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#Post#: 77519--------------------------------------------------
UK Parking Control PCN - advice needed please
DIR By: Bobbit500
Date: June 21, 2025, 9:50 am
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Hello and thanks in advance for all advice.
on 30/4/25 the vehicle parked at the Bridge Retail Park in
Torquay, and suffered a mechanical issue. The driver had to
await assistance, the issue was resolved and the driver left the
car park. The registered keeper received a letter from UK
Parking Control Ltd dated 7/5/25 stating that the vehicle had
been on the premises for 34 minutes longer than the allowed
maximum time, and that a £100 charge was due, reduced to £60 if
paid in 14 days (see scan pages 1 and 2). A further letter was
received approximately 2 weeks later but was not opened, was not
read and is now lost. The attached letters dated 4th and 12th of
June were then received stating that £170 is now due and if not
paid the case will escalate with further costs (3rd attached
letter has identical 2nd side to the 2nd attached letter).
The registered keeper believes that the letters received do not
constitute a legitimate invoice for parking charges as they are
not appropriately detailed and specify varying amounts owing.
However, the RK is concerned that the case may escalate to court
and wishes to avoid this. No contact has been made with UKPC.
I would value any advice to deal with this matter in a timely
fashion and avoid further escalation or paying the escalated
costs; ideally a solution which prevents any payment being
necessary.
I do not have a picture of the parking signs but they are
visible on the Streetview from 2022. Location is here:
HTML https://maps.app.goo.gl/Yx3cKMhkxMqXUUJUA
Many thanks
[attachment deleted by admin]
#Post#: 77524--------------------------------------------------
Re: UK Parking Control PCN - advice needed please
DIR By: RichardW
Date: June 21, 2025, 10:44 am
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Only 2 options now: pay, or wait for them to issue a court
claim. The latter will almost certainly be easily defended with
help from here.
#Post#: 77534--------------------------------------------------
Re: UK Parking Control PCN - advice needed please
DIR By: b789
Date: June 21, 2025, 12:40 pm
---------------------------------------------------------
If you follow the advice here, you will not pay a penny to UKPC.
However, it is a protracted process. As it is too late appeal
and you have started to receive debt recovery letters, you will
have to wait for UKPC to issue a claim which will come from
their bulk litigator of choice, DCB Legal.
You can safely ignore all the debt collector letters with their
fake add-on £70. Debt collectors are powerless to do anything
except to try and persuade the low-hanging fruit on the gullible
tree to pay up out of ignorance and fear.
When you receive a Letter of Claim (LoC) from DCB Legal, respond
with the following by email to info@dcblegal.co.uk and also CC
yourself:
--- Quote ---
> Dear Sirs,
>
> Your Letter Before Claim contains insufficient detail of the
claim and fails to provide copies of evidence your client places
reliance upon and thus is in complete contravention of the
Pre-Action Protocol for Debt Claims.
>
> Because your letter lacks specificity and breaches the
requirements of the Pre-Action Protocol for Debt Claims
(paragraphs 3.1(a)-(d), 5.1 and 5.2) as well as the Practice
Direction - Pre-Action Conduct (paragraphs 6(a) and 6(c)), you
must treat this letter as a formal request for all of the
documents/information that the protocol now requires your client
to provide. Your client must not issue proceedings without
complying with that protocol.
>
> As solicitors you must surely be familiar with the
requirements of both the Practice Direction and the Pre-Action
Protocol for debt claims and your client, as a serial litigator
of debt claims, should likewise be aware of them. As you (and
your client) must know, the Practice Direction and Protocol bind
all potential litigants, whatever the size or type of the claim.
Its express purpose is to assist parties in understanding the
claim and their respective positions in relation to it, to
enable parties to take stock of their positions and to negotiate
a settlement, or at least narrow the issues, without incurring
the costs of court proceedings or using up valuable court time.
It is embarrassing that a firm of Solicitors are sending a
consumer a vague and un-evidenced 'Letter of Claim' in complete
ignorance of the pre-existing Practice Direction and the
Pre-Action Protocol.
>
> I confirm that, once I am in receipt of a Letter Before Claim
that complies with the requirements of para 3.1 (a) of the
Pre-Action Protocol, I shall then seek advice and submit a
formal response within 30 days, as required by the Protocol.
Thus, I require your client to comply with its obligations by
sending me the following information/documents:
>
> [indent]1. An explanation of the cause of action
> 2. whether they are pursuing me as driver or keeper
> 3. whether they are relying on the provisions of Schedule 4 of
POFA 2012
> 4. what the details of the claim are; for how long it is
claimed the vehicle was parked, how the monies being claimed
arose and have been calculated
> 5. Is the claim for a contractual breach? If so, what is the
date of the agreement? The names of the parties to it and
provide to me a copy of that contract.
> 6. If the claim is for a contractual breach, photographs
showing the vehicle was parked in contravention of said
contract.
> 7. Is the claim for trespass? If so, provide details.
> 8. Provide me a copy of the contract with the landowner under
which they assert authority to bring the claim, as required by
the BPA/IPC Private Parking Single Code of Practice (PPSCoP).
