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#Post#: 97441--------------------------------------------------
Re: CPM - PCN online appeal denied - advice for IAS
DIR By: CatarinaSF
Date: November 9, 2025, 5:20 am
---------------------------------------------------------
--- Quote from: jfollows link ---
>
> So when you say
> [quote]I will do the appeal in IAS, as you recommend.
--- End Quote ---
you are far too late in the process to do this.
[/quote]
I said I would do the IAS appeal that was just now advise, on
the 7th November.
If it is too late to do this now, then what is the advise now?
Thank you.
#Post#: 97444--------------------------------------------------
Re: CPM - PCN online appeal denied - advice for IAS
DIR By: b789
Date: November 9, 2025, 5:27 am
---------------------------------------------------------
Please show us the content of the LoC and anything they included
as “evidence”. We do not need to see any of the other forms they
may have included with it. Just the wording of their claim.
Ignore the advice I gave about the IAS appeal. I was under the
impression you had received an appeal rejection just recently.
Once you’ve shown us the content of the LoC, we can advise on
the response.
#Post#: 97448--------------------------------------------------
Re: CPM - PCN online appeal denied - advice for IAS
DIR By: CatarinaSF
Date: November 9, 2025, 5:52 am
---------------------------------------------------------
--- Quote from: b789 link ---
>
> Please show us the content of the LoC and anything they
included as “evidence”. We do not need to see any of the other
forms they may have included with it. Just the wording of their
claim.
>
> Ignore the advice I gave about the IAS appeal. I was under the
impression you had received an appeal rejection just recently.
>
> Once you’ve shown us the content of the LoC, we can advise on
the response.
>
--- End Quote ---
No problem, thank you for giving another look. I really
appreciated!!
LoC1:
[img]
HTML https://ibb.co/3YFxy7YB[/img]
HTML https://ibb.co/3YFxy7YB
LoC2:
[img]
HTML https://ibb.co/mrMLpRLx[/img]
HTML https://ibb.co/mrMLpRLx
LoC3:
[img]
HTML https://ibb.co/Fk9FgcWw[/img]
HTML https://ibb.co/Fk9FgcWw
Do I need to resend the original PCN and the images of the
parking area?
Let me know if you need anything else :)
#Post#: 97453--------------------------------------------------
Re: CPM - PCN online appeal denied - advice for IAS
DIR By: b789
Date: November 9, 2025, 6:30 am
---------------------------------------------------------
Respond to that LoC as follows:
--- Quote ---
> Subject: Response to your Letter of Claim – Ref: [reference
number]; PCN: [xxxxx]; VRM: [ABC123]; Site/Date: [site],
[dd/mm/yyyy]
>
> Dear Sirs,
>
> This is my formal response under the Pre-Action Protocol for
Debt Claims. I dispute the debt. Your Letter of Claim contains
insufficient detail and omits documents you intend to rely upon,
contrary to PAPDC 3.1(a)–(d) and 3.1(3), and Practice Direction
– Pre-Action Conduct (PD-PAC) 6(a) and 6(c).
>
> The Protocol requires sufficient information and disclosure of
key documents to enable an informed response. Your template
refers to a “contract” but encloses none.
>
> Pursuant to PAPDC/PD-PAC, please provide:
> [indent]1. The Notice to Keeper (and any prior NtD) with all
pages, dates of posting, and proof of service.
> 2. Confirmation whether you rely on PoFA 2012 Schedule 4; if
so, a point-by-point explanation of compliance.
> 3. Contemporaneous, legible photographs of the signage in
place on the material date, and a site plan marking sign
locations.
> 4. The precise contractual wording allegedly accepted and the
clause(s) said to be breached, and whether you plead a
contractual sum or damages.
> 5. The landowner authority/chain permitting UKCPM to issue
PCNs and to litigate in its own name at Brooklands Court, New
Haw.
> 6. An up-to-date statement of account from the original PCN to
the claimed total, identifying each item (parking charge, any
“debt recovery”/“legal costs”/interest), the date applied, and
the legal/contractual basis for each; confirm whether interest
is claimed and the rate and start date.
> 7. If any sum above £100 is sought, the precise term said to
permit it and whether any part represents VAT.[/indent]
>
> Protocol hold: Under PAPDC 5.2 and 7.1–7.2, confirm that (i)
the matter is placed on hold immediately and (ii) no proceedings
will be issued for at least 30 days after you supply the above
documents/evidence.
>
> Until compliant disclosure is given, I cannot respond
substantively. On receipt of a compliant LoC bundle, I will
respond within 30 days as the Protocol contemplates.
