Hello all,
I received a PCN from Parking Group Limited as the registered keeper of the vehicle, claiming the driver didn't park within a marked bay. Unfortunately, on the date of the contravention, my V5C was linked to my previous address, having recently relocated, so the Notice to Keeper PCN was sent to my old address. I didn’t receive any notice until a final Notice of Debt Recovery arrived at my new address from Direct Collection Bailiffs Ltd (DCBL).
I attempted to appeal the charge via Parking Group Limited’s website, but by then, the system couldn’t locate the PCN.
PCN Details:
Date of Contravention - 02/07/2025
Client - Parking Group Limited
Location - White Rose Retail Centre
Reason for Contravention - Vehicle Not Parked Within A Marked Bay
I sent a Data Rectification Notice to Parking Group Ltd and DCBL, instructing them to update their records with my current address, and I also updated my V5C.
Not too long after, I received a Letter of Claim from DCB Legal dated 20 October 2025. Following advice from the forum, I sent the following email to DCB Legal, having copied myself in on 16 November 2025:
Dear Sir or Madam,
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.
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 provide.
Yours faithfully,
My full nameDCBL Legal responded that they were unable to locate my file asking for more information on 24 November 2025. I'd included my name in full, but forgot to include the reference number. I responded with the reference on the same day. They're yet to respond.
I've since received a claim form issued on 21 November 2025. I take it I have until 4pm on 10 December 2025 to submit my defence unless I file an Acknowledgement of Service (AoS) before then. I don't intend to submit an AoS, but plan to submit a MCOL only defence. I’m now seeking guidance as I believe the MCOL defence can vary depending on the circumstances.
I've uploaded all letters to:
https://ibb.co/jkJXtK0whttps://ibb.co/sdV9wsQ1https://ibb.co/8L3pzdqfhttps://ibb.co/HfG0mtT0https://ibb.co/gLzQ5BGdhttps://ibb.co/bMFNvnkdhttps://ibb.co/4gYwrX1MThank you for any advice and for all the time and effort you put into this forum. I couldn't have got this far without your input.
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