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#Post#: 112434--------------------------------------------------
N1SDT Claim Form - DCB Legal / Eurocarparks
DIR By: frankster
Date: March 8, 2026, 12:22 pm
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28th Feb I received an NS1DT Claim Form:
HTML https://ibb.co/v4MZjd4S
I would appreciate help with my response/defence.
Timeline
* Ticket purchased at machine, car left area within purchased
time. ECP claim error entering registration into machine.
* Sign at entrance merely requests full reg is entered
HTML https://ibb.co/Qvc7FWHm
* Notice To Keeper Received
HTML https://ibb.co/TB8fx3Xq
and
HTML https://ibb.co/HDyZQNrD
* Appealed to ECP - Rejected
HTML https://ibb.co/FbLYcrss
and
HTML https://ibb.co/VWBvcVsQ
* Appealed to POPLA - Rejected
* Letter of Claim received.
HTML https://ibb.co/zTSCcrkM
* Replied via DCB Legal website asking for certain documents. No
response received.
* NS1DT claim received
HTML https://ibb.co/v4MZjd4S
Not complied with pre-action protocol
It seems like DCB Legal may not have complied with PRE-ACTION
PROTOCOL FOR DEBT CLAIMS in two ways. Firstly by not enclosing
information sheet/reply form. Secondly by opening a claim
without waiting 30 days from the reply and without providing me
the documents I asked for.
3.1c "enclose a copy of the Information Sheet and the Reply Form
at
Annex 1 to this Protocol"
There was not an Information Sheet nor a Reply form enclosed
with the letter. Although they offer at the bottom of the letter
(
HTML https://ibb.co/zTSCcrkM)
to send a physical copy if I phone
then. Does this count at enclosing a copy?
4.2 "the creditor should not start court proceedings less than
30 days from
receipt of the completed Reply Form or 30 days from the creditor
providing
any documents requested by the debtor, whichever is the later."
The Letter of Claim was dated 22 Jan 2026. I replied 30 days
after the date of the letter on 21st Jan 2026. I replied via a
form on DCB Legal's website which they claim was a reply form,
althouh the form differed in some respects from the form in
Annex 1 of the PRE-ACTION PROTOCOL FOR DEBT CLAIMS. In my reply
I noted that they had not sent a reply for or information sheet.
I indicated that I needed certain information (maintenance
records/known issue list/certification the payment machine is
fit for purpose and free of detects,the Terms and COnditions
that ECP claim were in force, and a breakdown of the claimed
debt). I saved copies of the form that I submitted on my
computer.
I have not been sent any of the requested documents (in fact not
had any response at all), and then received a Claim From on 28th
Feb. This is less than 30 days after the reply.
Outline of Defence
This is how I'm thinking of defending:
1. disagree driver entered invalid reg, error in machine.
2. sign (
HTML https://ibb.co/Qvc7FWHm)
says "please enter full reg".
Why did they include "please" if it's a term and condition
rather than an optional request? Not a term and condition
2a. CRA 2015 - contract terms must be fair and transparent.
Disproportionate financial sanction for a paid for service is
unfair.
2b. CRA 2015 69Contract terms that may have different meanings
(1)If a term in a consumer contract, or a consumer notice, could
have different meanings, the meaning that is most favourable to
the consumer is to prevail.
3. Driver left within purchased time - ECP suffered no loss of
revenue, no overstay, no misuse of space
Therefore charge is punitive not protective (Legitimate interest
test form Beavis 2015 - complied in substance)
4. DCB Legal have substantially not complied with preaction
protocol so the case should be stayed or discontinued
Thanks in advance for any thoughts or advice shared..
#Post#: 112436--------------------------------------------------
Re: N1SDT Claim Form - DCB Legal / Eurocarparks
DIR By: InterCity125
Date: March 8, 2026, 12:38 pm
---------------------------------------------------------
Has the driver been revealed to the parking operator? (In either
appeal)
#Post#: 112442--------------------------------------------------
Re: N1SDT Claim Form - DCB Legal / Eurocarparks
DIR By: frankster
Date: March 8, 2026, 2:17 pm
---------------------------------------------------------
I've acknowledged that I'm the registered keeper of the vehicle
in both appeals. I've acknowledged paying for the ticket in the
POPLA appeal. I have not stated that I was the driver.
