Author Topic: PCN - Parked in a disabled bay without displaying valid Disabled badge Grove Farm Retail Park Chadwell Heath. RM6 4BN  (Read 6398 times)

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You don't fill in any of the forms. I have given you instructions on what you need to do in my previous post. You just need to log into your MCOL portal and submit an Acknowledgement of Service (AoS) or, if you do not need extra time to file your defence, just copy and paste the defence provided above.
Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain

I've checked everywhere but I don't see an option for logging into MCOL or having a previous account. Can anyone point me to a link that I can do this?

thanks

The N1SDT form you posted in Reply #26

Which you left with claim number and password clear to see!
« Last Edit: October 01, 2025, 01:27:24 pm by jfollows »

I have found it seconds after posting that sorry for the troubles and have now submitted the defence as instructed:
Claim History
A claim was issued against you on 12/09/2025

Your defence was submitted on 01/10/2025 at 12:41:26

Your defence was received on 01/10/2025 at 14:05:10

Here is the link for anyone that needs it in future: https://www.moneyclaim.gov.uk/

Defence and Counterclaim
Claim number
ClaimantG24 Limited
Defendant
 
How much of the claim do you dispute?
I dispute the full amount claimed as shown on the claim form.
 
Do you dispute this claim because you have already paid it?
No, for other reasons.
 
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 adequately 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 PD 16, para 7.3(1);

(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 submits that courts have previously struck out
materially similar claims of their own initiative for failure to
adequately comply with CPR 16.4, particularly where the
Particulars of Claim failed to specify the contractual terms
relied upon or explain the alleged breach with sufficient clarity.

5. In comparable cases involving modest sums, judges have found
that requiring further case management steps would be
disproportionate and contrary to the overriding objective.
Accordingly, strike-out was deemed appropriate. 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
due to the Claimant’s failure to adequately comply with CPR 16.4,
rather than permitting an amendment. The Defendant proposes that
the following Order be made:

Draft Order:

Of the Court's own initiative and upon reading the particulars of
claim and the defence.

AND the court being of the view that the particulars of claim do
not adequately comply with CPR 16.4(1)(a) because: (a) they do
not set out the exact wording of the clause (or clauses) of the
terms and conditions of the contract which is (or are) relied on;
and (b) they do not adequately set out the reason (or reasons)
why the claimant asserts that the defendant was in breach of
contract.

AND the claimant could have complied with CPR 16.4(1)(a) had it
served separate detailed particulars of claim, as it could have
done pursuant to PD 7C, para 5.2, but chose not to do so.

AND upon the Court determining, having regard to the overriding
objective (CPR 1.1), that it would be disproportionate to direct
further pleadings or to allot any further share of the Court’s
resources to this claim (for example by ordering further
particulars of claim and a further defence, with consequent case
management).

ORDER:

1. The claim is struck out.

2. Permission to either party to apply to set aside, vary or stay
this order by application on notice, which must be filed at this
Court not more than 7 days after service of this order, failing
which no such application may be made.
 
Signed
I am the Defendant - I believe that the facts stated in this form are true

 
Address to which notices about this claim can be sent to you
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Good morning everyone,

I’ve now received an email from DCB Legal (bulklitigation@dcblegal.co.uk) following the submission of my defence. Here’s what they’ve said:

“Having reviewed the content of your defence, we write to inform you that our client intends to proceed with the claim.

In due course, the Court will direct both parties to each file a directions questionnaire. In preparation for that, please find attached a copy of the Claimant's, which we confirm has been filed with the Court.

Without prejudice to the above, in order to assist the Court in achieving its overriding objective, our client may be prepared to settle this case - in the event you wish to discuss settlement, please call us on 0203 434 0433 within 7 days and make immediate reference to this correspondence.

If you have provided an email address within your Defence, we intend to use it for service of documents (usually in PDF format) pursuant to PD 6A (4.1)(2)(c). Please advise if there are any limitations to this.”

They’ve also attached a draft N180 Directions Questionnaire (Small Claims Track), which they say has already been filed with the court.

A few questions for guidance:

Should I be filling out my own N180 form now, or wait until I receive the official one from the court?

Is it normal for DCB Legal to send their copy directly like this before the court’s instructions arrive?

Should I respond to their “settlement offer” or just ignore that part completely?

Finally, should I reply to confirm my email address can be used for future correspondence, or stay silent?

I haven’t responded to them yet — just wanted to check with you all before taking any action.

Thanks in advance for any help or suggestions.

