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Phone the CNBC first thing on Monday morning, preferably about 8:30am in order to avoid a long wait. You will have to give them the claim number, and tell them you need them to email you the PoC while you wait and do not leave the call until you have received the PoC by email in your in-box.
Hi,
I called CNBC and they sent the below text extract (they did not send a PDF):Quote
Claimant: UK PARKING CONTROL LIMITED
Claimant solicitor: DCB LEGAL LTD.
Particulars of claim: 1. THE DEFENDANT (D) IS INDEBTED TO THE CLAIMANT (C) FOR A PARKING CHARGE(S) ISSUED TO VEHICLE X AT UXBRIDGE ROAD RETAIL PARK, UXBRIDGE ROAD, HAYES, UB4 0TU. 2. THE PCN(S) WERE ISSUED ON 03/12/2023, 07/01/2024, 21/01/2024. 3. THE DEFENDANT IS PURSUED AS THE DRIVER OF THE VEHICLE FOR BREACH OF THE TERMS ON THE SIGNS (THE CONTRACT). REASON:NOT PARKED CORRECTLY WITHIN THE MARKINGS OF THE BAY OR SPACE. 4. IN THE ALTERNATIVE THE DEFENDANT IS PURSUED AS THE KEEPER PURSUANT TO POFA 2012, SCHEDULE 4. AND THE CLAIMANT CLAIMS 1. £510 BEING THE TOTAL OF THE PCN(S) AND DAMAGES. 2. INTEREST AT A RATE OF 8% PER ANNUM PURSUANT TO S.69 OF THE COUNTY COURTS ACT 1984 FROM THE DATE HEREOF AT A DAILY RATE OF £.07 UNTIL JUDGMENT OR SOONER PAYMENT. 3. COSTS AND COURT FEES
They also mentioned that for further info I should reach out to the local county court that is now dealing with it. -
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Thanks — those PoC help. Why you have not told us which local county court, I have no idea so you'll have to do your own researcher the appropriate email address to sue for the court service.
Given the paper strike-out/judgment was made without a hearing, the cleanest route is:1. Apply right now (N244) to set aside/vary the order under CPR 3.3(5), seek relief from sanctions under CPR 3.9, and obtain permission to file an Amended Defence (attached).
2. Ask for a stay of enforcement/registration pending determination.
3. Serve the application bundle on DCB Legal at the same time by CCing them in on the email to info@dcblegal.co.uk.
Below is everything you need, tailored to these PoC (UKPC/DCB Legal; three PCNs at Uxbridge Road Retail Park on 03/12/2023, 07/01/2024, and 21/01/2024; “not parked correctly within markings”; driver in the alternative keeper under PoFA; £510 + s.69 interest + costs).
N244 — wording for Q11 (“What order & why”)
Order sought:1. The order dated [date] striking out the Defence and entering judgment for £666.56 be set aside/varied.
2. Relief from sanctions be granted.
3. The Defence be reinstated and the Defendant have permission to file and serve the Amended Defence annexed within 14 days of this order.
4. Enforcement and registration of the judgment be stayed until this application is determined and, if granted, until further order.
5. Costs in the case.
Why (summary grounds):
a) The strike-out/judgment was made without a hearing on a pleading point; the Defendant (a LiP) had filed the DQ and attended mediation. Any defect was form not substance and is now cured by a compliant Amended Defence.
b) The PoC are minimal MCOL particulars spanning three separate dates/events and relying on driver or, in the alternative, PoFA keeper liability. The proposed Amended Defence pleads to each allegation and narrows the issues.
c) Applying the Denton test: (1) any breach was not serious in context (case already progressed; no trial date lost); (2) good reason (LiP relying on a publicly available template; earlier court error had already occurred in this claim history); (3) all the circumstances favour determination on the merits.
d) Small-claims costs are limited; immediate enforcement/registration would be unfair and unnecessary if the matter is reinstated.QuoteDRAFT ORDER (attach as a separate page)
Here is a concise witness statement you can use:
UPON the Court’s order dated [date] striking out the Defence and entering judgment;
AND UPON the Defendant’s application dated [date];
It is ordered that:1. The order of [date] is set aside and the Defendant’s Defence is reinstated.
