KADOE Agreement with the DVLA since that agreement specifically requires that the operator agree to follow the Code of Practice.

My details have therefore been obtained in breach of the KADOE Agreement.

That this also constitutes a misuse of personal data.
Title: Re: MET Parking Services - Alleged Overstay - Southgate Park, Stansted
Post by: InterCity125 on March 04, 2026, 12:23:00 pm
We can probably come up with a location specific defence for this claim.

Can you confirm that the driver has never been revealed in any appeal etc?
Title: Re: MET Parking Services - Alleged Overstay - Southgate Park, Stansted
Post by: jfollows on March 04, 2026, 10:48:16 am
You really need to search the forum for lots of cases at the same place, see the defences they used, and then modify and post here before submitting.
If you search for DCB Legal also you will see that they proceed until having to pay the court fee in 99% of cases.
Title: Re: MET Parking Services - Alleged Overstay - Southgate Park, Stansted
Post by: CD on March 04, 2026, 10:33:46 am
Thanks for clarification - all a bit new to me and out of my comfort zone. I've created an online account today and completed an acknowledgement of service online, indicting I will dispute the claim.

I would really appreciate some assistance on what to set out as my defence case for my situation.

Once I have replied with a defence case does the HM Courts and Tribunals Service review the defence or do they have to set a court date?
Do DCB Legal have to decide whether to proceed after the defence has been issued or are they already committed to the process?

Thank You.

CD
Title: Re: MET Parking Services - Alleged Overstay - Southgate Park, Stansted
Post by: jfollows on February 28, 2026, 07:18:49 am
The form tells you what next to do.

You have 5+14 days from the date on the N1SDT form to file either an Acknowledgment of Service or a defence. If the former, then you have an additional 14 days for the defence.

14 & 28 March I believe. You use the online MCOL service for both.
Title: Re: MET Parking Services - Alleged Overstay - Southgate Park, Stansted
Post by: CD on February 27, 2026, 04:51:47 pm
Thanks for the reassurance - much appreciated. I will wait for some input how best to proceed.

CD
Title: Re: MET Parking Services - Alleged Overstay - Southgate Park, Stansted
Post by: Brenda_R2 on February 27, 2026, 04:43:06 pm
First of all - don't panic.

This is an entirely predictable turn of events.  These parasites only back off at the very final stage when they are required to pay a court fee to make their claim "live".

There are very wise people here who will be along to guide you as to what you need to do next.
Title: Re: MET Parking Services - Alleged Overstay - Southgate Park, Stansted
Post by: CD on February 27, 2026, 04:40:48 pm
Link to documents received.

https://i.postimg.cc/NG2VfvSk/Claim-Form.png
Title: Re: MET Parking Services - Alleged Overstay - Southgate Park, Stansted
Post by: CD on February 27, 2026, 04:33:11 pm
Good Afternoon,

I replied as per the advice. Today I received a claims form from HM Courts Tribunals Service and have to send a reply within 14 days.

I will attach the link to the paperwork I have received but the breakdown of the claim amounts to DCB Legal Ltd claiming £170 for the PCN plus £15.88 interest, £35 court fee and £50 legal representative costs.

I would appreciate some advice on how best to respond.

Thanks

CD
Title: Re: MET Parking Services - Alleged Overstay - Southgate Park, Stansted
Post by: jfollows on February 13, 2026, 12:11:10 pm
Search the forum for lots of DCB Legal encounters.
First, ignore everything from DCBL who are debt collectors.
Secondly, DCB Legal will probably issue a court claim against you.
As long as this is defended, with advice here, it is very likely to be discontinued.
But you should read up now and follow the process in due course.
From earlier:
Quote
I can tell you with greater than 99.9% certainty that as long as you follow the advice you are receiving here, you will not be paying a penny to MET. As long as they have, in desperation, used DCB Legal to issue the claim, as long as it is defended when it comes, irrespective of all the winning points you have up your sleeve, it will either be struck out or discontinued before it ever reaches a hearing.
Title: Re: MET Parking Services - Alleged Overstay - Southgate Park, Stansted
Post by: CD on February 13, 2026, 12:05:17 pm
Thanks for the advice and the words!