Here's the link to Google Drive as this post is no longer allowing me to upload files or images

https://drive.google.com/drive/folders/1XP0QFXld_Eikd185aPLFVhI0pBmzXN3F?usp=sharing

You can check your MCOL history and when it updates to show that your N180 DQ has been sent, you can apply the following:

Quote
Having received your own N180 (make sure it is not simply a copy of the claimants N180) or been notified on MCOL that yours has been sent, do not use the paper form. Ignore all the other forms that came with it. you can discard those. Download your own N180 DQ here and fill it in on your computer. You sign it by simply typing your full name in the signature box.

https://assets.publishing.service.gov.uk/media/673341e779e9143625613543/N180_1124.pdf

Here are the answers to some of the less obvious questions:

• The name of the court is "Civil National Business Centre".

• To be completed by "Your full name" and you are the "Defendant".

• C1: "YES"

• D1: "NO". Reason: "I wish to question the Claimant about their evidence at a hearing in person and to expose omissions and any misleading or incorrect evidence or assertions.
Given the Claimant is a firm who complete cut & paste parking case paperwork for a living, having this case heard solely on papers would appear to put the Claimant at an unfair advantage, especially as they would no doubt prefer the Defendant not to have the opportunity to expose the issues in the Claimants template submissions or speak as the only true witness to events in question
.."

• F1: Whichever is your nearest county court. Use this to find it: https://www.find-court-tribunal.service.gov.uk/search-option

• F3: "1".

• Sign the form by simply typing your full name for the signature.

When you have completed the form, attach it to a single email addressed to both dq.cnbc@justice.gov.uk and info@dcblegal.co.uk and CC in yourself. Make sure that the claim number is in the subject field of the email.
Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain

Thanks for the detailed guidance — really helpful.

Just to confirm, I haven’t actually received anything from the Civil National Business Centre yet. The only N180 I’ve got is the Claimant’s draft version that DCB Legal emailed to me.

Should I wait until the court sends me my official N180 (or it shows as “sent” on MCOL) before I complete and submit my own version?

I just want to be sure I don’t send it prematurely.

thanks

Thanks for the detailed guidance — really helpful.

Just to confirm, I haven’t actually received anything from the Civil National Business Centre yet. The only N180 I’ve got is the Claimant’s draft version that DCB Legal emailed to me.

Should I wait until the court sends me my official N180 (or it shows as “sent” on MCOL) before I complete and submit my own version?

I just want to be sure I don’t send it prematurely.

Yes. Either wait for yours to arrive in the post and then follow the advice or as soon as your MCOL updates with the info it has been sent, then you can email yours in.
Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain

Hi ive filled out the N180 form can someone tell me if im missing anything or is this now fine to send to the court and g24 ltd

https://drive.google.com/file/d/1sKC3xqLb7iwwb7_Ti8z-2zOEoelx7ED0/view?usp=drivesdk

Link above

Why are you filling in a paper form. I gave you the advice on how to download and fill in on a computer. You have left some obvious Yes/No tick boxes. This is not rocket science to complete a simple form.

No need to use paper. Simply complete the PDF form on your computer and attach it as a single email addressed to both the court and thee claimants solicitor. No dead trees, no trudging to the post office, instantaneous delivery and evidence of receipt y the court and of sending to the claimant.
Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain

Read Section A at the start of the form and complete Section E with your details.

Thanks for all your help and support so I have followed instructions to send it via online form and I've just one question shall I

A. Stick to the original D1 answer -

I wish to question the Claimant about their evidence at a hearing in person and to expose omissions and any misleading or incorrect evidence or assertions. Given the Claimant is a firm who complete cut & paste parking case paperwork for a living, having this case heard solely on papers would appear to put the Claimant at an unfair advantage, especially as they would no doubt prefer the Defendant not to have the opportunity to expose the issues in the Claimants template submissions or speak as the only true witness to events in question.

or

B. Use my amended version not that I know better just including more information -

I wish to question the Claimant about their evidence at a hearing in person to ensure a fair and accurate examination of the facts. My vehicle was broken down at the time of the alleged contravention, which was beyond my control.

Given that the Claimant is a commercial firm that routinely submits template parking case paperwork, there is a risk that important details specific to this case may be missing or unclear. Allowing me to question the Claimant in person will enable the court to clarify any omissions or inaccuracies, confirm the evidence, and ensure that the decision is based on a complete and truthful account of the circumstances.
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I think I'd go with option 1. The directions questionnaire is generally not the place to argue your defence. At any rate, I'm not sure that the nature of events on the day is on its own a convincing reason to require a hearing in-person. The reason is because you want to be able to question the claimant.

I agree.
The first version has been used countless times and has never failed to work. People who have varied the N180 submission from the advice normally given here have sometimes got themselves in a mess because of it.

Perfect thanks for everyone's time I have now sent off my n180 following your instructions. I shall await mediation appointment and follow up with everyone. I'll attempt to have a text written transcript of the call for all future cases.