Author Topic: UK Parking Control LTD - notice of debt recovery - longer than permitted  (Read 4921 times)

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ok now I've got a legal claims letter asking for £260 from HM courts and tribunals.. What do I do now?

Show us the letter.

here you go.

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With an issue date of 3rd July, you have until 4pm on Tuesday 22nd July to submit your defence. If you submit an Acknowledgement of Service (AoS) before then, you would then have until 4pm on Tuesday 5th August 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 UK Parking Control Ltd v [your full name] Claim no.: [claim number]."

Quote
IN THE 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. 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 16.7.3(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 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
Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain

Thanks for this.

I'm not clear - do I need to do this AoS as well as send over the email or not?

Also - can you explain what exactly I am contesting here so I know what I'm getting myself into?

You only need to do the AoS if you need more time to prepare the defence. It's not required normally.

You are contesting a claim made against you by UKPC for an alleged breach of contract by the driver. If you do nothing, you will get a CCJ by default and unless it is paid within 30 days of the judgment, it will remain on your credit file for the next 6 years and cause you untold financial pain.

If you follow the advice given here, this will all end in the next few months when the claim is either struck out or discontinued.

You choice. You either trust the advice or go iy alone or find a solicitor who will have a fraction of the knowledge we have about these matters and you will likely be paying more than if you were to just pay the claim amount.
Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain

Forgive my ignorance, I just wanted to have some awareness of what I'm doing, what my defense is. After reading up, I think I understand it.

Thanks for your help!
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Re: UK Parking Control LTD - notice of debt recovery - longer than permitted
« Reply #22 on: »
Latest update here:

I sent in my defense by email as advised.

I have now received a 'notice of proposed allocation to the small claims track' and I need to fill out a questionnaire.
Apparently a copy of the defense has been sent to me - not received it.
and it is suitable for allocation

Any advice welcome.

Re: UK Parking Control LTD - notice of debt recovery - longer than permitted
« Reply #23 on: »
You misunderstand slightly. What you have received is a copy of the Notice of Proposed Allocation. The Claimants solicitor received the same notice and it is they who received a copy of your defence. The version sent to you should have had that bit crossed out.

Before we continue, was the N1SDT Claim Form you received signed by a Sarah Ensall? Also, you should have had a letter from DCB Legal after you submitted your defence that said their client intended to proceed and would normally have included a copy of their N180 Directions Questionnaire (DQ). If so, what is the name of the person who signed it and in what capacity (paralegal?)

If the notice you just received includes a blank N180 DQ, you DO NOT fill anything out and you can discard all the forms that ask about persona finance etc. Just follow this advice:

Quote
Having received your own N180 (make sure it is not simply a copy of the claimants N180), do not use the paper form. Ignore all the other forms that came with it. you can discard those. Download your own 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.

However, please answer the questions about who signed the claim form with the PoC and their copy of the N180DQ.
Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain

Re: UK Parking Control LTD - notice of debt recovery - longer than permitted
« Reply #24 on: »
The N1SDT form was from Sarah Esnall (not actually signed if that makes a difference). Separately I got a letter from the court confirming they received my defence .

I didnt get any correspondence from DCB after my defence.

The letter now came with a N180 form - all that is filled in is the claim number.



Re: UK Parking Control LTD - notice of debt recovery - longer than permitted
« Reply #25 on: »
Any document filed electronically does not have to have a "wet" signature. It only needs the persons name typed in full.

The N1SDT Claim Form has been signed by Sarah Ensall who is not authorised to conduct litigation.

Once your defence is received by the CNBC, they acknowledge receipt and inform you that they are sending a copy of it to the claimant and that you will hear back once they have received their copy. Did you not receive a letter from DCB Legal confirming that they had received a copy of your defence and that their client intends to proceed? That letter usually includes a copy of their N180DQ and is usually signed by someone with [initial]. [last name] and is usually a paralegal.

They may not have sent that yet.

Anyway, for now, you should email DCB Legal at info@dcblegal.co.uk and CC yourself with eh following:

Quote
Subject: Claim [insert court reference] – N1SDT Claim Form signed by Sarah Ensall: authority to conduct litigation, and regulatory notice

Dear Sir/Madam,

I refer to the Claim Form (N1SDT) filed/served in this matter. The document is signed by Sarah Ensall, position stated as Head of Legal, and purports to be signed on behalf of the Claimant’s solicitor.