I have sent it to them as you set it out. Hopefully will do the trick and they will see the light but who knows with them! Will be in contact if I hear anything else back.

Thanks again for your help and advice.

CD
Title: Re: MET Parking Services - Alleged Overstay - Southgate Park, Stansted
Post by: InterCity125 on February 11, 2026, 08:13:36 am
Given your circumstances I would personally reply with something along the lines of the following;




To whom it may concern,

I can confirm that I have now received your revised Letter of Claim.

I am the vehicle keeper - the driver is not known to your client and there is no legal requirement to provide driver details.

Liability for the so called 'debt' is firmly denied.

For the purposes of clarity; the original PCN (NtK) sent to me by your client was unlawful as it clearly stated that they could invoke PoFA keeper liability in order to make me liable for any unpaid parking charges - PoFA cannot be used at the location in question as the location is clearly inside the area of statutory control at Stansted Airport.

Furthermore, an examination of your clients own Code of Practice reveals that parking operators are expressly forbidden from using claims of keeper liability (arising from PoFA) when PoFA cannot be used - your client clearly breaches their Code of Practice and in doing so also breaches their KADOE contract with the DVLA.


I now feel that I have both set out my legal position and provided you with sufficient information to bring this matter to prompt close.

I am sorry that I cannot help you further.



Best wishes,

xxxxxx xxxxxxxxx
Title: Re: MET Parking Services - Alleged Overstay - Southgate Park, Stansted
Post by: CD on February 10, 2026, 06:42:09 pm
Hi guys,

I've attached the "evidence" included with their e-mail. Any suggestions / advice regarding a response to their letter?

Thanks
Title: Re: MET Parking Services - Alleged Overstay - Southgate Park, Stansted
Post by: CD on February 09, 2026, 06:00:26 pm
https://i.postimg.cc/sD4Xb4TH/evidence.png (https://i.postimg.cc/sD4Xb4TH/evidence.png)

Link attached as requested. Seems to be original PCN with the original reminder and then several photos of generic signage around the car park.
Title: Re: MET Parking Services - Alleged Overstay - Southgate Park, Stansted
Post by: InterCity125 on February 09, 2026, 04:44:57 pm
Please post up all the evidence which they included in their response.
Title: Re: MET Parking Services - Alleged Overstay - Southgate Park, Stansted
Post by: CD on February 09, 2026, 04:33:00 pm
Good Afternoon,

I followed the advice and sent the appropriate response from the template and have now had the below response from DCB Legal via e-mail. Could you please advise what response I should send. They have requested a response within 30 days which is 14th Feb. I've been a bit distracted with a family illness so haven't had a chance to respond yet but still within time.

The reference to their attached document was just them scanning the original PCN, which I obviously already had.

Thank You.

----------------------------------------------------------------------------------------------------------------
We write in response to your recent correspondence in response to our Letter of Claim (LOC) and will now respond as follows.

It is our position that the Letter of Claim (“LOC”) is compliant with the Pre-Action Protocol for Debt Claims (“the Protocol”). The LOC provides adequate information for you to identify the debt that our Client is seeking to recover. We would 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.

For the avoidance of doubt, please note that the timeframe in which to appeal the Parking Charge has expired. You were given the opportunity to lodge an appeal when the initial Notice was issued to you. Given that the case has been escalated to this firm for recovery action, the time to appeal has now elapsed and payment of the Parking Charge(s) is now required.

The amount owed is a genuine pre-estimate of the losses incurred in managing the parking location to ensure compliance with the clearly displayed terms and conditions. Further, in accordance with the British Parking Association (BPA)/International Parking Community (IPC) Code of Practice, where the Parking Charge becomes overdue and before Court proceedings have commenced, a reasonable sum may be added for the debt recovery fees. The correct recovery fees have been added and will not be removed, for completeness we would advise that the fee is not inclusive of any VAT, as it does not pertain to a supply of goods/services between you and our Client.