#Post#: 112449--------------------------------------------------
Re: N1SDT Claim Form - DCB Legal / Eurocarparks
DIR By: InterCity125
Date: March 8, 2026, 2:50 pm
---------------------------------------------------------
Please show us both appeals - we need to be clear on exactly
what they have as evidence - quite often appeals made where
someone states, "I bought a ticket" is pretty much an
acknowledgement that you were driving.
#Post#: 112455--------------------------------------------------
Re: N1SDT Claim Form - DCB Legal / Eurocarparks
DIR By: frankster
Date: March 8, 2026, 3:18 pm
---------------------------------------------------------
ECP appeal
HTML https://ibb.co/FbLYcrss
and
HTML https://ibb.co/VWBvcVsQ
POPLA APPEAL
Sorry for the formatting gore, this is the best I have as a
transcript.
Ground for appeal
The vehicle was not improperly parked
Appeal clarication
You were still within the time you paid for
What time did you park?
24/11/2024 11:30
What time did you leave the car park?
24/11/2024 14:00
How long did you pay for in the car park?
3 hours
Can you upload any evidence to support that you were still
within the time you paid for?
Appeal clarication
Your car parking ticket was clearly displayed
Where within your car did you display your parking ticket?
on the dashboard
Can you upload any evidence to support that your parking ticket
was in clear view?
-
Appeal clarication
The terms and conditions of the car park were not properly
signed
Why do you perceive that the terms and conditions of the car
park were not properly signed (for example where
they blocked, too small, or not showing)?
Eurocarparks claim I have made a "major keying error" but on the
sign at the entrace to the carpark there is no discussion of
a major keying error. Not one of those three words appears on
the sign even individually (see attached photo). Eurocarparks
seem to be construing a request on their sign "please enter full
vehicle registration" as a term and condition There are
various pieces of information on the sign at the entrance. Some
are in a small font, and some are in a large font. The block
I've highlighted in blue appears to be the terms and conditions
that motorists are expected to absorb and comply with. This
is suggested by the design - a bold font, plenty of space around
the writing to make it easy to read, and icons to structure it.
The block i've highlighted in red in the uploaded image is
written in a small font. Some of it is phrased as a request
("please
Appeal details Edit
extract of ECP spreadsheet containing my
payment
Motorist Ocial Document
enter..."), while some of it refers to another part of the
information as details rather than T&Cs ("see separate sign for
details"). Most likely these are not intended to be absorbed by
motorists due to the conversational request-like wording
("please enter") and the design of the sign deemphasising this
block. Many or most motorists will therefore interpret the
Terms and Conditions as these three key points from the bottom
block highlighted in blue: 1) purchase and retain a valid
ticket or pay by phone 2) only park in a disabled bay if you
hold a bdage 3) motorcyclists must pay the same tari as other
vehicles
Can you provide any evidence to support your claim that the
terms and conditions were not properly signed?
Appeal clarication
You complied with the signage at the car park
What did the signage at the car park say?
1) purchase and retain a valid ticket or pay by phone 2) only
park in a disabled bay if you hold a bdage 3) motorcyclists must
pay the same tari as other vehicles
Why do you consider you complied with the signage?
I paid for parking for 3 hours, entered full vehicle
registration (not partial), displayed my ticket on the car
dashboard, and
stayed less than 3 hours.
Why does the parking operator consider you to have failed to
comply with the signage?