> 9. a plan showing where any signs were displayed
> 10. Photographs of the signs displayed (size of sign, size of
font, height at which displayed) at the time of any alleged
contravention.
> 11. Provide details of the original charge, and detail any
interest and administrative or other charges added
> 12. Am I to understand that the additional £70 represents what
is dressed up as a 'Debt Recovery' fee, and if so, is this nett
or inclusive of VAT? If the latter, would you kindly explain why
I am being asked to pay the operator’s VAT?
> 13. With regard to the principal alleged PCN sum: Is this
damages, or will it be pleaded as consideration for
parking?[/indent]
>
> I am clearly entitled to this information under paragraphs
6(a) and 6(c) of the Practice Direction. I also need it in order
to comply with my own obligations under paragraph 6(b).
>
> If your client does not provide me with this information 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.
>
> Until your client has complied with its obligations and
provided this information, I am unable to respond properly to
the alleged claim and to consider my position in relation to it,
and it is entirely premature (and a waste of costs and court
time) for your client to issue proceedings. Should your client
do so, then I will seek an immediate stay pursuant to paragraph
15(b) of the Practice Direction and an order that this
information is provided.
>
> Yours faithfully,
>
> [Your name]
--- End Quote ---
You will receive an N1SDT Claim Form at some stage, at least 30
days after this. When you do, come back and we will provide the
necessary advice on how to acknowledge service and we will
provide a defence for submission.
In due course, the claim will either be struck out or
discontinued.
#Post#: 78752--------------------------------------------------
Re: UK Parking Control PCN - advice needed please
DIR By: Bobbit500
Date: June 29, 2025, 4:28 am
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This is amazing. Thank you so much. I will return when I get the
N1SDT Claim Form. Really appreciate this.
#Post#: 96478--------------------------------------------------
Re: UK Parking Control PCN - advice needed please
DIR By: Bobbit500
Date: November 1, 2025, 5:09 pm
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Hello
I sent the response letter to the Letter of Claim as set out
below, and have not received any response or acknowledgement.
I have now received the N1SDT Claim Form. I have only just
opened this as I've been away, it's dated 28th October.
I'm going to be out of the country from Monday 3rd November
until 10th November. Do I need to seek an extension of some sort
so that I can address this on my return, or do I need to send a
response before I leave?
If you could provide me with a suitable response it would be
appreciated
Thanks in advance
#Post#: 96525--------------------------------------------------
Re: UK Parking Control PCN - advice needed please
DIR By: b789
Date: November 2, 2025, 9:36 am
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Please show us the N1SDT Claim Form. We need to see the
Particulars of claim (PoC). If the date on the form is 28th
October, you have until 4pm on Monday 17th November to submit
your defence. If you submit an Acknowledgement of Service (AoS)
before then, you would then have until 4pm on Monday 1st
December to submit your defence.
You only need to submit an AoS if you need extra time to prepare
your defence. If you want to submit an AoS then follow the
instructions in this linked PDF:
HTML https://www.dropbox.com/s/xvqu3bask5m0zir/money-claim-online-How-to-Acknowledge.pdf?dl=0
Once you have shown us the PoC, I will give you the correct
defence template to copy and paste.
#Post#: 96552--------------------------------------------------
Re: UK Parking Control PCN - advice needed please
DIR By: Bobbit500
Date: November 2, 2025, 2:04 pm
---------------------------------------------------------
Hopefully this link works?
HTML https://imgpile.com/p/ACYJO9x
The date is 28th October
Thank you
#Post#: 96556--------------------------------------------------
Re: UK Parking Control PCN - advice needed please
DIR By: b789
Date: November 2, 2025, 2:25 pm
---------------------------------------------------------
Until very recently, we never advised using the MCOL to submit a
defence. However, due to recent systemic failures within the
CNBC, we feel that it is safer to now submit a short defence
using MCOL as it is instantly submitted and entered into the
"system". Whilst it will deny the use of some formatting or
inclusion of transcripts etc. these can always be included with
the Witness Statement (WS) later, if it ever progresses that
far.
You will need to copy and paste it into the defence text box on
MCOL. It has been checked to make sure that it will fit into the
122 lines limit.
--- Quote ---
> 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.
--- End Quote ---
#Post#: 97750--------------------------------------------------
Re: UK Parking Control PCN - advice needed please
DIR By: Bobbit500
Date: November 11, 2025, 2:23 pm
---------------------------------------------------------
Thank you - will get onto this right away.
#Post#: 102057--------------------------------------------------
Re: UK Parking Control PCN - advice needed please
DIR By: Bobbit500
Date: December 11, 2025, 10:13 am
---------------------------------------------------------
Hello again
I've received further correspondence from DCB Legal which states
that they are going to proceed with the claim. Their email
copied below. They have also attached their N180 Directions
Questionnaire form (which I can upload if needed).
Are there any further steps which I need to take at this point?
Thanks as always
DCB email:
<<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) hereon in pursuant to PD 6A (4.1)(2)(c). Please advise
whether there are any limitations to this (for example, the
format in which documents are to be sent and the maximum size of
attachments that may be received). Unless you advise otherwise,
we will assume not.>>
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