To clarify, when parking on private land, the contractual terms of the site are set out on the signs. You are thus entering into a contract (by way of conduct) 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.

Attached are copies of evidence pertaining to the matter, however, if there are any documents that you have requested, but that are not attached, 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 now have 30 days from the date of this email to make payment of the amount as per our Letter of Claim. 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:

Please note that in the absence of payment in the next 30 days, our position remains as previously advised. As such, should our client instruct us to proceed with further legal action, we reserve the right to do so without any further reference to you.

If you are at all unsure of your legal position, we recommend that you seek your own independent legal advice

Kind Regards,

Litigation Support Team

DCB Legal Ltd
Title: Re: MET Parking Services - Alleged Overstay - Southgate Park, Stansted
Post by: b789 on December 12, 2025, 10:53:53 am
The debt recovery letters are only "intimidating" if you do not understand that there is absolutely nothing these debt collectors can do. They are powerless. They are not a party to the contract allegedly breached by the driver.

As long as you are aware of that, then those letters should never be "intimidating" ever again. Use the free paper as kindling or shred it to make hamster bedding. Win win.
Title: Re: MET Parking Services - Alleged Overstay - Southgate Park, Stansted
Post by: CD on December 11, 2025, 04:49:47 pm
Thanks so much for the template and the advice.

I have copied and e-mailed them the response you set out, to dcb legal today and will await their reply.

I'm sure they will carry on with the intimidating letters but will pop back for more advice once I hear anything back.

Thanks again - you guys give me faith there are decent, knowledgeable people out there willing to help those that need it to stand up to these highway robbers.

CD
Title: Re: MET Parking Services - Alleged Overstay - Southgate Park, Stansted
Post by: b789 on December 09, 2025, 03:57:15 pm
This could have been put to bed at POPLA. However, you are where you are. At least the drivers identity has not been blabbed, which is the strongest point.

I can tell you with greater than 99.9% certainty that as long as you follow the advice you are receiving here, you will not be paying a penny to MET. As long as they have, in desperation, used DCB Legal to issue the claim, as long as it is defended when it comes, irrespective of all the winning points you have up your sleeve, it will either be struck out or discontinued before it ever reaches a hearing.

FOr now, simply respond to DCB Legal with the following email to info@dcblegal.co.uk and CC yourself:

Quote
Subject: Response to your Letter of Claim Ref: [reference number]

Dear Sirs,

Your Letter Before Claim contains insufficient detail of the claim and fails to provide copies of the evidence your client places reliance upon, putting it in clear breach of the Pre-Action Protocol for Debt Claims.

As a supposed firm of solicitors, one would expect you to comply with paragraphs 3.1(a)–(d), 5.1 and 5.2 of the Protocol, and paragraphs 6(a) and 6(c) of the Practice Direction. These provisions exist to facilitate informed discussion and proportionate resolution. You may wish to reacquaint yourselves with them.

The Civil Procedure Rules 1998, Pre-Action Conduct and Protocols (Part 3), require the exchange of sufficient information to understand each other’s position. Part 6 clarifies that this includes disclosure of key documents relevant to the issues in dispute.

Your template letter refers to a “contract” yet encloses none. That omission undermines the only foundation upon which your client’s claim allegedly rests. It is not possible to engage in meaningful pre-litigation dialogue while you decline to furnish the very document you purport to enforce.

I confirm that, once I am in receipt of a Letter Before Claim that complies with para 3.1(a), I shall seek advice and submit a formal response within 30 days, as required. Accordingly, please provide:

1. A copy of the original Notice to Keeper (NtK) and any notice chain relied upon to assert PoFA 2012 liability.

2. A copy of the contract you allege exists between your client and the driver, being an actual photograph of the sign(s) in place on the material date (not a stock image), together with a site plan showing the sign locations.