2. The Defendant has permission to file and serve the Amended Defence in the form annexed within 14 days.
3. Enforcement and registration of the judgment are stayed pending determination of this application and, if granted, until further order.
4. Costs in the case.QuoteWitness Statement
1. I am the Defendant. This statement supports my application to set aside/vary the paper strike-out and for relief from sanctions.
2. Timeline: (a) I filed a Defence; judgment was wrongly entered; it was set aside by order of HHJ [name] on 7 April 2025; (b) I filed my DQ in early June; mediation took place in July; (c) on [date served] I received the order striking out my Defence as a “paste from the internet” and entering judgment for £666.56.
3. I am a litigant-in-person. I have engaged with the process at all times. Any defect in my earlier Defence was procedural only.
4. The PoC are MCOL-style and identify three separate PCNs (03/12/2023, 07/01/2024, 21/01/2024) at Uxbridge Road Retail Park, alleging “not parked correctly within the markings”, pursuing me as driver and, in the alternative, as keeper under PoFA for a global sum of £510 plus interest and costs.
5. I now tender a fully compliant Amended Defence responding to each allegation and putting the Claimant to proof on signage/terms, driver identity, and strict PoFA compliance (if relied upon), together with authority to contract and litigate, and quantum (challenging add-ons above any principal charge).
6. Applying Denton, relief should be granted: the breach (pleading form) was not serious in context; there is good reason (LiP relying on a public template); and justice favours trial on the merits.
7. I respectfully seek the draft order.
Statement of truth
I believe that the facts stated in this Witness Statement 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:
Exhibits:
A: order of 7/4/2025 (set-aside of earlier CCJ);
B: DQ;
C: mediation notice/outcome;
D: impugned strike-out order;
E: PoC details from CNBC;
F: proposed Amended Defence.
Here is an amended defence tailored to those woeful PoC:QuoteIN THE COUNTY COURT AT [Name of county court]Claim No: [Claim Number]BETWEEN:
UK Parking Control Ltd
Claimant
- and -
[Defendant's Full Name]
Defendant
DEFENCE
1. The Defendant denies the claim in its entirety. No liability is admitted and no debt is owed.
2. The Defendant was the registered keeper of [VRM]. The Defendant does not admit being the driver on 03/12/2023, 07/01/2024 or 21/01/2024. If the Claimant relies on PoFA 2012 Schedule 4, strict compliance is denied.
3. The Particulars of Claim are inadequately particularised and do not comply with CPR 16.4 and PD16 7.3. No contract is attached or set out; the pleaded facts and quantum breakdown are insufficient.
4. In response to PoC §§1–2, it is not admitted that any parking charge was properly incurred at Uxbridge Road Retail Park on the dates pleaded. The Claimant is put to strict proof, for each date separately, of any period of parking, the vehicle’s position, and that bay markings were clear and enforceable at the time.
5. In response to PoC §3 (“not parked correctly within the markings”), breach is denied. The Claimant is put to strict proof that a clear and prominent contractual term required strict bay compliance with an associated charge, that such term was transparently conveyed at the entrance and on-site, that it was a contractual offer (not a prohibition), and that any departure was more than de minimis.
6. In response to PoC §4 (keeper liability), PoFA reliance is denied. The Claimant is put to strict proof, for each PCN, of full statutory compliance including identification of the creditor, specification of a period of parking, mandatory wording/invitations, and all applicable time limits.
7. Standing is not admitted. The Claimant is put to strict proof of landowner authority to contract for parking and to litigate in its own name at this site on the material dates.
8. Quantum is denied. The global figure of £510 is unparticularised; no lawful basis is pleaded for any sums beyond any principal charge (which is denied). Section 69 CCA 1984 interest is discretionary and not properly pleaded.
9. Each PCN is a separate event. The Claimant must prove liability and (if relied upon) PoFA compliance for each date; aggregation cannot remedy failures of proof.
