Good Afternoon

I have previously received advice on the flta.uk website, my thread link is:

https://www.ftla.uk/private-parking-tick...-received/

I thought this had died a death, however I have now recieved in the post a Notice Of Transfer Of Proceedings to the claimant Horizon Parking Limited, the advice previously was that the claimant would usually pull out of proceedings before any fees were paid, I am happy to wait and see but I am concerned that I should also be doing something in preparation/ anticipation for any escalation of the matter.

Any advice would be greatly appreciated.

Thank You

Hi B789

You was helping me last year on flta advice forum and gave me great advice and I have discovered you are now running this forum. 

I’m hoping you can help me with the next step. 

I will link the original thread here https://www.ftla.uk/private-parking-tick...al-estate/

If you want me to bring all the information here into this thread I can 

I have now revived a Letter before claim for this parking ticket. 

I have drafted a response using Chat GPT after feeding the info into it. If you could verify what I will send is sufficient that would be great. 


Dear Sir/Madam,
Re: Letter Before Claim
Reference: [Insert Reference]

I dispute the alleged debt in full.
Your client’s own evidence confirms that the vehicle was present for approximately 44 seconds. This is fatal to any claim.

The Private Parking Code of Practice requires that a driver must be allowed a minimum consideration period of five minutes to read signage and decide whether to accept the terms. A duration of 44 seconds makes it impossible for any contract to have been formed. No reasonable person could locate, read, and accept contractual terms within that timeframe.
Accordingly, no contract was formed, no breach occurred, and no charge is payable.

Further, your client’s Notice to Keeper is non-compliant with Schedule 4 of the Protection of Freedoms Act 2012. It fails to:

Specify the land with sufficient clarity (referring only to a broad industrial estate covering multiple roads and an incorrect postcode);
Specify any period of parking;
Properly identify the creditor.

As such, keeper liability does not apply.

In addition, the signage relied upon is prohibitive (“No Parking”) and therefore incapable of forming a contractual agreement.

Given the above, your client’s claim has no realistic prospect of success.

I require the matter to be placed on hold for 30 days and request full disclosure of all documents relied upon, including:

In accordance with the Pre-Action Protocol for Debt Claims, please provide the following:
A copy of the original Parking Charge Notice and all correspondence
All photographic evidence relied upon
A precise site map identifying the exact location of the alleged contravention and clarification of the postcode discrepancy
Evidence of the alleged period of parking, including full observation logs
Copies of all signage in place at the time, including wording and locations
A full unredacted copy of the contract with the landowner, including proof of authority to operate and litigate
Confirmation of the legal basis of the claim (contract or trespass)
A detailed breakdown of the sum claimed and the legal basis for any additional charges
Until this information is provided, the claim is not properly particularised and I am unable to respond substantively.

Should your client proceed with litigation, I will robustly defend the claim and seek recovery of costs for unreasonable conduct.

Yours faithfully,
[Your Name]


   

   

This case concerns a Parking Charge Notice (private parking firm) issued by CP Plus Ltd t/as Group Nexus, relating to an alleged contravention on Tuesday, 02 March 1926. The notice itself is dated Tuesday, 09 March 1926, and I first became aware of it via received initial notice.

The notice appears to have been issued as By post (ANPR/camera). Driver identified status: NO. Equality Act considerations: No. The location is stated as Moto Burton in Kendal.

A preliminary Protection of Freedoms Act (PoFA) assessment indicates COMPLIANT: Likely PoFA timing compliant for paragraph 9 (postal NtK, no windscreen NtD). Route applied: PoFA paragraph 9 (postal NtK, no windscreen NtD). The notice is treated as given on Thursday, 11 March 1926 (9 days after the alleged event).

Current stage:
- Notice responded to: No
- Debt recovery letters: No
- Letter of Claim: No
- County Court claim: No

Additional notes provided:
Vehicle registered to a Sole trader, with a T/As company name.
Driver on the night is resident in Northern Ireland.

Please can I have advice on the strongest next steps and defence points for this case.

Attached Files

  GroupNexus(1).pdf (Size: 1.49 MB / Downloads: 10)

Firstly, greetings, as a regular on another forum I enquired about 'The' most helpful person for PCN's as I'd not seen him (b789) there for some time and was told about this site, so please forgive the duplicate request for help.

