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Yes, I’d add something to (2) to the effect of

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and therefore the defendant, as hirer, can not be held liable when the driver has not been identified

just to make the point.

can i replace it with this? - unfortunately for some reason the formatting isn`t coming up correctly for me to paste the whole defense again. if this is ok, do i fill up the acknowledgment of defence and put this as my defence form?

2. The Claimant has failed to comply with the strict requirements of Schedule 4 of the Protection of Freedoms Act 2012 ("POFA 2012"), specifically:
(a) The Creditor failed to provide the Hirer with a 'Notice to Hirer' within the relevant statutory period in accordance with Paragraph 14(2)(a);

(b) The 'Notice to Hirer' was not accompanied by the mandatory documents required under Paragraph 14(2)(b), namely:

(i) A statement signed by or on behalf of the vehicle-hire firm confirming that the vehicle was hired to a named person under a hire agreement;
(ii) A copy of the relevant hire agreement; and
(iii) A copy of the statement of liability signed by the hirer under that hire agreement.

Consequently, the Claimant has failed to satisfy the strict statutory conditions required to transfer liability from the registered keeper to the hirer.
In the absence of POFA 2012 compliance, the Claimant has no lawful right to pursue the Defendant in their capacity as the hirer. Therefore, the Defendant, as hirer, cannot be held liable for this charge when the identity of the driver at the material time has not been established, and the Defendant is under no legal obligation to identify the driver.

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But you will need to file a defence in due course.

By 1 June, or you file an Acknowledgment of Service by this date which gives you until 15 June to file a defence.
You were promised a template defence earlier in this thread by someone who no longer posts here, but increasingly we have seen the likely template defence struck out by the courts because it’s generic and addresses the failings of the claimant’s process rather than being a defence specific to the case.
You have the information you need in this thread to construct a defence around Parking Eye’s failure to comply with PoFA 2012 to transfer liability from the unknown driver to the hirer, so I suggest you work on that, structure it into paragraphs for clarity and post it here for comment.
The basic point that DCB Legal will almost certainly discontinue in the face of a properly defended claim stands.

Could this be used

N THE COUNTY COURT
Claim No: [Claim Number]

BETWEEN:

UK Parking Control Ltd
Claimant

- and -

[Defendant's Full Name]

Defendant


DEFENCE


1. The Defendant denies any liability for this claim.

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 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 CPR PD 16(7.5);

(b) The PoC do not state the exact wording of the clause (or clauses) of the terms and conditions of the contract which is relied on;

(c) 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;

(d) The PoC do not state exactly how the claim for statutory interest is calculated;

(e) The PoC do not state what proportion of the claim is the parking charge and what proportion is damages;

(f) The PoC states that the Claimant is suing the defendant as the driver or the keeper. The claimant obviously knows whether the defendant is being sued as the driver or the keeper and should not be permitted to plead alternative causes of action.

4. The Defendant has attached to this defence a copy of an order made at another court which the allocating judge ought to make at this stage so that the Defendant can then know and understand the case which he/she/it faces and can then respond properly to the claim.

Statement of truth

I believe that the facts stated in this Defence are true. I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth.

Signed:


Date:

Draft Order for the defence

Anyone?

What does it say on the signs in the car park?

When you say hirer, is this a Motability car?

It's a replacement car via insurance

"No charge for blue badge holders"

Received a reply from DCB legal.they only attached picture of the car entering and exiting the car park.

We write in response to your correspondence received in our office dated 27th of March 2026.
We now respond to the same as follows.

 

Please find attached all relevant evidence we hold on the matter.

 

When parking on private land, the contractual terms of the site are set out on the signs. You are entering a contract, 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 terms and conditions on the signs clearly provided tariff rates to pay for parking, if the correct payment was not made a parking charge would be issued. The parking charge was issued correctly as you failed to pay for the correct time your vehicle was on site.

 

A Notice to Keeper was issued to you. You were afforded the opportunity to; appeal the parking charge, transfer liability to the driver (if it was not you) or make payment. Neither a successful appeal, nor an adequate nomination were received, yet payment remains outstanding.

 

You now have 30 days from the date of this email to make payment of £170.00. Failure to make payment may 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 (711200999882PEL) 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.

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/.

Quote from: settop23 on March 25, 2026, 10:32:58 am

I am self employed so what proof would I need to provide to claim?

The time to ask would have been after the judge made clear their claim had failed - apologies, I completely forgot to mention this when advising on the hearing.

In this particular case as the witness statement was drafted by a paralegal couldn't the OP use the Mazur argument?
Wouldn't that dismiss the case entirely? (Sorry if that sounds as a noob)

I agree, the response to the Letter of Claim isn’t too vital, you respond as above and that’s fine.
But you will need to file a defence to a court claim, so you should research this now so that you have it ready in due course. A defended case with a proper defence will very likely end up with a discontinuation, but you need to follow the paperwork path first.

I have been reading some thread including this https://www.ftla.uk/private-parking-tickets/dbc-legal-letter-of-claim/30/

If you have one where the claim was successful please include it here.

Can anyone please share a template when it's a hire vehicle? I am struggling to find one on the forum.