10. The Defendant invites strike-out for failure to comply with CPR 16.4. In the alternative, the Defendant seeks an order that within 14 days the Claimant serve Further and Better Particulars identifying the exact terms relied upon and how incorporated, whether driver or PoFA keeper liability is pursued with the facts said to found it, a contemporaneous site plan and all signage/photos for each date, and a full breakdown of sums; with permission to amend within 14 days thereafter.
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:
To-do list• File N244 with: the Draft Order, the WS + exhibits, and the Amended Defence.
• Email it to the hearing centre on the order and CC DCB Legal at info@dcblegal.co.uk.
• In covering text, ask the court office to note the request for an urgent stay of enforcement/registration.
• If you are outside the 7-day window on the paper order, still apply and ask the court to extend time—explain you are a LiP and moved promptly once you had the PoC detail. -
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..
Thanks a lot for all the detail. The court is Uxbridge Count Court.
The N244 form seems to have updated, - I think the "what and why" order question is now question 3.
Just double checking on how to fill out some of the questions:
Question 5, I assume I put: "at a hearing".
Question 6-8 I am not sure how to fill out.
Question 9a/9b I guess would be DCB Legal?
Question 10 would be: Draft Order, the WS + exhibits, and the Amended Defence.
Question 11 would be a "No".
Finally, are fees applicable in my case? Just asking because it is mentioned on the form too. Once I have the above, I will send all the info to countycourtuxbridge@justice.gov.uk (I assume this is better than emailing enquiries@uxbridge.countycourt.gsi.gov.uk). -
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You’ve got the right form. On that version Q3 is the “what order and why” box. Here is how to complete it for this application.
Q1–Q2
Put the defendant’s full name. Tick Defendant.
Q3 (order and why)
Text you can paste:“Set aside or vary the order dated [date] which struck out the Defence and entered judgment. Grant relief from sanctions. Reinstate the Defence and give permission to file and serve the attached Amended Defence within 14 days. Stay enforcement and registration pending determination. Costs in the case. Reasons: order made without a hearing on a pleading issue; litigant in person engaged with the process (DQ and mediation); any defect is now cured by the attached, compliant Amended Defence.”
Q4
Tick Yes (you are attaching a Draft Order).
Q5 (how do you want to deal with your application)
Tick without a hearing. If the court prefers a hearing, they will list it. If you choose “at a hearing” instead, that increases admin; if you do, state 30 minutes.
Q6 (time estimate)
Leave blank if you ticked without a hearing. If you selected at a hearing, write 30 minutes.
Q7 (give details of any fixed trial date or period)
Write None.
Q8 (level of judge)
Write District Judge.
Q9 and 9a (who should be served and their address)
Write Claimant’s solicitors: DCB Legal Ltd and give their service address from the claim form. You will serve them by CCing the email you are sending to the court.
Q10 (evidence relied on)
Tick the attached witness statement and the statement of case. Your bundle should contain: Draft Order; Witness Statement with exhibits (the April set-aside order, your DQ, mediation notice or outcome, the impugned strike-out order, the PoC details from CNBC); and the Amended Defence.
Q11 (vulnerability)
Tick No unless it applies.
Fees:• General application on notice (you will be serving DCB Legal): £313.
• General application by consent or without notice: £123.
Help With Fees is available if eligible; include your HWF reference if using it.
Filing and serving
File at Uxbridge County Court and Family Court. Email your application to countycourtuxbridge@justice.gov.uk and CC info@dcblegal.co.uk. In your covering email ask the court to note that you seek an urgent stay of enforcement and registration pending determination.
Optional precise wording for your Draft Order:1. The order dated [date] striking out the Defence and entering judgment is set aside.
2. The Defence is reinstated.
3. The Defendant has permission to file and serve the Amended Defence annexed within 14 days.
4. Enforcement and registration of the judgment are stayed pending determination of this application and, if granted, until further order.
5. Costs in the case. -
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..
Thank you so much!
I have followed your guidance carefully and filed the N244 + all the files in the manner suggested.
I will keep you updated on this thread! -
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Hi,
So I filed the N244 + all the files on the 17th of September.
