Free Traffic Legal Advice
Live cases legal advice => Private parking tickets => Topic started by: tentenplay on December 21, 2025, 09:12:29 pm
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Please can someone kindly have a look. Is this okay to be sent? Many thanks.
DEFENCE
1. The Defendant denies that the Claimant is entitled to relief in the sum claimed, or at all.
2. The Defendant is the registered keeper of the vehicle in question. The Defendant was not the driver on the material date and the Claimant is put to strict proof of driver identity.
3. The Particulars of Claim are sparse and fail to comply with CPR 16.4 and Practice Direction 16. The claim does not clearly state the contractual terms allegedly breached nor how the sum of £170 has been calculated.
4. The Claimant alleges that the vehicle was “Parked and Left Site.” The Defendant denies that any such breach occurred. The Claimant is put to strict proof that:
a) Clear and prominent signage was in place defining the boundaries of the “site”;
b) The signage clearly stated that leaving the site would result in a parking charge;
c) The driver was observed leaving the site;
d) The individual observed was the driver of the vehicle;
e) The Claimant has lawful authority from the landowner to enforce such a term.
5. The allegation of “leaving the site” is vague, subjective and incapable of forming a clear contractual obligation. Any such term would require exceptionally clear and prominent signage to be enforceable.
6. The Claimant is put to strict proof of full compliance with Schedule 4 of the Protection of Freedoms Act 2012 in order to pursue the registered keeper. In the absence of strict compliance, the Defendant cannot be held liable as keeper.
7. The claim includes an additional sum beyond the advertised parking charge. The £70 added to the principal charge is an attempt at double recovery and is not recoverable under Schedule 4 of the Protection of Freedoms Act 2012 nor under CPR 27.14. The Defendant avers that this is an abuse of process.
8. The Claimant is put to strict proof that it has standing to bring this claim and that a valid contract existed between the Claimant and the driver.
9. The Defendant distinguishes this matter from ParkingEye Ltd v Beavis. In that case, clear signage and a legitimate commercial justification were present. The facts in this case are materially different.
10. The Defendant respectfully requests that the Court strike out or dismiss the claim.
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You need to file a defence using MCOL. If you file by email, as some cases have advised, you need to copy DCB Legal at the same time. If you do not file a defence by the deadline then DCB Legal will promptly apply for a default judgment against you.
You have to write your own defence, for which there are plenty of examples here, but any defence is probably better than no defence.
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Hello everyone,
I filed my AOS on 7th of Feb and I believe I am suppose to file a Defence by the 23rd, which is today. I did not really get a Defence from the forum and the one I saw, I am not sure whether I am suppose to copy word for word and who do I send the Defence to? Would it be back to the court? I would appreciate if someone can explain to me. Thank you
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My bad :)
The typo was on my text not my search bar. I have just searched again and just no case related to mine came up
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Yes, please...
What do you mean?
I was trying to point out the correct spelling of what you should be searching for.
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Yes, please...
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DCB Legal?
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Good morning everyone. I want to write my defence for the case. Someone had advised I check this forum for past successful cases, and I searched for cases around DBC LEGAL, and nothing much came up. I will appreciate help that can nudge me in the right direction. Thank you.
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Thanks again :)
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That was I did. I filled it out online using the Gateway login. Is that the same thing you are referring to?
Excellent - yes indeed. From the chat above I got the impression you had submitted a paper form by post. Far easier to do so online as you have done.
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That was I did. I filled it out online using the Gateway login. Is that the same thing you are referring to?
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Is there a reason you're using form N9 and not simply filing your AoS online using the MCOL service?
Simply my bad advice I think, apologies.
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Is there a reason you're using form N9 and not simply filing your AoS online using the MCOL service?
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Thank you. I have filled out and submitted the N9 form.
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You need to use form N9, for example https://assets.publishing.service.gov.uk/media/5c45e568ed915d38a0611a61/n9-eng.pdf
Waiting until the last possible day makes no difference to your deadline for filing a defence, which will always remain 5+14+14 days after the date on the N1SDT form. So 21 February once you file the AoS, I think. Perhaps 23 February because of the weekend.
