Free Traffic Legal Advice

No.
Just defendant.

Just received a call from DCB offering a 20% discount to settle.....i said im not paying anything

Quote from: InterCity125 on June 11, 2026, 05:22:00 pm

Can you post up the defence which you submitted for continuity purposes?

This?

Morning. This is what i posted on mcol


How much of the claim do you dispute?
I dispute the full amount claimed as shown on the claim form.
 
Do you dispute this claim because you have already paid it?
No, for other reasons.
 
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 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.

When you have completed the form, attach it to a single email addressed to both dq.cnbc@justice.gov.uk and (email of solicitor) and CC in yourself. Make sure that the claim number is in the subject field of the email.

Thank you jfollows. Can i just check who would "(email of solicitor)" be as i dont have one?

also, when i paste this in the pdf,

"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.."

cant fit "the only true witness to events in question.." in the box.
would that be an issue


gpt trimmed it down to this:
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.
Since the Claimant is a firm that earns income by handling cut-and-paste parking case paperwork, hearing this case solely on paper would give them an unfair advantage. They would likely prefer the Defendant not to expose flaws in their template submissions or speak as the only true witness to the events.

will that work. Please advise. thank you

Thank you. I found a similar case and used that to reply to them. Received attached this 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

No option to attach pdf lol. Will upload screenshots via laptop shortly

Obscure the password.

Thank you. Obscured the pw.
Terminologies are really baffling tbh. Would you recommending following similar steps from this thread?
https://www.ftla.uk/private-parking-tickets/claim-form-received-dcb-legal-ltd-feltham-please-help!/

Please show us.

Hello all. Just seen this. I think I might have mixed up loc with the other pending pcns.
After nearly 6 months, I had below email with pcns, appeal and rejection attached which is all from or in here.

Can someone please advise what I need to do next. Thank you.


Dear,

 

We write in response to your correspondence received in our office dated 29th October 2025.
We apologise for the delayed response. We now respond to the same as follows,

 

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 Notice to Keepers were issued to you. Copies are attached. You were afforded the opportunity to; appeal the parking charges, transfer liability to the driver (if it was not you) or make payment. In regard to your appeal which did not yield the desired outcome, I would like to inform you that you still had the option to escalate your cases further by appealing to the Independent Appeal Service.

 

The signage at the car park stated the maximum stay is 120 minutes permitted for free parking, or otherwise a parking charge would be issued. The vehicle was recorded on both occasions on overstaying the maximum time, as demonstrated in the photographic evidence attached. The parking charges were issued correctly.

 

As payment was not made, either within 14 or 28 days, the creditor was entitled to instruct debt recovery agents / Solicitors to pursue payment and is entitled to recover the costs of doing so. It would have been made clear in the terms and conditions set out in the signs that additional enforcement costs may be incurred in the event of non-payment.

 

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 £340.00. 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 (711200423509G24) 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/.

So show it if you want advice. Which firm issued it and does it comply with the PAPDC?

Please show us.

Pls see below

https://ibb.co/jZbYG7GN

Thank you

Quote from: DWMB2 on September 09, 2024, 09:59:04 am

File and ignore. It's a Letter of Claim from said solicitors that you need to look out for.

This advice has not changed.

Hello. Received LOC. Please advise what to do next