Long story short, the Uxbridge County Court team has been extremely incompetent. Today I was told by the phone operator (from the central team) that the court only put this N244 application on the system today and the case is now waiting for a referral to a district judge (which apparently can take weeks). I called the phone team last week (and today) to get updates given that the email team was not replying to my chases over the last few weeks.
I have been fully engaged and submitted every extra piece of evidence they asked for (financials) since 17 September but despite this, they have been so incompetent the process has been stuck in the same position as early October. Since my initial submission, different team members asked me to re-submit the N244+documents multiple more times (in total I have submitted these 3 times - each time with an automatic reply proving they were received).
To give another example of their incompetence, after submitting one of the financial documents they requested, I chased them several times on an update and did not receive a reply. They eventually replied stating that the document was not legible once they printed it (and this reply only came because I called the central phone team who pushed them to reply). So they just sat on it for over a week without emailing me back asking for an update. All this while the application was still not put on their system.
The issue I am worried about is that DCBL came to my door twice over the last two weeks - I informed them that I had already filed a N244 and I was already engaging with the court. They said that this wouldn't stop enforcement.
Today I received a letter from DCBL stating that they may make an application to the Court for a Warrant of Entry. The phone operator didn't seem sure of whether the fact it is on the system now (finally) and waiting for a referral to the district judge means that any enforcement is suspended. The DCBL letter mentions the King's Bench High Court and Northampton County Court - it is actually Uxbridge County Court dealing with this so not sure if the mention of High Court is an error also?
My question is:
Can DCBL make an application for a Warrant of Entry and enter by force? Even though the application is now finally in the court system? What do I need to do now given the circumstances?
Meanwhile, I will be making a complaint via the official complaints process for how Uxbridge County Court has dealt with this.
-
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What a disgraceful example of utter incompetence at the HMCTS. You need to do the following:
First, send the following email to the court (and CC yourself into everything you email to anyone about this):QuoteSubject: URGENT – Interim stay of enforcement sought – [Claim no.] – [Claimant] v [Defendant] – N244 filed 17/09/2025 – administrative failures
To: countycourtuxbridge@justice.gov.uk
Dear Court Manager,
I am the Defendant. On 17/09/2025 I filed an N244 to set aside/vary the paper strike-out and judgment, for relief from sanctions, reinstatement of the Defence, permission to file an amended defence, and a stay of enforcement/registration.
This is not a routine backlog. The application was acknowledged each time I filed and re-filed at the court’s request, yet it was not entered on the system until today, 43 days after submission. I was told a document was “not legible when printed” only after repeated chasers via the central helpline, and nothing was progressed until I chased again. Meanwhile, enforcement agents attended my home twice and have threatened further action. The exposure to enforcement exists solely because the court failed to process an already-filed application seeking a stay.
I respectfully ask that a District Judge considers this today on the papers and makes an interim order:“Until determination of the Defendant’s application issued 17/09/2025, enforcement and registration of the judgment are stayed. Costs reserved.”
Please also (1) treat the application as issued on 17/09/2025 for all purposes, and (2) expedite referral to a District Judge for determination.
Attachments:1. Draft Interim Order (1 page)
2. N244 bundle filed 17/09/2025 (or filing receipts if file size limits apply)
3. DCBL letters/attendance notes
4. Supplemental Note setting out the administrative failures and timeline (1 page)
Please confirm by return that this has been placed before a District Judge today.
Yours faithfully,
[Full name]
[Postal address]
[Phone]
[Email]
[Claim number]
Here is the Draft Interim Order (attach as PDF):QuoteDRAFT INTERIM ORDER
IN THE COUNTY COURT AT UXBRIDGE
Claim No: [ ]
Between: [UK Parking Control Ltd] (Claimant) and [Defendant full name] (Defendant)
UPON the Defendant’s application issued on 17 September 2025 to set aside/vary the order striking out the Defence and entering judgment, for relief from sanctions, reinstatement and permission to amend
AND UPON the risk of enforcement created by administrative delay
IT IS ORDERED THAT:1. Until determination of the Defendant’s application issued 17 September 2025, enforcement and registration of the judgment are STAYED.
