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#Post#: 95771--------------------------------------------------
Re: DCBL collection - debt recovery & final reminder for 5
year old PCN
DIR By: b789
Date: October 27, 2025, 1:33 pm
---------------------------------------------------------
Nothing to worry about. Simply respond to their letter to
info@dcblegal.co.uk and CC yourself with the following:
--- Quote ---
> Subject: Your Letter of Claim – Ref: 711200292970SMP / Parking
Charge Ref: TC60726593
>
> Dear Ms Marth,
>
> Thank you for your correspondence dated [insert date].
>
> I dispute the alleged debt. Your reply letter does not comply
with the Pre-Action Protocol for Debt Claims (PAPDC) and does
not engage with the substantive issues raised. For clarity:
>
> 1) PAPDC non-compliance
>
> Your reply fails to provide the information and documents
required to enable me to understand, investigate, and respond to
the claim:
> [indent]• You do not clearly identify the cause of action
(breach of contract / contractual sum / trespass / damages).
> • The location details are incomplete in your letter, and no
site plan is provided.
> • You have not provided the contract/authority between your
client and the landowner/occupier.
> • You have not provided the terms relied upon (signage text as
it stood on the material date) nor evidence that the terms were
adequately brought to the attention of motorists.
> • You have not provided the Notice to Driver/Notice to Keeper
and any subsequent notices, nor evidence of compliance with the
Protection of Freedoms Act 2012, Sch. 4 (PoFA) if keeper
liability is alleged.[/indent]
>
> Under PAPDC para. 2.1(c) and paras. 3.1 & 5.1, please now
provide the following within 30 days so that the matter can be
properly considered:
> [indent[1. The full, unredacted landowner authority/contract
in force on 08/05/2021, showing your client’s standing to issue
charges and litigate.
> 2. The NTD/NTK and all subsequent correspondence, with proof
of posting and dates, and a statement of PoFA compliance (or
confirmation you rely only on driver liability).
> 3. Machine/payment data for the entire day (or the relevant
time window), including VRM inputs, synchronisation settings,
and any partial/mistyped VRMs; plus any ANPR/patrol logs relied
upon.
> 4. Maintenance and ANPR calibration/accuracy logs for the
period spanning 08/05/2021.
> 5. A full breakdown of the sum claimed, identifying each head
of loss and when/why it was added.
> 6. Your client’s grace and consideration period policy in
force on the material date and evidence of adherence to
it.[/indent]
>
> Pending receipt of the above, the PAPDC clock is not running.
Please confirm the matter is placed on hold for at least 30 days
after you provide the complete response and documents.
>
> 2) “Genuine pre-estimate of loss”
>
> Your letter asserts that the amount represents a “genuine
pre-estimate of loss.” That is wrong in law. Since ParkingEye
Ltd v Beavis [2015] UKSC 67, charges are assessed under the
penalty/legitimate interest test, not on a pre-estimate of loss
basis. Please ensure future correspondence is accurate.
>
> 3) Added “debt recovery” fees
>
> Any sum added on top of the core charge (typically £100) for
so-called “debt recovery” is unrecoverable and has been treated
by courts as an abuse of process. Recent judicial commentary and
decisions have repeatedly disallowed such add-ons. The current
Private Parking Single Code of Practice (2025) also prohibits
adding extra recovery fees beyond the core charge (save for
fixed court fees/interest if awarded). I will invite the court
to strike out or disallow any such add-ons.
>
> 4) Keeper liability / driver identity
>
> Unless and until you demonstrate strict PoFA compliance, no
keeper liability arises. For the avoidance of doubt, I do not
admit to being the driver, and you have no evidence of driver
identity.
>
> 5) Next steps
>
> Once you have complied with the PAPDC and supplied the
documents requested, I will provide a substantive response
within 30 days. If you issue proceedings without remedying these
defects, I will draw this correspondence to the court’s
attention on the question of conduct and costs.
>
> Yours faithfully,
>
> [Name]
> [Address]
> [Email]
--- End Quote ---
#Post#: 101125--------------------------------------------------
Re: DCBL collection - debt recovery & final reminder for 5
year old PCN
DIR By: applecrate
Date: December 5, 2025, 8:01 am
---------------------------------------------------------
Hi all,
It would appear the previous letter above didn't have the
desired effect e.g. they have now (or the court has) issued a
claim - see attached/linked scan. They have also applied a huge
amount of interest bring the claim value now up to £320, from
the original £170.
This has now defiintiely gone beyond my level of expertise &
experience/knowledge. What can I do now? Am I locked into paying
the fully unjustified amount, or is there any way to push back
on this to get them to go bury their heads once & for all?
As always, any & all guidance gratefully accepted.
HTML https://1drv.ms/b/c/46ae79d8cea5d38a/IQBOYgEoeDu8R7lr72D_PaH-AaLD95DkTh3onJCcpoLcqkY?e=35REbY
HTML https://1drv.ms/b/c/46ae79d8cea5d38a/IQBOYgEoeDu8R7lr72D_PaH-AaLD95DkTh3onJCcpoLcqkY?e=35REbY
#Post#: 101126--------------------------------------------------
Re: DCBL collection - debt recovery & final reminder for 5
year old PCN
DIR By: jfollows
Date: December 5, 2025, 8:11 am
---------------------------------------------------------
You’re not “locked in” to paying anything.
--- Quote ---
> Just do a search of the forum for any other DCB Legal Letter
of Claim (LoC). Look for any very recent ones and follow the
same advice given in those.