Please confirm by return:
1. Their role, and whether they are an authorised person within the meaning of the Legal Services Act 2007 with current rights to conduct litigation (provide SRA or CILEX number and practising status). If not authorised,
2. The precise exemption relied upon under Schedule 3 of the Legal Services Act 2007 that permits this individual personally to conduct litigation and sign this document in these proceedings (if relying on a court order, provide the sealed order; if relying on an enactment, identify it precisely).

For the avoidance of doubt:
• Preparing, signing, filing, or serving [insert document name] is an act of conducting litigation, a reserved legal activity.
• Practice Direction 22 requires the signatory’s full name and capacity when signing on behalf of a party; initials only are not sufficient for verification of authorisation.
• Following Mazur v Charles Russell Speechlys LLP [2025], unqualified employees may assist but cannot themselves conduct litigation unless authorised or exempt.

Action required:
• Confirm the above within 7 days.
• If the document was not signed by an authorised (or exempt) person, re-file and serve a compliant version personally signed by an authorised individual, with their full name clearly stated.

Costs and regulatory notice:
If the document was signed by a person not authorised or exempt, or must be re-filed/served to correct the signatory’s identity/status, I, as a litigant in person, will treat this as unreasonable conduct. In line with Mazur and CPR 27.14(2)(g), I will invite the Court, in its discretion, to order the Claimant to pay the Defendant’s costs caused by your firm’s irregular conduct, and, if appropriate, to consider wasted costs against representatives.

Further, carrying on a reserved legal activity without entitlement is a criminal offence under the Legal Services Act 2007. If any unauthorised conduct of litigation has occurred, I will report the matter to the Solicitors Regulation Authority without further notice and reserve the right to place this correspondence before the Court.

Yours faithfully,

[Full Name]
[Postal Address]
[Email]
Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain

Re: UK Parking Control LTD - notice of debt recovery - longer than permitted
« Reply #26 on: »
Thanks for this - just to be clear I shouldn't fill out the N180 for now?

Re: UK Parking Control LTD - notice of debt recovery - longer than permitted
« Reply #27 on: »
If what you have received is a blank N180 DQ and not just a copy of the claimants DQ, then yes, you should complete it:

Quote
Having received your own N180 (make sure it is not simply a copy of the claimants N180), do not use the paper form. Ignore all the other forms that came with it. you can discard those. Download your own 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

Re: UK Parking Control LTD - notice of debt recovery - longer than permitted
« Reply #28 on: »
Just wondering about this Sarah Ensall - her position is 'claimants Legal Representative as defined by CPR 2.3(1)' - just making sure the email I should send is still valid?

Re: UK Parking Control LTD - notice of debt recovery - longer than permitted
« Reply #29 on: »
Yes, you shoul still send that email. Here is why...

That wording – “in accordance with CPR 2.3(1)” – is basically DCB Legal’s boilerplate attempt to make the sign-off look compliant.

Here’s what it refers to:
• CPR 2.3(1) is in the definitions section of the Civil Procedure Rules.
• It defines, amongst other things, what a “legal representative” means:
“Legal representative” means a barrister, solicitor, solicitor’s employee or other authorised litigator (as defined in the Legal Services Act 2007) or a person authorised under the Legal Services Act 2007 to conduct litigation.

So, when they write “Claimant’s Legal Representative as defined by CPR 2.3(1)”, they are asserting that the signatory (e.g. Sarah Ensall) falls into one of those categories.

Why it matters:
• It doesn’t prove authorisation – it’s just a self-certification.
• If the signatory isn’t an authorised person under the Legal Services Act 2007 (or exempt), then describing themselves as a “legal representative under CPR 2.3(1)” is misleading.
• This goes to the point highlighted in Mazur v Charles Russell Speechlys LLP [2025]: only authorised (or exempt) individuals can actually “conduct litigation.” Employees can assist under supervision, but cannot sign/act as the litigating representative themselves.
• Therefore, the reference to CPR 2.3(1) is an assertion of status, and you are entitled to demand proof (SRA number, exemption relied on, etc.).

In short: it’s DCB Legal trying to cloak the signature with CPR authority, but unless the person is actually authorised or exempt, the words don’t cure the defect.
Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain
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