Free Traffic Legal Advice

Today my wife received a letter from DCB Legal (attached) following others from DCBL Bailiffs acting on behalf of G24 Ltd. They are claiming that, as the keeper of a vehicle, she owes £170 for an ‘unpaid Parking Charge’; five years earlier.

The car was regularly driven by three different members of our family, none of whom can remember parking at the Homebase carpark in question on the 24th December 2019. My wife was also the keeper of second car in 2019 which she drove more regularly.

It is no longer possible to view the car park or signage that may have been applicable on the date in question.

Please can you offer some advice?

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Oh, sorry, this is the formal letter of claim.

Same advice, just wait for formal paperwork and complete with our help. They will eventually discontinue.

You will have some formal paperwork to deal with first. You will get guidance here. You will have to file a defence and a Directions Questionnaire, the case will be allocated to your local court and then DCB Legal will discontinue before having to pay the court fee.

Read up here on many similar cases in the meantime. It’s what I have done.

Essentially it costs very little to send the letter and they know that a significant percentage of recipients just pay £170 or whatever.

Respond to the LoC with the following by email to info@dcblegal.co.uk and CC in yourself:

By email to: info@dcblegal.co.uk

[Date]

Dear Sirs,

Re: Letter of Claim dated 20th March 2025

I refer to your Letter of Claim.

I confirm that my address for service at this time is as follows, and I request that any outdated address be erased from your records to ensure compliance with data protection obligations:

[YOUR ADDRESS]

Please note that the alleged debt is disputed, and any court proceedings will be robustly defended.

I note that the sum claimed has been increased by an excessive and unjustifiable amount, which appears contrary to the principles established by the Government, who described such practices as “extorting money from motorists.” Please refrain from sending boilerplate responses or justifications regarding this issue.

Under the Pre-Action Protocol for Debt Claims, I require specific answers to the following questions:

1. Does the additional £70 represent what you describe as a “Debt Recovery” fee? If so, is this figure net of or inclusive of VAT? If inclusive, I trust you will explain why I, as the alleged debtor, am being asked to cover your client’s VAT liability.

2. Regarding the principal sum of the alleged Parking Charge Notice (PCN): Is this being claimed as damages for breach of contract, or will it be pleaded as consideration for a purported parking contract?

I would caution you against simply dismissing these questions with vague or boilerplate responses, as I am fully aware of the implications. By claiming that PCNs are exempt from VAT while simultaneously inflating the debt recovery element, your client – with your assistance – appears to be evading VAT obligations due to HMRC. Such mendacious conduct raises serious questions about the legality and ethics of your practices.

I strongly advise your client to cease and desist. Should this matter proceed to court, you can be assured that these issues will be brought to the court’s attention, alongside a robust defence and potentially a counterclaim for unreasonable conduct.

Yours faithfully,


[YOUR NAME]

Anyone can send the email, as long as it is done in her name.

Yesterday my wife received an email reply from DCB Legal. A copy (anonymised) is attached.

Their email included a PDF of the Parking Charge Notice which shows photographs of the car, registration plate, time vehicle was parked etc. I am unable to see who was driving.

How should she respond? Thanks.

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Thanks again b789. Amazing letter. I’ll make sure it is sent off shortly.

As they have not responded to the response to the LoC you can refer them to the SRA. I advised someone earlier today on how to do that in this post:  https://www.ftla.uk/private-parking-tickets/vcs-cn-stopping-in-a-prohibited-zone-bristol-airport/msg74558/#msg74558

Just adapt that to your situation.

Regarding the claim, with an issue date of 29th May, you have until 4pm on Tuesday 17th June to submit your defence. If you submit an Acknowledgement of Service (AoS) before then, you would then have until 4pm on Tuesday 1st July to submit your defence.

If you want to submit an AoS then follow the instructions in this linked PDF:

https://www.dropbox.com/s/xvqu3bask5m0zir/money-claim-online-How-to-Acknowledge.pdf?dl=0

Otherwise, here is the defence and link to the draft order that goes with it. You only need to edit your name and the claim number. You sign the defence by typing your full name for the signature and date it. There is nothing to edit in the draft order.

When you're ready you combine both documents as a single PDF attachment and send as an attachment in an email to claimresponses.cnbc@justice.gov.uk and CC in yourself. The claim number must be in the email subject field and in the body of the email just put: "Please find attached the defence and draft order in the matter of G24 Ltd v [your full name] Claim no.: [claim number]."

IN THE COUNTY COURT

Claim No: [Claim Number]

BETWEEN:

G24 Ltd
Claimant

- and -

[Defendant's Full Name]

Defendant

---

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 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 (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 attaches to this defence a copy of a draft order approved by a district judge at another court. The court struck out the claim of its own initiative after determining that the Particulars of Claim failed to comply with CPR 16.4. The judge noted that the claimant had failed to:

(i) Set out the exact wording of the clause (or clauses) of the terms and conditions relied upon;

(ii) Adequately explain the reasons why the defendant was allegedly in breach of contract;

(iii) Provide separate, detailed Particulars of Claim as permitted under CPR PD 7C.5.2(2).

(iv) The court further observed that, given the modest sum claimed, requiring further case management steps would be disproportionate and contrary to the overriding objective. Accordingly, the judge struck out the claim outright rather than permitting an amendment.

5. 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 for the Claimant’s failure to comply with CPR 16.4.

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

It matters not what you have received prior to the claim. Have a read of CPR 16 to understand what must be included in the PoC. You have to imagine that you know absolutely nothing about this claim and the N1SDT Claim Form is the first you know about this. The PoC have to explain the claimants case with enough detail for you to be able to make an informed defence.

There is nothing to stop the claimant issuing further, more detailed PoC within 14 days if they cannot explain their case on the N1SDT form. They have chosen not to do that.

Their PoC do not adequately set out their case.