>
> You will eventually receive a claim anyway and as long as you
defend it with the same advice in any of those threads, you wil
not be paying a penny.
--- End Quote ---
You have to follow the process, for which you will get advice
here, and DCB Legal will discontinue in the face of your doing
so before having to pay the court fee.
As advised, search the forum for many similar cases.
#Post#: 101151--------------------------------------------------
Re: DCBL collection - debt recovery & final reminder for 5
year old PCN
DIR By: applecrate
Date: December 5, 2025, 10:17 am
---------------------------------------------------------
Thanks for the guidance. I've searched the forum & found this
thread which I think covers the main actions to take? Just so I
get this right, I assume I now have to submit an AoS
(Acknowledgement of Service), and then a personalised copy of
the defence template quoted in the thread e.g. "in the County
Court between Vehicle Control Services Ltd" etc (obviously
adjusting for my particular details).
This is then to be emailed to the prescribed email address in
the thread
(claimresponses.cnbc[member=6517]justice[/member].gov.uk) noting
claim number etc. There is alos a copy of a draft order for
defence - should I include this also?
HTML https://www.ftla.uk/private-parking-tickets/vcs-parked-after-expiry-time-powis-car-park-woolwich/msg69322/#msg69322
HTML https://www.ftla.uk/private-parking-tickets/vcs-parked-after-expiry-time-powis-car-park-woolwich/msg69322/#msg69322
#Post#: 101159--------------------------------------------------
Re: DCBL collection - debt recovery & final reminder for 5
year old PCN
DIR By: b789
Date: December 5, 2025, 10:31 am
---------------------------------------------------------
Stop overthinking this and rushing in and FUBARing it. You have
been advised that we will advise every step of the way and if
you follow the advice, you will not have to pay a penny to
anyone.
With an issue date of 3rd December, you have until 4pm on Monday
22nd December to submit your defence. If you submit an
Acknowledgement of Service (AoS) before then, you would then
have until 4pm on Monday 5th January 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
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#: 101583--------------------------------------------------
Re: DCBL collection - debt recovery & final reminder for 5
year old PCN
DIR By: applecrate
Date: December 8, 2025, 2:18 pm
---------------------------------------------------------
Many thanks for this - I would not have known to do any of this
without your help & probably would have fubar'd it as yuou
noted. I've pasted the text into the appropriate field on the
MCOL website & have submitted. I assume its now a case of hurry
up & wait for their reply/assessment?
#Post#: 101640--------------------------------------------------
Re: DCBL collection - debt recovery & final reminder for 5
year old PCN
DIR By: b789
Date: December 9, 2025, 3:59 am
---------------------------------------------------------
There are a ton of other DCB Legal issued claims you can search
on the forum to see what happens when. just have a read of a few
to see the answers given at each stage.
Try "DCB Legal defence" as your search term (include the
apostrophes)
#Post#: 102497--------------------------------------------------
Re: DCBL collection - debt recovery & final reminder for 5
year old PCN
DIR By: applecrate
Date: December 15, 2025, 7:15 am
---------------------------------------------------------
Quick update just for info & benefit of others like me who do
not know this process at all - recieved acknowlegdement/recipet
of defence submission, so now assume we wait for DCBL to reply,
if at all.
Link to scan of court reciept letter:
HTML https://1drv.ms/b/c/46ae79d8cea5d38a/IQDgY64MxWwYQ5R5ZB6AsqHDAQIJNwh5tWhqKREECTh-CMQ?e=FfnDn1
HTML https://1drv.ms/b/c/46ae79d8cea5d38a/IQDgY64MxWwYQ5R5ZB6AsqHDAQIJNwh5tWhqKREECTh-CMQ?e=FfnDn1
#Post#: 102503--------------------------------------------------
Re: DCBL collection - debt recovery & final reminder for 5
year old PCN
DIR By: b789
Date: December 15, 2025, 8:21 am
---------------------------------------------------------
Yes, you will receive a letter saying that they have reviewed
your defence and their client intends to proceed and a copy of
their N180 DQ.
#Post#: 104678--------------------------------------------------
Re: DCBL collection - debt recovery & final reminder for 5
year old PCN
DIR By: applecrate
Date: January 5, 2026, 2:31 pm
---------------------------------------------------------
--- Quote from: b789 link ---
>
> Yes, you will receive a letter saying that they have reviewed
your defence and their client intends to proceed and a copy of
their N180 DQ.
>
--- End Quote ---
You are spot on once again b789. DCB Legal have emailed me the
following email & attached N180.
Email:
HTML https://1drv.ms/b/c/46ae79d8cea5d38a/IQDiOViv9mq3QpVuyj6foawsAeQQicsh-FxaI-18kvoa5QM?e=CxV0kc
HTML https://1drv.ms/b/c/46ae79d8cea5d38a/IQDiOViv9mq3QpVuyj6foawsAeQQicsh-FxaI-18kvoa5QM?e=CxV0kc
N180:
HTML https://1drv.ms/b/c/46ae79d8cea5d38a/IQCfQgicEG77SpKYvfeNjPlYAa7Rkfwil5ra85JLBh5lv2c?e=mo8U8e
HTML https://1drv.ms/b/c/46ae79d8cea5d38a/IQCfQgicEG77SpKYvfeNjPlYAa7Rkfwil5ra85JLBh5lv2c?e=mo8U8e
There does not appear to be any updates on the MCOL website yet
if that means anything.
So the 64,000 peso question is - what next?
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