3. The precise wording of the clause(s) allegedly breached.

4. The written agreement between your client and the landowner evidencing standing/authority to enforce and to litigate.

5. A breakdown of the sums claimed, identifying whether the principal sum is claimed as consideration or damages, and whether the £70 “debt recovery” add-on includes VAT.


I am entitled to this information under paragraphs 6(a) and 6(c) of the Practice Direction, and I require it to meet my own obligation under paragraph 6(b).

If you fail to provide the above, I will treat that as non-compliance with the PAPDC and Pre-Action Conduct and will raise a formal complaint to the SRA regarding your conduct. I reserve the right to place this correspondence before the Court and to seek appropriate sanctions and costs (including, where appropriate, a stay and/or other case management orders).

Until your client complies and provides the requested material, I am unable to respond properly to the alleged claim or to consider my position. It would be premature and a waste of costs and court time to issue proceedings. Should you do so, I will seek immediate case management relief pursuant to paragraph 15(b) of the Practice Direction and an order compelling provision of the above.

Please note, I will not engage with any web portal; I will only respond by email or post.

Yours faithfully,

[Your name]

Do not use their portal. Do not use any forms that came with the Letter of Claim (LoC). Everything is going to be by email. Nothing is sent by snail mail post.
Title: Re: MET Parking Services - Alleged Overstay - Southgate Park, Stansted
Post by: jfollows on December 09, 2025, 07:40:47 am
They can request what they want but, no, you can reply in any way that reaches them, and you can ignore the “financial statement”, what right do you think they have to receive this information? This is only slightly relevant if you’re intending to pay them, but if you’re going to tell them you will defend any claim then it’s completely irrelevant.
Title: Re: MET Parking Services - Alleged Overstay - Southgate Park, Stansted
Post by: CD on December 08, 2025, 09:51:29 pm
They have requested response via www.dcblegal.co.uk/response and to complete a financial statement. Should I be responding via this method or letter via registered post or does it matter?
Title: Re: MET Parking Services - Alleged Overstay - Southgate Park, Stansted
Post by: CD on December 08, 2025, 09:40:39 pm
Thanks for info - I'll give it a try.
Title: Re: MET Parking Services - Alleged Overstay - Southgate Park, Stansted
Post by: jfollows on December 08, 2025, 09:25:12 pm
Just search the forum for
Stansted
and there are lots of cases and responses, for example
Quote
I am the registered keeper. MET cannot hold a registered keeper liable for any alleged contravention on land that is under statutory control. As a matter of fact and law, MET will be well aware that they cannot use the PoFA provisions because Stansted Airport is not 'relevant land'.

If Stansted Airport wanted to hold owners or keepers liable under Airport Bylaws, that would be within the landowner's gift and another matter entirely. However, not only is that not pleaded, it is also not legally possible because MET is not the Airport owner and your 'parking charge' is not and never attempts to be a penalty. It is created for MET's own profit (as opposed to a bylaws penalty that goes to the public purse) and MET has relied on contract law allegations of breach against the driver only.

The registered keeper cannot be presumed or inferred to have been the driver, nor pursued under some twisted interpretation of the law of agency. Your NtK can only hold the driver liable. MET have no hope at POPLA, so you are urged to save us both a complete waste of time and cancel the PCN.
But you’re past this now, so need to reply to the Letter of Claim for now.
For example, as in https://www.ftla.uk/private-parking-tickets/met-victim-dcb-legal-letter-of-claim-stansted-southgate/msg94737/#msg94737 but I haven’t checked this in detail.
Title: Re: MET Parking Services - Alleged Overstay - Southgate Park, Stansted
Post by: CD on December 08, 2025, 09:20:11 pm
Thanks - I did read something in another thread about that (and METPS contesting it). Do you think just send a reply on that point? Has there been cases that have found on this basis (or have they not gone to court?). The Driver has not been declared / identified.
Title: Re: MET Parking Services - Alleged Overstay - Southgate Park, Stansted
Post by: jfollows on December 08, 2025, 09:12:30 pm
The real issue is that this is not “relevant land” for the purposes of the legislation (PoFA 2012, https://www.legislation.gov.uk/ukpga/2012/9/schedule/4) which can otherwise be used to transfer liability from the unknown driver to the registered keeper of the vehicle. As long as the driver is not identified, the registered keeper can not be liable although the process will take several months with MET claiming otherwise and threatening court, as can be seen in other cases here.
Title: MET Parking Services - Alleged Overstay - Southgate Park, Stansted
Post by: CD on December 08, 2025, 09:06:09 pm
Hi there,