2. Costs reserved.
Dated: [leave blank for court]
Use the following for the Supplemental Note you are attaching to the email. (1 page, attach as PDF):QuoteSUPPLEMENTAL NOTE
At the same time email the following to DCB Legal (not DCBL):
Title: Supplemental Note – Administrative Delay and Urgent Interim Stay1. This is not a routine administrative delay. It is a sequence of preventable failures by the court office that have left an issued application unprocessed for weeks, exposed me to enforcement, and created avoidable prejudice.
2. I filed the N244 and bundle on 17/09/2025 and received immediate automated acknowledgements. Despite this, the application was not entered onto the system.
3. Different staff then required me to re-submit the same documents multiple times. Each re-submission was acknowledged, yet the application still was not actioned.
4. The court asked for a “legible” copy of a financial document only after I chased repeatedly; until prompted by the central helpline, the court did not even inform me that they “could not print” the document. I supplied a clear PDF the same day. No progress followed.
5. Only today, 30/10/2025, 43 days later, was my 17/09/2025 application finally “put on the system”. This is over 6 weeks after first filing and only after persistent chasers.
6. During this period of inaction, enforcement agents attended my home twice and threatened further action. That exposure exists solely because the court failed to process an already-filed application that seeks, among other things, a stay of enforcement.
7. These are not mere backlogs. They are operational failures: acknowledged filings not actioned; re-submissions requested then ignored; an avoidable printing issue allowed to stall the file without telling the party; and basic case-entry not performed until today.
8. I respectfully ask the Court to treat my application as issued on 17/09/2025, to grant an interim stay on the papers immediately, and to expedite the referral to a District Judge so that the application can be determined without further prejudice.
[Name]
[Date]QuoteSubject: [Claim no.] – Application filed 17/09/2025 – immediate suspension of enforcement required
Dear Sirs,
1. I filed an N244 on 17/09/2025 to set aside/vary the paper strike-out and judgment, for relief from sanctions, reinstatement, permission to amend, and a stay. I have multiple automated acknowledgements from that date and subsequent re-submissions at the court’s request.
2. Due solely to the court office’s administrative failures, the application was only entered on the system today. That delay is not mine. I have been actively chasing and providing any further documents immediately when asked.
3. I have today requested an interim stay on the papers. In the meantime, you are on notice that any further enforcement action will be placed before the Court as unreasonable conduct for costs purposes (CPR 27.14(2)(g)) given the pending application and the fact that the delay in logging it is entirely the Court’s.
4. Please confirm by 4pm today that you will:a) suspend all enforcement, and
b) instruct DCBL to place the file on hold for 28 days pending the Court’s decision on the interim stay (or any earlier order).
5. If you agree, I invite you to confirm a short consent order in these terms:“By consent, enforcement and registration of the judgment are stayed for 28 days, pending determination of the Defendant’s application filed 17/09/2025, or further order.”
6. If you refuse or do not respond by the deadline, this email will be exhibited to the Court with my stay request and at any costs hearing.
Please acknowledge safe receipt and confirm your position by 4pm.
Yours faithfully,
[Full name]
[Postal address]
[Email]
Email the following to DCBL (not DCB Legal):QuoteSubject: [Your name] – [Claim no.] – Application filed 17/09/2025 – interim stay requested – immediate hold required
Dear Sir/Madam,
A court application to set aside/vary the order and judgment was filed on 17/09/2025 and is now logged. An interim stay has been requested today. This matter is actively before the court.
Place this account on immediate hold and suspend all attendances and enforcement action pending the court’s decision. Confirm in writing by 4pm today that the file is on hold.
Any further visit pending the court’s decision will be treated as unreasonable conduct and may be put before the court on costs.
[Name]
[Address]
[Claim no.]
[Warrant/writ number if any]
[Your DCBL reference if shown]
As soon as you've ent the emails, call the court and use there following as a script guide:QuoteHello, name is [Full name], Defendant in claim [Claim no.].
I’m calling to confirm receipt of my urgent email just sent to countycourtuxbridge@justice.gov.uk about an interim stay. Could you:1. Confirm you’ve received the email and all attachments.