>
> If you issue regardless of these requests, I will place this
correspondence before the Court and seek appropriate
case-management orders (including a stay) and costs for
unreasonable non-compliance (PD-PAC 15).
>
> I do not consent to using any web portal. Correspondence by
email to: [your email] and by post to: [your postal address]
only.
>
> Yours faithfully,
>
> [Your name]
--- End Quote ---
#Post#: 97455--------------------------------------------------
Re: CPM - PCN online appeal denied - advice for IAS
DIR By: CatarinaSF
Date: November 9, 2025, 6:40 am
---------------------------------------------------------
--- Quote from: b789 link ---
>
> Respond to that LoC as follows:
>
> [quote]Subject: Response to your Letter of Claim – Ref:
[reference number]; PCN: [xxxxx]; VRM: [ABC123]; Site/Date:
[site], [dd/mm/yyyy]
>
> Dear Sirs,
>
> This is my formal response under the Pre-Action Protocol for
Debt Claims. I dispute the debt. Your Letter of Claim contains
insufficient detail and omits documents you intend to rely upon,
contrary to PAPDC 3.1(a)–(d) and 3.1(3), and Practice Direction
– Pre-Action Conduct (PD-PAC) 6(a) and 6(c).
>
> The Protocol requires sufficient information and disclosure of
key documents to enable an informed response. Your template
refers to a “contract” but encloses none.
>
> Pursuant to PAPDC/PD-PAC, please provide:
> [indent]1. The Notice to Keeper (and any prior NtD) with all
pages, dates of posting, and proof of service.
> 2. Confirmation whether you rely on PoFA 2012 Schedule 4; if
so, a point-by-point explanation of compliance.
> 3. Contemporaneous, legible photographs of the signage in
place on the material date, and a site plan marking sign
locations.
> 4. The precise contractual wording allegedly accepted and the
clause(s) said to be breached, and whether you plead a
contractual sum or damages.
> 5. The landowner authority/chain permitting UKCPM to issue
PCNs and to litigate in its own name at Brooklands Court, New
Haw.
> 6. An up-to-date statement of account from the original PCN to
the claimed total, identifying each item (parking charge, any
“debt recovery”/“legal costs”/interest), the date applied, and
the legal/contractual basis for each; confirm whether interest
is claimed and the rate and start date.
> 7. If any sum above £100 is sought, the precise term said to
permit it and whether any part represents VAT.[/indent]
>
> Protocol hold: Under PAPDC 5.2 and 7.1–7.2, confirm that (i)
the matter is placed on hold immediately and (ii) no proceedings
will be issued for at least 30 days after you supply the above
documents/evidence.
>
> Until compliant disclosure is given, I cannot respond
substantively. On receipt of a compliant LoC bundle, I will
respond within 30 days as the Protocol contemplates.
>
> If you issue regardless of these requests, I will place this
correspondence before the Court and seek appropriate
case-management orders (including a stay) and costs for
unreasonable non-compliance (PD-PAC 15).
>
> I do not consent to using any web portal. Correspondence by
email to: [your email] and by post to: [your postal address]
only.
>
> Yours faithfully,
>
> [Your name]
--- End Quote ---
[/quote]
THANK YOU!!!
I get in touch again, once I have a response :)
#Post#: 99121--------------------------------------------------
Re: CPM - PCN online appeal denied - advice for IAS
DIR By: CatarinaSF
Date: November 21, 2025, 4:12 am
---------------------------------------------------------
Hello,
I got a letter yesterday from BWlegal, saying for me to reply to
them until the 22nd November.
It was sent on the 13th November, the same day my letter (above
post) arrive at their office (I sent it with tracking).
It looks like a standard "reminder":
HTML https://ibb.co/Kc8rpzGd
[img]
HTML https://ibb.co/Kc8rpzGd[/img]
HTML https://ibb.co/5xTHqLGz
[img]
HTML https://ibb.co/5xTHqLGz[/img]
Should I wait for them to come back to me on he letter I sent
them?
Thank you :)
#Post#: 99137--------------------------------------------------
Re: CPM - PCN online appeal denied - advice for IAS
DIR By: b789
Date: November 21, 2025, 5:25 am
---------------------------------------------------------
Why on earth are you sending letters by post? All you have to do
is use their web portal and upload all letters as PDFs or by
email if you have an email address for them. No paper, no
trudging to the post office, no paying for tracking. It's
instantaneous and you also have "tracking" and proof of having
sent it.
THere's nothing to do now until you receive a response to the
letter you sent and they issue a county court claim.
