Hi all,
looking for some advice on how to proceed with a letter before claim from moorside legal.
Background story; received a parking ticket in my own flat parking space after permit 'not displayed' back in 2022, permit was on drivers seat. Initially disputed the claim with the parking company but was obviously rejected.
Ignored initial letters and 'debt' (now being referred to as an invoice) was passed between companies, now has landed with moorside legal.
They sent me a Letter of claim back in June 2025, this was disputed and my response sent was as follows after using some advice from other forums:
""Your Ref. 10028432
Proposed Legal Proceedings
Claimant: Parking Control Management UK Ltd
I refer to your letter of claim.
I confirm that my address for service for the time being - assuming you don't faff about and delay any claim - is as follows, and any older address must be erased from your records:
REDACTED
The alleged debt is disputed and any court proceedings will be vigorously defended.
I am sourcing and seeking independent debt advice and as such, I formally request that this matter be put on hold for an additional 30 days, in accordance with the Pre-Action Protocol for Debt Claims 2017 ('the PAP').
I note that the amount being claimed has increased by a hugely exaggerated amount which the Government called "extorting money from motorists".
Don't send me your usual blather about that.
The alleged debt is wholly disputed on the grounds as follows:
1:Under the terms of the lease, as stated "The right to park one roadworthy taxed and MOT'd vehicle not exceeding 2.25 tonnes gross unladen weight in the Parking Space" - There are no terms within the lease requiring lessees to display parking permits, or to pay penalties to third parties, such as the Claimant, for non-display of same.
2: The underground car parking area contains allocated parking spaces demised to some residents. Entry to the underground parking is by means of a key fob, of a type only issued to residents. Any vehicles parked therein are, therefore, de facto authorised to be there.
3: The vehicle clearly was 'authorised' as per the lease and the individual relies on primacy of contract and avers that the Claimant's conduct in aggressive ticketing is in fact a matter of tortious interference, being a private nuisance to residents
4: The vehicle had a copy of said 'required permit' onboard at the time of the 'contravention'
I have two questions, and under the PAP I am entitled to specific answers:
1. Am I to understand that the additional £60 represents what you lot dress up as a 'Debt Recovery' fee, and if so, is this net or inclusive of VAT? If the latter, would you kindly explain why I am being asked to pay the operator’s VAT?
2. With regard to the principal alleged PCN sum: Is this damages, or will it be pleaded as consideration for parking?
Yours faithfully""
They responded with a generic response saying that as I entered and parked on 'their private land' I entered into a contract with them and the fine is valid.
They then sent a letter before claim last week, this was non compliant with the Pre-Action Protocol for Debt Claims, I responded again with an email but using information from this forum:
""Dear Sirs,
Your so-called “Letter Before Claim” is a masterclass in procedural non-compliance. It reads less like a legal document and more like a payday loan advert—complete with “friendly team” and “flexible payment plans.” Charming, but irrelevant.
Let me be clear: this is not a compliant Letter Before Claim under the Pre-Action Protocol for Debt Claims. It fails to provide:
• The basis of the alleged claim as per guidance point 6.(a) taken from the pre-action conduct practice direction
• Any evidence whatsoever (no NtK, no signage, no landowner authority, no contract terms)
• A breakdown of the sum claimed (is the £160 damages, consideration, or just wishful thinking?) as per guidance point 6.(a) taken from the pre-action conduct practice direction
• Copies of key documents relied upon as per guidance point 6.(c) taken from the pre-action conduct practice direction
Your letter is devoid of substance, legal reasoning, and basic compliance. It does not enable informed dialogue, nor does it satisfy the requirements of paragraphs 3.1(a)–(d), 5.1, or 5.2 of the Protocol. It is procedurally defective and legally meaningless.
Should proceedings be issued on the back of this nonsense, then I put you on notice that I will be relying on the cases of Webb Resolutions Ltd v Waller Needham & Green [2012] EWHC 3529 (Ch), Daejan Investments Limited v The Park West Club Limited (Part 20) Buxton Associates [2003] EWHC 2872, Charles Church Developments Ltd v Stent Foundations Limited & Peter Dann Limited [2007] EWHC 855 in asking the court to impose sanctions on your client and to order a stay of the proceedings, pursuant to paragraphs 13, 15(b) and (c) and 16 of the Practice Direction, as referred to in paragraph 7.2 of the Protocol.
Unless a compliant Letter Before Claim is issued, I will be referring this matter to the Solicitors Regulation Authority (SRA) under Rule 1.4 and Rule 2.1 of the SRA Code of Conduct for Firms, on the basis that your conduct:
• Misrepresents the legal status of the claim
• Fails to uphold proper standards of legal service
• Demonstrates a lack of integrity and competence in pre-action procedure
Should your client issue proceedings based on this defective LoC, I will present it to the court as evidence of unreasonable conduct and procedural non-compliance. I will seek:
• An immediate stay under paragraph 15(b) of the Practice Direction
• A costs order under CPR 27.14(2)(g) for unreasonable behaviour
• Sanctions under paragraphs 13 and 16 of the Practice Direction
I also refer you to my previous correspondence with yourselves, email dated 15th June 2026. You have failed to update vital information where it was stated that you are to update my correspondence address, I will recite this to yourselves now to make it easier for you:
REDACTED
In addition to this I will also recite the grounds on which the alleged ‘unpaid invoice’ is wholly disputed as follows:
1:Under the terms of the lease of the property, as stated "The right to park one roadworthy taxed and MOT'd vehicle not exceeding 2.25 tonnes gross unladen weight in the Parking Space" - There are no terms within the lease requiring lessees to display parking permits, or to pay penalties to third parties, such as the Claimant, for non-display of same.
2: The underground car parking area contains allocated parking spaces demised to some residents. Entry to the underground parking is by means of a key fob, of a type only issued to residents. Any vehicles parked therein are, therefore, de facto authorised to be there.
3: The vehicle clearly was 'authorised' as per the lease and the individual relies on primacy of contract and avers that the Claimant's conduct in aggressive ticketing is in fact a matter of tortious interference, being a private nuisance to residents
4: The vehicle had a copy of said 'required permit' onboard at the time of the 'contravention'
You refer in your email dated 13 August 2025 to the fact that, quote, “By entering and parking the vehicle on our client's private land, you agreed to enter into a contract with our client and to be bound by the terms and conditions of that contract.
On this term you have made the mistake of assuming that the land belonged to the ‘client’ when in actual fact the land, i.e, the parking space belonged to myself as part of the leasehold, the client does and did not own the land at any time. This is backed up by the fact that the Lease states that ‘the leese has the right to park one roadworthy taxed and MOT'd vehicle not exceeding 2.25 tonnes gross unladen weight in the Parking Space’ with said parking space being illustrated on title deeds with the land registry.
If your client wishes to pursue this matter, I suggest they instruct solicitors capable of drafting a compliant Letter of Claim. Until then, I am under no obligation to respond further.
Yours faithfully,""
they responded with a generic email giving a 'breakdown' of the additional fees saying that 'The £60 does not represent the cost of recovery but it is a reasonable amount in relation to the parking charge'. They also provided some pictures of the vehicle in question and some signage but still haven't provided a compliant LOC, they also 'demanded' payment within 7 days of the email being received...
any ideas on how this can be dealt with? or best wait until a court summons is issued to fight there, obviously not wanting to pay this as I was entitled to park in the parking space as dictated by the lease, in addition, the lease did not include information relating to any parking scheme in operation.
I appreciate the thread is long but thanks in advance!