2. Confirm it will be put before a District Judge today as urgent box-work.
3. Note on the file: “URGENT – Interim stay requested – application filed 17/09/2025 – enforcement active due to court delay.”
4. Give me the name of the person/action team putting it before the Judge and a reference/note ID.
5. Tell me the correct inbox for urgent box-work (so I can re-send now if needed).
6. Email me a one-line acknowledgement today confirming it’s gone to the Judge.
7. If you can’t confirm that: please transfer me to the listing officer/manager now, or log a priority task with that wording and give me the task reference.
I’ll hold while you check.
(After they confirm) Thanks. Please repeat back what you’ve done, your name, and the time.
If they won't confirm, then you'll need to do the following:QuoteIf they won’t confirm:
1. Say: “Please transfer me to the listing officer or duty manager now.”
2. If they refuse: “Then please log a priority task on the file with this wording and give me the task reference before we end the call: ‘URGENT – Interim stay requested – application filed 17/09/2025 – enforcement active due to court delay – place before DJ today as box-work.’”
3. If they still refuse: “Please read back your full name, team, and the time of this call. I’m noting that you are unable to confirm receipt or escalation".
Then do these immediately (no new application):4. Re-send your stay email with subject prefixed: “SECOND REQUEST – URGENT – Interim stay – [Claim no]”. Attach the same bundle.
5. Send the same email to any alternative court inbox you have and CC yourself.
6. Print the email + draft order and hand a paper set in at the court counter in an envelope marked on the front: “URGENT – INTERIM STAY – PLACE IN JUDGE’S BOX TODAY – [Claim no]”. Ask for a stamped receipt.
7. Email DCB Legal and DCBL: “Court has been called; escalation refused/no confirmation given. Second urgent stay request sent and paper set lodged at counter. Hold enforcement pending the court’s decision.”
8. Make a one-paragraph note and email it to the court (same thread): “Call log – [time]: [name] refused/was unable to confirm receipt or escalation; priority task requested/not created. Please place before a DJ today.”
One-line script to close the call if/when they stonewall:“Thank you. I will record that you cannot confirm receipt or escalation. I am now lodging a paper set at the counter and sending a second urgent email for placement before a judge today.”
I suggest you do not live any downstairs doors or windows unlocked. Do not leave any property outside. If you cannot keep your car in a locked garage, then do not park it outside your property. Leave it in a different location.
DOORSTEP SCRIPT (keep by the door):Quote“I have an application issued on 17 September 2025 and I have requested an interim stay today. I will not let you in. Please leave now and contact your office.”
Do not sign anything. Do not hand over goods. Move your vehicle away from the property if possible.)
Finally, you need to lodge a formal complaint to HMCTS about this FUBAR by them. -
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...
Thanks a lot for the support. Received a letter today. See below:
https://ibb.co/Gv31SXK4
My only question is: this letter is dated the 10th of November and asks for a defence to be filed by the 17th. Is the defence I re-submitted based on your advice above what they are referring to and hence sufficient?
Is there any other action I need to take? I notice it mentiones serving other documents and witness statements but again I have done this so I assume I don't need to do it once more. -
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What you must do right now:
Submit the defence below as a PDF attachment together with a copy of the order to the court with the following email to the court at mailto:countycourtuxbridge@justice.gov.uk and CC info@dcblegal.co.uk and yourself. You only need to edit your full name, the claim number and you can sign it by just typing your full name:QuoteSubject: Defence – late filing – please accept out of time – [Claim no.] – UK Parking Control Ltd v [Defendant full name]
Dear Court,
I received the order sealed 10/11/2025 today 21/11/2025. Paragraph 2 required a Defence by 4pm on 17/11/2025. I could not comply as the order was only received today.
Please accept the attached Defence out of time and extend time for compliance to today under the Court’s case-management powers. The delay is short; no trial date is affected; I have acted promptly upon receipt.
Orders sought on the papers:1. The late Defence is accepted and deemed filed and served today.
2. Time for compliance with para 2 of the order is extended accordingly.
3. Costs reserved.
Attachments:• Defence (PDF)
• Copy of the order received today
I have copied in the Claimants legal representative with this email.
