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#Post#: 117830--------------------------------------------------
Re: NTK from UKPC for not parking within Bay marking. Beckton
Retail Park.
DIR By: Sander333
Date: May 5, 2026, 1:38 pm
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As far as I recollect you need to acknowledge the letter and you
need to reply denying any liability. Request the documents they
are relying on and await the next communication.
#Post#: 117833--------------------------------------------------
Re: NTK from UKPC for not parking within Bay marking. Beckton
Retail Park.
DIR By: jfollows
Date: May 5, 2026, 1:46 pm
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Yes, from
HTML https://www.justice.gov.uk/courts/procedure-rules/civil/rules/pd_pre-action_conduct#6.1
--- Quote ---
> (a) the claimant writing to the defendant with concise details
of the claim. The letter should include the basis on which the
claim is made, a summary of the facts, what the claimant wants
from the defendant, and if money, how the amount is calculated;
--- End Quote ---
--- Quote ---
> (b) the defendant responding within a reasonable time – 14
days in a straight forward case and no more than 3 months in a
very complex one. The reply should include confirmation as to
whether the claim is accepted and, if it is not accepted, the
reasons why, together with an explanation as to which facts and
parts of the claim are disputed
--- End Quote ---
You can also note how the letter of claim fails to meet the
relatively low bar of the procedure rules.
#Post#: 118401--------------------------------------------------
Re: NTK from UKPC for not parking within Bay marking. Beckton
Retail Park.
DIR By: Lut
Date: May 12, 2026, 6:31 am
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Can anyone help me with the drafting a response to the letter
and where/how to respond?
I've attached the letter below again.
[img]
HTML https://imgur.com/a/OJABczS[/img]
HTML https://ibb.co/TMWyzDJd
#Post#: 118404--------------------------------------------------
Re: NTK from UKPC for not parking within Bay marking. Beckton
Retail Park.
DIR By: Lut
Date: May 12, 2026, 6:41 am
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I found this on the forum. Should I send this to
info@dcblegal.co.uk?
Dear Sir/Madam,
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.
As a firm of supposed solicitors, one would expect you to be
capable of crafting a letter that aligns with paragraphs
3.1(a)–(d), 5.1 and 5.2 of the Protocol, and paragraphs 6(a) and
6(c) of the Practice Direction. These provisions do not exist
for decoration—they exist to facilitate informed discussion and
proportionate resolution. You might wish to reacquaint
yourselves with them.
The Civil Procedure Rules 1998, Pre-Action Conduct and Protocols
(Part 3), stipulate that prior to proceedings, parties should
have exchanged sufficient information to understand each other’s
position. Part 6 helpfully clarifies that this includes
disclosure of key documents relevant to the issues in dispute.
Your template letter mentions a “contract”, yet fails to provide
one. This would appear to undermine the only foundation upon
which your client’s claim allegedly rests. It’s difficult to
engage in meaningful pre-litigation dialogue when your side
declines to furnish the very document it purports to enforce.
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:
1. A copy of the original Notice to Keeper (NtK) that confirms
any PoFA 2012 liability
2. A copy of the contract (or contracts) you allege exists
between your client and the driver, in the form of an actual
photograph of the sign you contend was at the location on the
material date, not a generic stock image
3. The exact wording of the clause (or clauses) of the terms and
conditions of the contract(s) which is (are) relied upon that
you allege to have been breached
4. The written agreement between your client and the landowner,
establishing authority to enforce
5. A breakdown of the charges claimed, identifying whether the
principal sum is claimed as consideration or damages, and
whether the £70 “debt recovery” fee includes VAT
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]
#Post#: 118409--------------------------------------------------
Re: NTK from UKPC for not parking within Bay marking. Beckton
Retail Park.
DIR By: jfollows
Date: May 12, 2026, 7:08 am
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If it’s true and if you understand what it’s saying.
Otherwise don’t try and boil the ocean and follow the simple
advice on the two replies above yours.
#Post#: 118420--------------------------------------------------
Re: NTK from UKPC for not parking within Bay marking. Beckton
Retail Park.