#Post#: 100160--------------------------------------------------
Re: CPM - PCN online appeal denied - advice for IAS
DIR By: CatarinaSF
Date: November 28, 2025, 2:20 am
---------------------------------------------------------
Got a response:
"Dear xxx
Thank you for your letter, please find our response below:
Please find attached a copy of the parking Charge Notice, which
was appealed and the appeal rejected on 11/12/2024 with the
POPLA Validation Code: xxxxxxxx.
Please be advised, it is unnecessary for our Client to provide
proof of delivery. Our Client issued these Notices under the
Protection of Freedoms Act 2012 and this confirms any Notices
sent to the address provided by the DVLA, can be presumed
delivered the second working day after postage.
As a result, our Client is satisfied these Notices were posted
and delivered correctly to the address of the Registered Keeper.
Please note that we will not be providing a copy of the
agreement between our Client and the landowner. The document is
commercially sensitive and shall only be produced if the matter
progresses to formal hearing at Court.
However we can confirm that our Client holds the necessary right
with the landowner to issue PCN's and take legal action to
recover outstanding balances where needed.
Debt recovery costs are contractually agreed by the motorist
when visiting the car park. They only apply when the
opportunity to pay the parking charge has expired and the
parking company has been forced to commence debt recovery
activities.
Such contractual costs are recognised by the courts as covering
debt recovery activity between the expiry of the parking charge
notice and the commencement of litigation, including
pre-litigation correspondence.
The fees we charge our clients for our services are subject to
VAT. However, these are separate and distinct from contractual
debt recovery costs recoverable by our client from the motorist.
If you would like to view the full contact history or submit a
new query, please log into our Customer Portal by clicking here.
 
Yours sincerely,
BW Legal"
What should I reply?
Thank you :)
#Post#: 100183--------------------------------------------------
Re: CPM - PCN online appeal denied - advice for IAS
DIR By: b789
Date: November 28, 2025, 5:50 am
---------------------------------------------------------
Respond as follows:
--- Quote ---
> Subject: Your Letter of Claim – Ref: [reference number]; PCN:
[xxxxx]; VRM: [ABC123]; Site/Date: [site], [dd/mm/yyyy]
>
> Dear Sirs,
>
> Thank you for your email of [date]. It does, however, confirm
that whoever drafted it has not understood either my previous
letter or the Pre-Action Protocol for Debt Claims.
>
> For ease of reference, I will deal with matters in short
points.
>
> 1. Non-compliance with PAPDC/PD-PAC
>
> Your response fails to comply with the Protocol and Practice
Direction. You have still not supplied key documents, including
contemporaneous photographs of the vehicle and signage on the
material date, a site plan showing sign locations, any statement
of account explaining how you leap from the original PCN to the
inflated sum claimed (with dates, amounts and the alleged
contractual or statutory basis of each item), or any landowner
authority (even in redacted form) evidencing that UKCPM has
standing to issue PCNs and litigate in its own name at
Brooklands Court, New Haw.
>
> The Protocol requires you to provide key documents so that a
prospective defendant can understand and narrow the issues, not
to send a template stock answer and expect blind acceptance of
bare assertions. A contract, the terms allegedly accepted, and
evidence of your client’s standing are not optional extras. They
are central to any cause of action and fall squarely within
PAPDC 3.1 and PD-PAC 6(a) and 6(c).
>
> If you continue to refuse to provide core documents, that will
be relied upon in any costs argument as unreasonable pre-action
conduct.
>
> 2. Presumption of delivery and PoFA “unless the contrary is
proved”
>
> You state that it is unnecessary for your client to provide
proof of delivery and then recite the well-known deemed service
provision in Schedule 4 to the Protection of Freedoms Act 2012.
>
> I am fully aware that PoFA provides a rebuttable presumption
that a notice sent by post is deemed delivered on the second
working day after posting. That does not mean that proof of
posting is irrelevant, or that service can never be challenged,
or that a defendant is not entitled at the pre-action stage to
see basic evidence of when and where documents were allegedly
sent and to what address.
>
> “Unless the contrary is proved” is precisely the point. The
presumption is not conclusive. Dates of issue, dates of posting,
the method of posting and the address used are all matters of
evidence. A solicitor who thinks that quoting the presumption
somehow relieves the claimant of any burden of proof has not
grasped even the rudiments of PoFA or civil evidence.
>
> My original request was for copies of the NtK/NtD with all
pages, dates of posting, and proof of service. The partial
response you have given (a bare copy of a PCN) does not comply
with that request or with the Protocol.
