Apologies if this comes across as posting a lot at once. I’ve finally had time to sit down and review the documents relating to this case and start identifying potential defence points.
I will have to take tomorrow evening to sit down properly to learn how to write defence.
As for now I have written perhaps main defence points.
Will it be reasonable as to share such draft in here?
Main defence points so far:
1. Lack of transparency / inflated chargeThe original Notice to Keeper states:
“Payment is now required in the sum of £100.”
However, the first letter from DCBL states:
“NOTICE OF DEBT RECOVERY – Unpaid Parking Charge £170.00.”
This letter
does not explain what the additional £70 represents, nor does it mention any debt recovery fee.
Only in later correspondence does the claimant state that the £170 includes a £70 debt recovery fee.
2. Driver not identified3. Residential car park operating beyond capacity4. Very brief observation periodThe Notice to Keeper states an observation period of:
11:39:35 – 11:43:12 (3 minutes 37 seconds).
However, the timestamps on the photographs themselves show only 1 minute 44 seconds between the first and last photograph (total 7 pictures).
This appears to be an extremely short timeframe to establish any genuine “period of parking.”
Given the residential nature of the site and the frequent lack of available spaces, this timeframe could equally represent a vehicle manoeuvring within the car park, briefly stopping while assessing whether a parking space was available,
or temporarily stopping due to the absence of available bays.
5. Tenancy agreementMy tenancy agreement contains no provisions regarding parking enforcement by a third-party parking company or the imposition of parking charges on residents.
6. Confusing introduction of the parking schemeParking enforcement was introduced around October 2025 in a confusing manner...the original signage was incorrect and subsequently changed without proper notification.Edit: additionally to the last one, for initial confusion. Generic A4 information states NPC service will begin on the 2nd October. However signs and most important incorrect signs have appeared in place on 30th September - which that technically creates contract at this date isn't it?