The driver was fined for parking outside the bays, admittedly they were parked poorly, the driver is heavily expecting and so was in a major rush.

Can the experts please advise best way to challenge this fine?

https://ibb.co/chxkq6wL
https://ibb.co/NdWSmkr1

I am told the PCN is not PoFA compliant, is that correct and which paragraph(s) can I use to submit an appeal, thank you in advance.


Thanks.

PS. I owe a few cups of coffee from the past so will buy you some... 

This case concerns a Parking Charge Notice (private parking firm) issued by MET Parking Services Ltd, relating to an alleged contravention on Sunday, 22 December 2024. The notice itself is dated Monday, 30 December 2024, and I first became aware of it via received initial notice.

The notice appears to have been issued as By post (ANPR/camera). Driver identified status: NO. Equality Act considerations: Yes. The location is stated as Southgate Park, Stansted CM24 1PY.

A preliminary Protection of Freedoms Act (PoFA) assessment indicates COMPLIANT: Likely PoFA timing compliant for paragraph 9 (postal NtK, no windscreen NtD). Route applied: PoFA paragraph 9 (postal NtK, no windscreen NtD). The notice is treated as given on Wednesday, 01 January 2025 (10 days after the alleged event).

Current stage:
- Notice responded to: No
- Debt recovery letters: Yes
- Letter of Claim: Yes
- County Court claim: Yes
- Letter of Claim responded to: Yes
- Letter of Claim source: Operator's own legal department
- Operator legal team: dcb legal Ltd

Letter of Claim response already sent (verbatim where possible):

LoC response sent on 11/12/2025 to dcb legal Ltd. A response was received from dcb legal Ltd on 15/01/2026 - both attached verbatim below.

Dear Sirs,

Your Letter Before Claim contains insufficient detail of the claim and fails to provide copies of the evidence your client places reliance upon, putting it in clear breach of the Pre-Action Protocol for Debt Claims.

As a supposed firm of solicitors, one would expect you to comply 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 exist to facilitate informed discussion and proportionate resolution. You may wish to reacquaint yourselves with them.

The Civil Procedure Rules 1998, Pre-Action Conduct and Protocols (Part 3), require the exchange of sufficient information to understand each other’s position. Part 6 clarifies that this includes disclosure of key documents relevant to the issues in dispute.

Your template letter refers to a “contract” yet encloses none. That omission undermines the only foundation upon which your client’s claim allegedly rests. It is not possible to engage in meaningful pre-litigation dialogue while you decline to furnish the very document you purport to enforce.

I confirm that, once I am in receipt of a Letter Before Claim that complies with para 3.1(a), I shall seek advice and submit a formal response within 30 days, as required. Accordingly, please provide:

1. A copy of the original Notice to Keeper (NtK) and any notice chain relied upon to assert PoFA 2012 liability.

2. A copy of the contract you allege exists between your client and the driver, being an actual photograph of the sign(s) in place on the material date (not a stock image), together with a site plan showing the sign locations.

3. The precise wording of the clause(s) allegedly breached.

4. The written agreement between your client and the landowner evidencing standing/authority to enforce and to litigate.

5. A breakdown of the sums claimed, identifying whether the principal sum is claimed as consideration or damages, and whether the £70 “debt recovery” add-on includes VAT.


I am entitled to this information under paragraphs 6(a) and 6(c) of the Practice Direction, and I require it to meet my own obligation under paragraph 6(b).

If you fail to provide the above, I will treat that as non-compliance with the PAPDC and Pre-Action Conduct and will raise a formal complaint to the SRA regarding your conduct. I reserve the right to place this correspondence before the Court and to seek appropriate sanctions and costs (including, where appropriate, a stay and/or other case management orders).

Until your client complies and provides the requested material, I am unable to respond properly to the alleged claim or to consider my position. It would be premature and a waste of costs and court time to issue proceedings. Should you do so, I will seek immediate case management relief pursuant to paragraph 15(b) of the Practice Direction and an order compelling provision of the above.

Please note, I will not engage with any web portal; I will only respond by email or post.

------------------------------------------------------------------------------------------------

We write in response to your recent correspondence in response to our Letter of Claim (LOC) and will now respond as follows.

It is our position that the Letter of Claim (“LOC”) is compliant with the Pre-Action Protocol for Debt Claims (“the Protocol”). The LOC provides adequate information for you to identify the debt that our Client is seeking to recover. We would respectfully draw your attention to paragraph 2.1(c) of the Protocol and remind you that both parties are expected to act reasonably and proportionately.