I would appreciate some advice on this case. I've had a look through the internet and on this forum and appreciate this appears to be a particularly prominent car park where MET Parking Services are issuing people with tickets for basically nothing and then attempting to intimidate them into paying through veiled threats of legal action and debt recovery via different letterhead letters. I note that numerous of these incidents have been highlighted in the mainstream media including newspaper and online articles as well as TV shows, (Jo Lucett), unfortunately discovered all these post PCN.

From what I read in the online content there seemed little point in the appeal process so have taken the stance of completely ignoring all correspondence so far up to now without replying, (PCN + 9 letters). However, have just received a "Letter of Claim", which I believe requires a response?

PCN was apparently issued on 30/12/24 for parking incident on 22/12/24. Didn't receive PCN until 08/01/25 (after the 14 days), but not sure that can be proved. On 22/12/24 the driver entered the car park at 23:53:10 and parked outside Starbucks, Southgate Park with the intention of using the store to make a purchase for food and drink and use the facilities. However, once parked it was found that Starbucks was actually closed, which was not initially clear due to driving and time of night /weather. On checking the signage it indicated that there was free 1 hour parking for customers.

As Starbucks was closed and the McDonalds immediately next to it in the same site was open the driver walked the very short distance to McDonalds where a purchase was made as a customer and the facilities were used. At 00:49:01, 55 minutes later the driver drove out of the car park within the 1 hour limit. A PCN was later received addressed to the registered keeper which indicated the vehicle had remained on the site on the date for "55 minutes, being longer than the period of parking that had been paid for or without authorisation" and apparently "in breach of the t&c's displayed on signs in prominent places".

I have since read articles online where it appears people have had the exact same situation and where MET Parking Services claim the car parks for Starbucks and McDonalds are separate businesses / car parks and marked as such, (which clearly is not true). It was cold, wet and dark at the time of the visit and the signage was vague and poorly lit but indicated in large writing there was free parking for 1 hour for customers. There was no indication that Starbucks and McDonalds would be treated separately as they were in the same car / retail park and there was no clear indication in the car park of any meaningful separation between either establishment

I have also seen other articles suggesting when the store is open there is a screen inside Starbucks to enter vehicle registration details when using the store, but even this isn't clear as a requirement and people have received tickets when parking in the car parkand using Starbucks. Obviously as it was closed there was no option to enter vehicle details or ask anyone permission to park there nor was there a facility to enter vehicle details in Mcdonalds. It certainly was not clear that in making a purchase in McDonalds you would not be classed as customer and the suggestion would be you were in a separate car park, (especially when there is one shared entrance / exit).

I enclose a copy of the PCN and latest letter of claim as well as some pictures and would appreciate advice how best to proceed.

Thanks

https://i.postimg.cc/6ppWX49r/MET_PCN_(edit).png

https://i.postimg.cc/9FnmcFrG/PCN_Letter_of_Claim_(edit).png

https://i.postimg.cc/26jZWSmQ/Venue.jpg

https://i.postimg.cc/RhkhgSrn/Signage.jpg

https://i.postimg.cc/nrDcjysK/Signage-2.jpg

https://i.postimg.cc/KY07cH3V/Map.jpg