DIR By: Lut
Date: May 12, 2026, 8:16 am
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Im not fully sure if it all relates to be honest. The letter of
claim is attached above if you want to have a look but i do
think its the generic template one they send to everyone.
Anyone able to help me draft a quick response according to the
advise given above. Thanks.
--- Quote ---
> You can also note how the letter of claim fails to meet the
relatively low bar of the procedure rules
--- End Quote ---
--- Quote ---
> As far as I recollect you need to acknowledge the letter and
you need to reply denying any liability. Request the documents
they are relying on and await the next communication.
--- End Quote ---
#Post#: 118424--------------------------------------------------
Re: NTK from UKPC for not parking within Bay marking. Beckton
Retail Park.
DIR By: Lut
Date: May 12, 2026, 8:41 am
---------------------------------------------------------
Ive put the following response together with help from chatgpt.
is this okay to send them or is it too much again?
Dear Sir/Madam,
I acknowledge receipt of your Letter of Claim.
I deny any liability for the alleged debt and dispute the claim
in its entirety.
Your client is aware, from prior correspondence and appeal
submissions, that liability is disputed on multiple grounds,
including but not limited to:
- failure to comply with the strict requirements of Schedule 4
of the Protection of Freedoms Act 2012;
- absence of keeper liability;
- inadequate and non-prominent signage incapable of forming a
contract;
- lack of strict proof of landowner authority;
- the unlawfulness and unrecoverability of the additional debt
recovery sums.
In particular, your client’s Notice to Keeper failed to specify
a “period of parking” as required by Schedule 4 Paragraph
9(2)(a) of the Protection of Freedoms Act 2012 and therefore
cannot establish keeper liability.
For the avoidance of doubt, no admission is made as to the
identity of the driver and no such inference may properly be
drawn.
Further, your Letter of Claim fails to comply with the spirit
and requirements of the Pre-Action Protocol for Debt Claims and
CPR Practice Direction – Pre-Action Conduct because it does not
provide sufficient detail or key documents required for a
prospective defendant to properly understand and respond to the
claim.
Accordingly, please provide the following documents and
information:
1. A copy of the original Parking Charge Notice and Notice to
Keeper;
2. All photographs relied upon;
3. Copies of the signage in place at the material time;
4. A site plan showing sign locations;
5. A copy of the contract or chain of authority between the
landowner and UK Parking Control Ltd authorising parking
enforcement and litigation;
6. Full particulars of the alleged contractual breach and cause
of action;
7. A detailed breakdown of the sum claimed, including the legal
basis for the additional £70 debt recovery charge;
8. Copies of all documents upon which you intend to rely in any
proceedings.
Please also explain how the additional £70 has been incurred and
how such sum is recoverable, given the repeated judicial
criticism of attempts at double recovery in private parking
claims.
Pending receipt of the above documents and information, I am
unable to provide any further substantive response and require
this matter to be placed on hold pursuant to the Pre-Action
Protocol for Debt Claims.
In addition, I confirm that I am seeking debt advice and
therefore require the matter to be placed on hold for not less
than 30 days in accordance with the Protocol.
I require all future correspondence to be in writing.
Yours faithfully,
[Your Name]
#Post#: 118528--------------------------------------------------
Re: NTK from UKPC for not parking within Bay marking. Beckton
Retail Park.
DIR By: Lut
Date: May 13, 2026, 5:10 am
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Can anyone provide feedback on my response to the letter of
claim above. Thanks
#Post#: 118760--------------------------------------------------
Re: NTK from UKPC for not parking within Bay marking. Beckton
Retail Park.
DIR By: DWMB2
Date: May 15, 2026, 8:56 am
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That'll do.
Please do not misuse the "Report to Moderator" function to bump
your thread. This is a busy forum run entirely by volunteers who
offer advice for free. Replies may not always be quick.
#Post#: 118764--------------------------------------------------
Re: NTK from UKPC for not parking within Bay marking. Beckton
Retail Park.
DIR By: Lut
Date: May 15, 2026, 9:53 am
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Thank you. Apologies, I genuinely thought I may be doing
something wrong as I usually always get a response within a day.
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