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: 12)

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

Hello

To @b789  

Thank you

My original thread: https://www.ftla.uk/private-parking-tick...#msg109341

Since you left, no one seems to want to help me over there.

I would be grateful if you could continue assisting me with this case.

To summarise

I have received 2 LOC 1 LBC

No visible confines impeded in enforcement officers photo.
Driver has image of the officer taking pictures, showing an empty car park. So no claim that the driver has cost them business.
Photos taken over the span of one minute by enforcement officer.
Vehicle can be seen running in photos driver took of officer, possible to claim PCM tried to trap driver as driver was parking

Latest status

Moorside responded to my email

Dear Sirs,

Your Letter Before Claim contains insufficient detail of the claim and fails to provide copies of the evidence your client intends to rely upon. It is therefore non‑compliant with the Pre‑Action Protocol for Debt Claims (PAPDC). 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, proportionate resolution, and I suggest you reacquaint yourselves with them.

The Civil Procedure Rules 1998, Pre‑Action Conduct and Protocols (Part 3), require each party to exchange sufficient information to understand the 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 very basis upon which your client’s claim allegedly rests. It is not possible to engage in any form of meaningful pre‑litigation dialogue while you refuse to furnish the documents you purport to enforce.

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


1. A copy of the original Notice to Keeper and the full notice chain relied upon to assert any alleged PoFA 2012 liability.
2. An actual photograph of the sign(s) in situ on the material date (not stock images), together with a contemporaneous site map showing sign locations.
3. The precise wording of the contractual term(s) your client alleges were breached.
4. The written agreement between your client and the landowner evidencing authority to manage, enforce and litigate in their own name.
5. A clear breakdown of the sums claimed, identifying whether the principal amount is alleged consideration or damages, and clarifying the legal basis and VAT position of the £70 add‑on.


These documents are required under paragraphs 6(a) and 6(c) of the Practice Direction to enable me to meet my obligation under paragraph 6(b).

Your letter’s attempt at intimidation

I also note that your accompanying schedule manages to refer to a “CCJ” four times, in what is clearly intended as a coercive device rather than legitimate legal information. The repetition is telling: it demonstrates not confidence in your client’s position, but reliance on fear as a substitute for substance.

To be clear: I am fully aware that a County Court Judgment only arises after your client wins a claim (which is unlikely on the facts), and even then, any judgment paid within one calendar month is removed from the register and has no impact on credit. Your overuse of the term “CCJ” is therefore not only pointless but improper.

Your firm is on notice that this conduct will now be reported to:

• the Solicitors Regulation Authority, for use of misleading and oppressive tactics contrary to the SRA Code of Conduct; and
• the Competition and Markets Authority, under the Digital Markets, Competition and Consumers Act 2024, given the statutory prohibition on coercive and misleading commercial practices.


If you proceed to issue a claim without first providing the documents and information required under the PAPDC and Pre‑Action Conduct, I will draw your non‑compliance to the Court’s attention and seek appropriate sanctions, including a stay and case‑management orders pursuant to paragraph 15(b) of the Practice Direction. Any unreasonable conduct by you or your client will be relied upon in support of an application for costs.

For the avoidance of doubt, I will not engage with any web portal. I will respond only via email or post.

Yours faithfully,

[img]data:image/gif;base64,R0lGODlhAQABAIAAAAAAAP///yH5BAEAAAAALAAAAAABAAEAAAIBRAA7[/img]

https://ibb.co/qGsmTGq
https://ibb.co/60kfJpWC

What should I do now?

Every civil claim begins with the Particulars of Claim (PoC). They are not a formality. They define the case the claimant is bringing, the legal basis relied upon, and the factual allegations that must be answered. If the Particulars are defective, vague or non-compliant with the Civil Procedure Rules (CPRs), the entire claim rests on unstable ground.

In private parking litigation, this point is routinely overlooked. Many claims are issued using standardised, formulaic wording that asserts the existence of a “contract” and a “breach” without properly identifying what agreement is relied upon, how it was formed, or what specific terms were allegedly broken. Defendants are then expected to respond to a case that has not been properly articulated.

The High Court decision in Liberty Homes (Kent) Ltd v Others [2022] EWHC 2201 (TCC) is a reminder that this is not acceptable pleading. It reinforces a fundamental procedural principle: where a claim is based on an agreement, the claimant must clearly state whether that agreement is written, oral, or made by conduct, and must plead the required particulars for that category. Failure to do so is not a minor drafting defect; it is a failure to comply with the rules governing how contractual claims must be brought.

For anyone defending a private parking claim — or advising on one — understanding the importance of robust, rule-compliant Particulars of Claim is essential. The adequacy of the pleading is often the first, and sometimes the most powerful, line of defence.

The decision in Liberty Homes (Kent) Ltd v Others [2022] EWHC 2201 (TCC) is procedurally significant because it reinforces strict compliance with CPR 16.4 and Practice Direction 16 where a claim is based on an agreement. Although it arose in a construction context, the principles are directly applicable to private parking claims, which are almost invariably pleaded as contractual claims.

The core procedural framework is set out at paragraph 42:

Quote:“The rules and Practice Direction together provide that the Particulars of Claim must set out a concise statement of the claimant’s case and, where it is based on an agreement, must provide the particulars or details specified in the Practice Direction. It is implicit that the Particulars of Claim must set out the claimant’s case as to whether the agreement is oral or in writing or made by conduct or some combination.”

• If the claim is based on a written agreement, a copy of the contract or the documents constituting the agreement should be attached to or served with the Particulars of Claim.
  
• If the claim is based on an oral agreement, the Particulars should set out the words used and state by whom, to whom, when and where they were spoken.
  
• If the claim is based on an agreement by conduct, the Particulars must specify the conduct relied upon and state by whom, when and where the acts constituting the conduct were done.
  

• “The Defendant entered into a contract by parking.”
  
• “The terms were displayed on signage.”
  
• “The Defendant breached the terms.”
  

1. State whether the alleged agreement is said to be written (the signage), oral, or by conduct.
   
2. Attach or serve the written contractual terms relied upon (that is, the full signage wording).
   
3. Particularise the conduct said to constitute acceptance.
   
4. Identify the specific term said to have been breached.
   
5. Identify clearly who the contracting parties were, particularly where the claim is against a registered keeper.
   

• The Particulars disclose no properly pleaded cause of action because they do not identify the nature of the alleged agreement.
  
• The claimant has failed to comply with PD16 paragraph 7.
  
• The court should strike out the Particulars or order Further and Better Particulars before the defendant is required to plead substantively.