>
> 3. Standing and landowner authority
>
> You say you will not provide a copy of the agreement with the
landowner because it is commercially sensitive and will only be
produced if the matter progresses to formal hearing at court.
>
> That is an untenable stance and is flatly contrary to the
spirit and letter of the Protocol. Your client’s locus standi is
a fundamental element of any claim. A bare assertion that “our
Client holds the necessary right” is not evidence and would not
be accepted as such at trial.
>
> Pre-action, the court expects disclosure of the core documents
that will be relied upon, so that claims without merit can be
weeded out and issues narrowed. It is perfectly possible to
provide a redacted agreement, a witness statement from the
landowner, or some other competent proof of authority. Your
client’s insistence on secrecy at this stage is a red flag, not
a virtue, and will be drawn to the court’s attention if
proceedings are issued.
>
> For the avoidance of doubt, I put your client to strict proof
of their authority to operate the site at Brooklands Court, New
Haw, and to issue PCNs and pursue court proceedings in their own
name.
>
> Your refusal to provide any such proof now will form part of
my evidence on any application for directions or costs.
>
> 4. Debt recovery add-ons
>
> Your paragraph about “debt recovery costs” being contractually
agreed and recognised by the courts is pure assertion with no
legal analysis.
>
> You have still not identified the specific term in the alleged
contract which you say permits any sum above £100, addressed the
requirement that such a term be fair and transparent under the
Consumer Rights Act 2015 and properly brought to the motorist’s
attention, or explained how any added sum is not a penalty or
unlawful double recovery given that your client’s alleged “debt
recovery” is simply part of its ordinary business model and
already priced into the core charge.
>
> There is now a substantial body of County Court authority that
such additional sums are irrecoverable in private parking claims
and amount to an abuse of process. Simply asserting that “the
courts recognise” these costs, without citation, does not make
it so.
>
> I repeat my request for a full, itemised statement of account
from the original PCN to the total now claimed, identifying each
sum, the date applied, and the legal or contractual basis you
say entitles your client to recover it.
>
> 5. Your internal arrangements and authorisation
>
> Your letter reads like a standardised script generated by
someone who has not read or is incapable of comprehending the
Protocol, my previous letter, or Schedule 4 PoFA, and who
plainly does not understand the issues raised.
>
> Please ensure that any further substantive response is
prepared by, or under the actual supervision of, an individual
authorised under the Legal Services Act 2007 to conduct
litigation, and is based on a proper review of the file and the
questions put to you.
>
> If you are unable or unwilling to engage at that level, there
is little point in further pre-action correspondence.
>
> 6. Portal and method of communication
>
> Once again, I do not consent to the use of your “Customer
Portal” or any similar web platform. The Protocol does not
entitle you to force defendants into your marketing systems.
>
> All future correspondence must be sent by email to [your
email] and, where required, by post to [your postal address]
only.
>
> 7. Next steps
>
> My position remains that the alleged debt is disputed in full.
Unless and until you comply with your obligations under PAPDC
and PD-PAC and provide the documents and information I
reasonably require, I am unable to narrow the issues any
further.
>
> If you choose to issue proceedings without first providing
proper disclosure of the alleged contract and terms, your
client’s standing, contemporaneous photographs and signage
evidence, and a coherent breakdown and legal basis for every
element of the sum claimed, I will invite the court to stay the
proceedings and order you to provide the same material you
should have provided now, and to take your unreasonable
pre-action conduct into account when considering any costs under
CPR 27.14.
>
> This correspondence will be placed before the court at the
appropriate time.
>
> Yours faithfully,
>
> [Your name]
--- End Quote ---
#Post#: 117611--------------------------------------------------
Re: CPM - PCN online appeal denied - advice for IAS
DIR By: CatarinaSF
Date: May 3, 2026, 3:35 am
---------------------------------------------------------
Hello,
I thought that reply was the last, but yesterday I got this
email from the firm:
"Thank you for contacting us, please find our response below:
We will not be reiterating the same points raised.
As previously stated, your appeal was rejected by our Client.
As such this charge remains due and owing.
Should you wish to dispute this further, we strongly suggest you
seek your own independent legal advice.
Should you have any further queries please contact us on 0113
487 0430 or by clicking reply at the bottom.
Alternatively, you can contact us via our Live Chat at
You are being redirected...
bwlegal.co.uk
which is open from Monday to Friday 8am - 5pm and Saturday 9am -
2:45pm.
If you would like to view the full contact history or submit a
new query, please log into our Customer Portal..
Yours sincerely,
BW Legal"
What should I do next? :-[
Thank you so much in advance!!
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