For the avoidance of doubt, please note that the timeframe in which to appeal the Parking Charge has expired. You were given the opportunity to lodge an appeal when the initial Notice was issued to you. Given that the case has been escalated to this firm for recovery action, the time to appeal has now elapsed and payment of the Parking Charge(s) is now required.

The amount owed is a genuine pre-estimate of the losses incurred in managing the parking location to ensure compliance with the clearly displayed terms and conditions. Further, in accordance with the British Parking Association (BPA)/International Parking Community (IPC) Code of Practice, where the Parking Charge becomes overdue and before Court proceedings have commenced, a reasonable sum may be added for the debt recovery fees. The correct recovery fees have been added and will not be removed, for completeness we would advise that the fee is not inclusive of any VAT, as it does not pertain to a supply of goods/services between you and our Client.

To clarify, when parking on private land, the contractual terms of the site are set out on the signs. You are thus entering into a contract (by way of conduct) and agreeing to the terms by parking and staying on the site. Parking in breach of the terms as stipulated on the signage means that you are then breaking the terms of the contract.

Attached are copies of evidence pertaining to the matter, however, if there are any documents that you have requested, but that are not attached, it is because we have deemed the request to be disproportionate and/or not relevant to the substantive issues in dispute. We respectfully draw your attention to paragraph 2.1(c) of the Protocol and remind you that both parties are expected to act reasonably and proportionately.

You now have 30 days from the date of this email to make payment of the amount as per our Letter of Claim. Failure to make payment will result in a Claim being issued against you without any further reference.

Payment can be made via bank transfer to our designated client account: -

Account Name: DCB Legal Ltd Client Account
Sort Code: 20-24-09
Account Number: 60964441
You must quote the correct case reference (711200481722MET) when making payment. If you do not, we may be unable to correctly allocate the payment. If further action is taken by us as a result of an incorrect reference being quoted, you will be liable for any further fees or costs incurred.

We would ask that you kindly furnish us with your most up to date telephone number and email address, this can be emailed to us at info@dcblegal.co.uk.

Alternatively, you can contact DCB Legal Ltd on 0203 838 7038 to make payment over the telephone or online at https://dcblegal.co.uk/response/pay-online/.

Please note that in the absence of payment in the next 30 days, our position remains as previously advised. As such, should our client instruct us to proceed with further legal action, we reserve the right to do so without any further reference to you.

If you are at all unsure of your legal position, we recommend that you seek your own independent legal advice



Kind Regards,

Litigation Support Team

DCB Legal Ltd

County Court claim deadlines: issue date Monday, 23 February 2026, deemed service Saturday, 28 February 2026, AoS deadline 4pm Monday, 16 March 2026, defence deadline without AoS 4pm Monday, 16 March 2026, and defence deadline with AoS 4pm Monday, 30 March 2026.

Additional notes provided:
1. No driver details have been disclosed at any stage and all correspondence and PCN has been addressed to me as the R/K.

2. Vehicle was parked in the car park outside Starbucks with intention to make purchase / use facilities, however venue was found to be closed on approach and so walked about 20 yards to McDonalds with children and made purchase / used facilities.
(This information has not been disclosed to MET parking / dcb legal at any stage and has not been cited in the claim from them however I mention it as from researching similar previous claims from other people at the same venue MET parking / dcb legal have previously claimed this counted as leaving the car park and the two venue were separate with separate car parks - even though this is clearly not the case).

3. Vehicle was parked 55 mins with signs saying 1 hour free parking, however other images in other parts of the car park provided by MET parking show 30 mins. I think this relates to point 2 as well.

4. A child passenger that was in the car has a medically diagnosed disability (autism and ADHD) that is covered under the Equality Act 2010, (not previously raised but mentioned as came up in Q&A questions on your forum).

Please can I have advice on the strongest next steps and defence points for this case.
  Claim Form.pdf (Size: 1.57 MB / Downloads: 3)

Hello

Back in Nov, the Keeper got the standard 'fine' letter after visiting a McDonald's in Worcester Blackpole. 



After taking advice an attempt at appeal was made but no POPLA code number came through. 

