Free Traffic Legal Advice

When you’ve answered my questions above, I will provide you with a draft letter that you will send as a pdf attachment in an email to DCB Legal. The date I tell you to send that email is critical and you must not send it any earlier.

You will have to make a note in your diary to remind you of the date it MUST be sent on. There can be no excuse for sending it earlier or later than the day I will give you. Most email agents have a function where you can delay the sending of an email to a specified date.

If you can figure out how to do so with your email agent, let me know once you’ve answered 5he questions posed in my previous post.

If you follow the advice, not only will you have avoided being sued for any of those PCNs, but you will also be able to enjoy the Schadenfreude of knowing that the incompetents at DCB Legal will be kicking themselves for having blown the opportunity to make a claim and, if I were G24, I’d also be kicking up a great fuss over DCB Legal’s utter incompetence in recovering all that money they claim you were in debt to them.

Why haven't you answered all my questions? You really must pay more attention to the advice and questions being asked.

Was this letter (LoC) received by email or by post?

In the meantime... send the following as a PDF attachment in an email to DCB Legal at info@dcblegal.co.uk and CC in yourself:

Subject: Response to Letter of Claim – Request for Full Breakdown of Alleged Debt

DCB Legal
Direct House
Greenwood Drive
Manor Park
Runcorn
WA7 1UG

By email to: info@dcblegal.co.uk

[Date]


Dear DCB Legal,

I refer to your Letter of Claim dated 13th March 2025. Your ref: [Their ref number]

I note that you have simply listed six alleged PCNs by date, along with an undisclosed breakdown of a total of £1,020. This fails to comply with the Pre-Action Protocol for Debt Claims (PAPDC), which requires you to provide a clear and detailed explanation of how the alleged sum has been calculated.

Before I consider my position, I require specific answers to the following questions:

1. A full breakdown of the sum claimed, including:

• The original amount of each Parking Charge Notice (PCN).
• Any additional charges applied, including but not limited to "Debt Recovery" fees or "Damages" per PCN.
• Does any additional sum represent what you describe as a “Debt Recovery costs” and 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.
• Whether interest has been added, and if so, from precisely what date for each PCN.

2. Confirmation as to whether the principal sum of each PCN is being claimed as:

• Damages for breach of contract, or
• Consideration for a purported parking contract?

3. If the additional sums exceed the original £100 per PCN, please explain how you or your client justifies these charges in light of the Court of Appeal ruling in Excel Parking v Wilkinson [2022] (G4QZ465V), where the court confirmed that "Debt Recovery" uplifts were an abuse of process?

I would caution both you and your client 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]

You can send the above letter now. However, keep this date in your diary, Monday 7th April, as I will provide you with a debt advice holding letter which must be sent to DCB Legal as a PDF attachment in an email on that date. No earlier or later.

Subject: Response to Letter of Claim – Request for 30-Day Hold for Debt Advice

DCB Legal
Direct House
Greenwood Drive
Manor Park
Runcorn
WA7 1UG

By email to: info@dcblegal.co.uk

7th April 2025


Dear DCB Legal,

Re: Letter of Claim dated 13th March 2025 – Reference [Your Reference Number]

I have already acknowledge receipt of your Letter of Claim dated 13th March 2025 regarding the alleged outstanding balance of £1,020.00.

I am currently seeking independent debt advice and, as per the Pre-Action Protocol for Debt Claims, I formally request that you place this matter on hold for a minimum period of 30 days from the date of this letter to allow me sufficient time to obtain advice.

Please confirm in writing that you have placed this matter on hold for 30 days.

Yours faithfully,

[Your Name]
[Your Address]
[Your Email]

You absolutely must not send this earlier than the 7th April and certainly no later than 16th April. Make absolutely sure that you email it to info@dcblegal.co.uk and that you CC in yourself. However, as you seem to not always fully read the advice and instructions/questions, I need you to confirm that you have 7th April marked in your diary with reminder to send this holding letter on this date.

I would further advise you to send a hard copy of the letter by first class post with a free proof of posting certificate from any post office on Friday 4th April. Whilst not absolutely necessary, it does provide a back up just in case they try to claim that they never received the email with the 30 day hold request and issue a claim anyway. Do not put it past these scammers to try and do so.