Eurocarparks claim that I have made a "major keying error"
although there is no mention of major keying errors in the terms
and conditions sign at the entrance. The parking operator claims
that "Please enter full vehicle registration via the key pad" is
a term/condition despite being written as a request and written
in a small font and deemphasised in the graphic design of
the sign (see previous box). Even if this small font request IS
a term and condition that I am deemed to have agreed to, the
parking operator claims that I have entered an incorrect
registration, but have not provided evidence that I mistyped
(such as
CCTV footage of me entering the wrong number), and have not
provided evidence that their machinery is in good order,
there are no software bugs either within the machine, or within
the onward data transmission process, and no administrative
errors. Why would the driver enter a registration mark other
than that of the vehicle? It doesn't make much sense. Even if
this small font request IS a term and condition AND there was no
machine or process fault within ECP Systems and I made an
error as I entered the full vehicle reg myself, I did not enter
a partial registration, but I entered the full vehicle reg so
was in
compliance with their request to "please enter full vehicle
registration". Even if I made a "major keying error", there is
nothing
in the terms and conditions that states that vehicle
registrations with mistakes incur a penalty charge, and there is
no
mention of "major keying error" on the sign. Even if the small
font request is a T&C, AND I made an error entering the
registration, this is not a major keying error, as the
registration ECP claim I entered is substantially the same as
the
registration of the vehicle (SK10HHP vs SK10OWZ). The majority
of the letters and numbers ECP claim I entered are identical
to those on the vehicle, in particular the rst sequence of
letters are identical, the subsequent sequence of numbers are
identical, and only the last letters are claimed to be dierent.
So this is not a major keying error, and certainly nothing that
could have prevented ECP's internal processes matching the
payment to the vehcile (this car entered at this time, there was
a
payment associated with this similar reg a few minutes after
entry). This is a far easier computational task than the one
they
already carried out to extract a car registation plate from a
million pixels of various colours. I note that Eurocarparks have
retained the payment I made, rather than refunding it as soon as
they decided it didn't correspond to any car that entered
the car park...
Can you provide any evidence to support your claim that you
complied with the signage at the car park
-
Annotated picture of the sign at entrance from
ECP
Motorist Photo
Please use this to provide an overall summary of the reasons for
appealing against the parking charge notice.
ECP have acknowledged that I paid the correct tari, have
acknowleged that I departed before the time was elapsed, but
claim I have not complied with their terms and conditions, on
faulty grounds.
#Post#: 112462--------------------------------------------------
Re: N1SDT Claim Form - DCB Legal / Eurocarparks
DIR By: InterCity125
Date: March 8, 2026, 3:49 pm
---------------------------------------------------------
The type of payment machine used at the location has a history
of jumping to the payment stage before a registration mark can
be entered in full.
I would log into MCOL and register an Acknowledgement of Service
which will buy you some extra time.
Euro Car Parks are idiots and have recently been fined for their
behaviour - in particular, failure to reply to enquiries from so
called clients!
We can formulate a plan and gather evidence.
#Post#: 118652--------------------------------------------------
Re: N1SDT Claim Form - DCB Legal / Eurocarparks
DIR By: frankster
Date: May 14, 2026, 3:34 am
---------------------------------------------------------
Odd "Notice of Proposed Allocation to the Small Claims Track"
received. I've received an odd letter attached to an N180
Directions questionnaire.
HTML https://ibb.co/cXwYsVC6
It says "This is now a defended claim. A copy of the defence has
already been sent to you by the defendant. It appears that this
case is suitable for allocation to the small claims track."
Given that I am the defendant, has this letter been sent to me
in error or is this normal?
#Post#: 118653--------------------------------------------------
Re: N1SDT Claim Form - DCB Legal / Eurocarparks
DIR By: DWMB2
Date: May 14, 2026, 3:39 am
---------------------------------------------------------
Is the N180 they have sent you already filled in? If so, this is
likely a copy of the Claimant's N180 (as they have to serve a
copy on you).
If not, they've presumably attached the wrong boilerplate,
however this shouldn't cause you much disadvantage, as you also
need to fill in an N180 and serve it on the court/the claimant,
and on that form you'll identify yourself as the defendant.
Don't use the paper one, fill it in online and serve by email.
#Post#: 118656--------------------------------------------------
Re: N1SDT Claim Form - DCB Legal / Eurocarparks
DIR By: frankster
Date: May 14, 2026, 4:25 am
---------------------------------------------------------
It's not filled in. Sounds like the wrong boilerplate was
attached by CNBC then.
#Post#: 119383--------------------------------------------------
Re: N1SDT Claim Form - DCB Legal / Eurocarparks
DIR By: frankster
Date: May 21, 2026, 4:12 am
---------------------------------------------------------
Would I expect the Claimant to have served me a copy of their
Directions Questionnaire? MCOL says that claimant has filed one
several weeks ago. although I've received nothing from them.
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