Just tick the box to defend all of the claim and submit it.
Then do your research into your defence, using information already available on this forum.
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Good morniing everyone, I intend to send the acknowledgment of Service today as advised, and I intend to send the below statement, hope this is okay. Thank you.
I,xxxxxx hereby acknowledge receipt of the Claim Form issued by DBC Legal dated on xxxx
This acknowledgment is submitted within the required timeframe. I confirm that I intend to respond to the claim in accordance with the applicable rules and deadlines.
This acknowledgment is made without admission of liability and without prejudice to my position in respect of the claim.
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Thanks again for the response. I will do that on the 7th of February for maximum time and I will search the forum as advised.
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So,
G24 is the parking company, not “Contractual”.
The notice you posted isn’t the original Notice to Keeper, which was sent in June. Presumably your car’s V5C was not updated when you moved. Update it now if you haven’t already done so.
You need to reply to the N1SDT by 5+14 days from its date, 7 February I think. If you reply with an Acknowledgment of Service you get 14 more days to submit a defence, or you do this on 7 February.
If you do neither, DCB Legal will apply for a judgment in default against you.
You will get help with your defence, but there are lots and lots of responses to DCB Legal’s poor Particulars of Claim on this forum, so I suggest you search the forum also.
You will also see that, if you follow the process, DCB Legal are 99% likely to discontinue the claim before having to pay the court fee. That is a number of months in the future.
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Thank you for your response. I have attached 3 links. The 1st is the first letter I ever received, which is from a company called G24. The 2nd link is the subsequent letter I received from DCBL, after they found out that there was change of address and the 3rd is the N1SDT letter.
https://ibb.co/R4j8nMK0
https://ibb.co/gNkpYyQ
https://ibb.co/HDyJgFPB
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If you’ve received the N1SDT form, please post it here, just the first page, redact your personal details, claim number and password.
Plus the original PCN. As requested in the links you say you have read.
The letter of claim will have been from DCB Legal, not from DCBL. The latter are debt collectors and can be ignored, as advised.
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Good evening,
I did ignore the Letter of Claim from DCBL and I have subsequently received a claimed form, saying if I do not respond, the claimant could request a CCJ. I will appreciate an advice on the next step. I have read the link you attached to your last message.
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Never heard of an unregulated parking firm named "Contractual". Also, DCBL has nothing, zero, nada to do with any parking firm. DCBL are just a powerless firm of powerless debt collectors and all they can do is try and intimidate the low-hanging fruit on the gullible tree into paying out of ignorance and fear.
So, if you want advice, read the following and then comeback with a netter explanation of which parking firm is DCBLs client.
READ THIS FIRST - Private Parking Charges Forum guide (https://www.ftla.uk/private-parking-tickets/read-this-first-private-parking-charges-forum-guide/)
Posting Images (https://www.ftla.uk/announcements/posting-images/#new)
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Good evening all, I received a PCN from Contractual as the registered keeper of the car. The place (Wickes) where the car was parked, use to have a free parking for 90mins, perhaps is the reason the driver parked there. I sent the below response from research:
I have received your Notice to Keeper xxxxx for vehicle VRM xxxx
You have failed to comply with the requirements of Schedule 4 of The Protection Of Freedoms Act 2012 namely, but not limited to, failing to specify the period of parking to which this notice applies as prescribed by section 9 (2) (e) of the Act. You cannot, therefore, transfer liability for the alleged charge from the driver at the time to me, the keeper.
There is no legal requirement to name the driver at the time and I will not be doing so.
I do not expect to hear from you again, or your debt collectors, except to confirm that no further action will be taken on this matter and my personal details have been removed from your records.
They responded with a Rejection letter and soon afterwards, I received another letter from DBCL as against Contractual. which I ignored. I have received two more letters and most recently a Letter of Claim. I will appreciate some advice on how I should proceed on this matter. Thank you