If you follow the advice, then that will be it. They will be statute barred from being able to issue a county court claim for any of the 28 PCNs that were outstanding.

The dates above are very important. For the 'debt advice' letter, a hard copy sent by 1st class post from a Post office on Friday 4th April, and a copy sent by email to info@dcblegal.co.uk on Monday 7th April.

I realise I'm labouring the point, but getting the dates right is the key to success in this case.

So, how have you got on with this?

That sounds positive.

Let’s remind ourselves what this was all about. This case originally concerned a potential claim for £6,290, based on 37 PCNs issued by G24 in late 2018 and early 2019. DCB Legal were instructed to pursue these on behalf of G24, but through a combination of delays and poor case management, the vast majority of those PCNs quietly became statute-barred under the Limitation Act 1980.

By the time DCB Legal finally issued a Letter of Claim on 13th March 2025, only six PCNs remained within the six-year limitation period. Despite this, they attempted to claim a grossly inflated sum of £1,020, well above the £600 that would be due if each PCN were pursued at its original £100 level. This increase was due to the addition of unlawful “debt recovery” charges—something which has repeatedly been criticised by both the courts and the Government.

On 7th April 2025, a holding letter was sent in full accordance with the Pre-Action Protocol for Debt Claims, confirming that the recipient was seeking debt advice. That letter imposed a lawful 30-day moratorium on any court proceedings, which DCB Legal must observe. Crucially, the last of the six PCNs will become statute-barred on 4th May 2025—three days before DCB Legal is legally permitted to issue any claim.

As of now, the limitation period has not yet expired—but DCB Legal are prohibited from issuing proceedings due to the lawful hold that is in place. Once that hold lifts on 7th May, they will be permanently out of time.

This entire outcome is a direct result of DCB Legal’s incompetence. Their client, G24, had issued all 37 PCNs back in 2018/2019 and would have been in possession of the relevant records throughout. It was DCB Legal’s responsibility, as their instructed legal representatives, to assess the portfolio and take timely action. Instead, they delayed so extensively that by the time they finally issued a Letter of Claim in March 2025, only six PCNs were still within the limitation period. And now, having received a properly timed 30-day debt advice hold request, they are legally prevented from issuing any claim until after those remaining six PCNs become statute-barred. What could have been a £6,290 claim is now unenforceable in its entirety—simply because DCB Legal failed to act within the most basic legal time limits.

I have received the following email from dcb legal along with another i will post shortly.

September 2020, confirmed that parking charge notices falls out of the scope of VAT. There is no requirement for a VAT invoice to be issued to you.           

     

Further to the above, in accordance with the appeal decision made on 29th July 2020 in Britannia Parking Group Ltd v Semark-Julien [2020] EW Mis 12 (CC), it is not correct to propose this claim should be struck out as an ‘abuse of process’ due to the contractual costs claimed.           

 

 

In addition to the afore, the sum added is a contribution to the actual costs incurred by our Client as a result of your non-payment. Our Client’s employees have spent time and material attempting to recover the debt. This is not our Client’s usual business and the resources could have been better spent in other areas of the business. Had you of paid as per the Contract, there would have been no need for recovery action so the amount due would not have increased.

 

 

With reference to the above, this parking charge is being pleaded as a breach of contract to which damages are payable in light of the matters raised in this correspondence.       

       

   

Pursuing a legally owed debt is not harassment. You may wish to seek independent legal advice in this regard. Our client pursuing this matter through the Small Claims Court is the correct course of action.   

 

 

 

DCB Legal have been instructed as all previous attempts to resolve the matter have been unsuccessful.   

 

 

 As per your request, your file is now on hold for 30 days from the date of this email, as per your request, to allow you time to seek your own independent legal advice.

 

 

You now have 30 days from the date of this email to make payment of £1020.00. 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 (121960.9282D) 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/.


Kind Regards,

 

Isabel Mwamba

Administration Associate

DCB Legal Ltd 

 

Tel: 0203 434 0433 | DX 23457 Runcorn