A Notice of Debt Recovery was deliveed on 11/11 - was advised "Therefore, if the NtK was issued on Saturday 15 November. That means the it was deemed delivered (received) on Tuesday 18 November. Therefore the 28 day window of appeal is valid until Tuesday 16 December. The Notice of Debt Recovery was issued on 13 December, at least 3 days too early." Was advised to send an email to complaints@ukparkingcontrol.com and CC aos@britishparking.co.uk making a formal complaint which was done, but it was rejected by both parties. 

Escaltion from UKPC to ZZPS has happened. 

And then today this arrived from QDR



No liability has been admitted and no payment has been made.

Please can we have some advise on what to do next? 

Thank you.

Hi, 
as a few others have found I'm carrying this case over from FTLA. 

https://www.ftla.uk/private-parking-tick.../#msg97674

@b789 You have been such a great help and I'm glad to have found you on here. My latest question on 26th February was after the mediation call. 
 
 As nothing came of the other one that Gladstone's were pursuing back in December are they waiting for this current court claim to be concluded before starting the process all over again?  As such can they do that?


Thanks for all your advice and guidance with this.

A company vehicle was delivering to a contractors premises, Oakleaf Recycling which is situated on a private access road owned by Oak Leaf Farms. The Recycling business is seemingly a lease holder.

Google Maps: https://maps.app.goo.gl/EnbX4aTiDWxD2ZWC7 

We have had 5 of these before that were subsequently cancelled. They were all recorded stopped on the road waiting to enter the site due to its limited capacity.

This time the vehicle had stopped coming out of the site. I didn't know why at first and didn't look into it as I don't have the time to investigate everything. As far as I'm concerned, there is an implied licence to use the road as a customer/supplier of the leasehodler.

We received a Parking Charge NtK, I appealed it on the information I had at the time on 20th February.

Link to the original Notice to Keeper: https://drive.google.com/file/d/1Jr9hWGm...p=drivesdk 

Link to initial appeal: https://drive.google.com/file/d/1O_EpXWi...p=drivesdk

Also emailed the "Head of Legal Compliance" on 23rd February, as he had previously assisted in getting the previous ones cancelled and seemed reasonable.

Link to email correspondence with "Head of Legal Compliance": https://drive.google.com/file/d/1zQ9OhRw...p=drivesdk 

I later found out the vehicle had a defect that made it unsafe to continue it's commercial operations, or frankly to be on the road at all.

I submitted this information to the operator on 26th February with an invoice for the repairs made at Scania Heathrow that was a few miles down the road.

Email providing the Operator with the information: https://drive.google.com/file/d/1szzBxVf...p=drivesdk

Then we received an appeal rejection notice yesterday, 02/03/2026.

Link to Appeal Rejection Notice: https://drive.google.com/file/d/1n-jCVLO...p=drivesdk

After that was received, I sent our Head of Legal Compliance ex-friend, an email as the rejection notice did not consider the vehicle defect.

Link to further correspondence with Head of Legal Compliance: https://drive.google.com/file/d/1_TSOhI7...p=drivesdk

The Head of Legal Compliance thinks he did something by repeatedly saying every aspect of the code and case law I mentioned is misplaced, but then simultaneously only comes out with waffle himself. He also thinks he exposed me by stating some of my points are similar to those found on FTLA forums at the same time he's quoting Beavis for a business access road with no invitation to park. It was a poor attempt to discourage me from taking it further I know.

But my only option here is to appeal to IAS. If you remember anything about my employer, it's that they won't take this to court. They get spooked by their stupid debt collector letters and pay it. Which makes my job all the more impossible. 

In terms of appealing to IAS, what is the best strategy? I know with POPLA there is basically no point in appealing on legal grounds as the assesors will overlook it, but clear PPSSCoP breaches can be considered. Such as if a consideration period has not been exceeded.

I am aware that IAS is much worse though.

Alternatively, is it possible to provide my details as the driver details so all correspondence comes to me personally so I can deal with it,or is that a really bad idea?

Any advice on this?

https://www.google.com/maps/place/51%C2%...d-0.158298


https://ibb.co/tM9sRZ6p
https://ibb.co/wZMQzwZr

Hi Carrying this case (https://www.ftla.uk/private-parking-tick...#msg111411)  over from FTLA as not had much response over there. How does this look as a witness statement?  Need to submit by 6th March 2026. 

Any comments and recommended amends greatly appreciated - https://docs.google.com/document/d/1D9MD...ue&sd=true