Yours faithfully,
[Name]
[Address]
[Email]
[Claim no.]
Use this defence:QuoteIN THE COUNTY COURT AT UXBRIDGEClaim No: [Claim Number]BETWEEN:
UK Parking Control Ltd
Claimant
- and -
[Defendant's Full Name]
Defendant
DEFENCE (pursuant to order dated 10/11/2025)
1. The Defendant denies the claim in its entirety. No liability is admitted and no debt is owed.
2. The Defendant was the registered keeper of [VRM]. The Defendant does not admit being the driver on 03/12/2023, 07/01/2024 or 21/01/2024. If the Claimant relies on PoFA 2012 Schedule 4, strict compliance is denied.
3. The Particulars of Claim are inadequately particularised and do not comply with CPR 16.4 and PD16 7.3. No contract is attached or set out; the pleaded facts and quantum breakdown are insufficient.
4. In response to PoC §§1–2, it is not admitted that any parking charge was properly incurred at Uxbridge Road Retail Park on the dates pleaded. The Claimant is put to strict proof, for each date separately, of any period of parking, the vehicle’s position, and that bay markings were clear and enforceable at the time.
5. In response to PoC §3 (“not parked correctly within the markings”), breach is denied. The Claimant is put to strict proof that a clear and prominent contractual term required strict bay compliance with an associated charge, that such term was transparently conveyed at the entrance and on-site, that it was a contractual offer (not a prohibition), and that any departure was more than de minimis.
6. In response to PoC §4 (keeper liability), PoFA reliance is denied. The Claimant is put to strict proof, for each PCN, of full statutory compliance including identification of the creditor, specification of a period of parking, mandatory wording/invitations, and all applicable time limits.
7. Standing is not admitted. The Claimant is put to strict proof of landowner authority to contract for parking and to litigate in its own name at this site on the material dates.
8. Quantum is denied. The global figure of £510 is unparticularised; no lawful basis is pleaded for any sums beyond any principal charge (which is denied). Section 69 CCA 1984 interest is discretionary and not properly pleaded.
9. Each PCN is a separate event. The Claimant must prove liability and (if relied upon) PoFA compliance for each date; aggregation cannot remedy failures of proof.
10. The Defendant invites strike-out for failure to comply with CPR 16.4. In the alternative, the Defendant seeks an order that within 14 days the Claimant serve Further and Better Particulars identifying the exact terms relied upon and how incorporated, whether driver or PoFA keeper liability is pursued with the facts said to found it, a contemporaneous site plan and all signage/photos for each date, and a full breakdown of sums; with permission to amend within 14 days thereafter.
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:
Separately, email the following to DCB Legal and CC yourself:QuoteSubject: Judgment set aside — immediate cessation of enforcement and recall request — [Claim no.] — UK Parking Control Ltd v [Defendant full name]
To: info@dcblegal.co.uk
Attachments: Sealed Order dated 10/11/2025 (copy)
Dear Sirs,
Please note the Court’s sealed Order dated 10/11/2025 (attached) setting aside the judgment. Consequently, all enforcement must cease immediately.
Please confirm by 4:00pm Monday 24 November 2025 that you have:1. Instructed your enforcement agents (DCBL) to place the file on immediate hold and cease all attendance and action;
2. Requested recall of any warrant of control (County Court) and/or writ of control (High Court), and provided the recall request reference;
3. Notified the Court (and, if applicable, the King’s Bench/High Court Enforcement Officer) of the set-aside and recall;
4. Confirmed that no registration of the set-aside judgment will be attempted and that any prior registration or credit file entry (if made) will be removed forthwith;
5. Confirmed that no further enforcement fees will be added and that any sums taken post-order (if any) will be refunded.
For the avoidance of doubt, any continued enforcement following the set-aside will be placed before the Court as unreasonable conduct and a matter for costs.
Please acknowledge safe receipt and provide the confirmations and references requested by the deadline above.
Yours faithfully,
[Defendant full name]
[Postal address]
[Email]
[Claim number]
Nothing else for now. Any other documents will have deadline based on whatever date a hearing is scheduled for. -
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