Gladstones Letter Before Claim - NPM PCN - No e-Permit - Woodgrange Road E7

[armz247]

Hi all,

I previously posted this on FTLA, but understand b789 may now be more active here. My FTLA thread is here:

https://www.ftla.uk/private-parking-tick...?topicseen

This relates to a private parking charge from National Parking Management Ltd at Woodgrange Road 13-15, London E7.

Summary:

* PCN: NPM207017
* Operator: National Parking Management Ltd
* Solicitor: Gladstones
* Location: Woodgrange Road 13-15, London E7
* Alleged contravention: Vehicle not pre-authorised, no e-permit
* Date of alleged charge: 23/12/2025
* Alleged time on site: 21:08:18 to 21:11:01, approx. 2 minutes 43 seconds
* Notice received: postal Notice to Keeper
* Keeper appeal rejected
* Driver has not been identified
* I am the registered keeper
* Letter Before Claim dated: 2 June 2026
* Amount now claimed: £170
* Estimated total if proceedings are issued: £255

Redacted Letter Before Claim:

Page 1: https://ibb.co/DHjWGvcM
Page 2: https://ibb.co/xqg4tG09
Page 3: https://ibb.co/JF2M6L6P

On FTLA I posted a draft PAPDC/document request response based on similar b789 templates I found. I have since had a reply suggesting that the response to a Letter of Claim should be simpler, and questioning the value of asking Gladstones for documents I already have, such as the Notice to Keeper.

I would appreciate guidance on the best response to Gladstones at this stage.

Would something shorter like the below be more suitable, or should I still use a fuller PAPDC/document request response?

---

Subject: Response to Letter Before Claim - PCN NPM207017

Dear Sirs,

Re: Letter Before Claim dated 2 June 2026
PCN: NPM207017
Client: National Parking Management Limited
Location: Woodgrange Road 13-15

I deny any debt to your client.

The vehicle was present on site for less than three minutes. I deny that any contract was formed or breached. The signage at this location does not make any clear offer of parking, nor does it explain how a driver could obtain an e-permit. In the absence of a clear offer capable of acceptance, no contract can exist.

I also dispute the added £70. Please explain the legal basis on which this sum is claimed, whether it is said to be consideration, damages, debt recovery costs, or something else, and whether VAT is included.

Please also provide the documents and evidence on which your client intends to rely, including:

1. Actual photographs of the signs in place on the material date, not stock images.
2. A site plan showing the position of the signs.
3. The precise wording of the clause or clauses allegedly breached.
4. The written agreement between your client and the landowner evidencing authority to enforce and litigate at this location.
5. Your client’s full basis for alleging keeper liability under Schedule 4 of the Protection of Freedoms Act 2012.
6. Copies of any video evidence relied upon.

I will not use your web portal. Please correspond by email or post.

For the avoidance of doubt, I am seeking debt advice, but I deny the debt.

Yours faithfully,

[Name]

---

Am I on the right track with this shorter response, or should the fuller PAPDC non-compliance template be used instead?

[b789]

@armz247, irrespective of what you put in your response to the Letter of Claim (LoC), the utter incompetents at Gladstones are going to issue a county court claim, no matter what. 
Knowing how incompetent the staff are at Gladstones, if/when they issue the county court claim, you can guarantee that the Particulars of Claim (PoC) will be the usual vague, template wording which fails to properly plead the cause of action. That can be dealt with if and when the claim arrives.

However, the purpose of replying to Gladstones is not to persuade them. The purpose is to create a clean pre-action paper trail showing that the debt was disputed, that the core issues were identified, that key documents were requested, and that any later claim was issued despite obvious weaknesses. The general pre-action direction expects a defendant’s response to say whether the claim is accepted and, if not, the reasons why and which facts are disputed. For an individual facing a debt claim, the Debt PAP is also relevant and provides that proceedings should not be started less than 30 days from receipt of the completed Reply Form, or 30 days after documents requested by the debtor are provided.

A long response is fine if every paragraph serves a pre-action purpose. But the usual copy-and-paste LoC replies are often counterproductive because they ask for documents already held, include irrelevant points from other cases, overstate weak arguments, and give Gladstones a chance to say the debtor has sent a generic template rather than engaging with the facts. It also dilutes the best points.

These are the best points to make in this case:

1. The alleged stop was under three minutes.
   
2. The evidence is at night.
   
3. The sign appears unlit.
   
4. The vehicle was stopped just beyond the sign, not deep inside a clearly marked car park.
   
5. The sign appears to say “E-Permit Holders Only”, which is prohibitive rather than contractual.
   
6. There is no obvious offer of parking to non-permit holders.
   
7. The £70 add-on is disputed as an unrecoverable invented debt recovery sum.
   
8. The Claimant is put to strict proof of landowner authority, signage, contractual terms and the legal basis of the charge.
   

That is all they need at LoC stage. Any detailed evidence analysis, PPSCoP breaches, photographs, timeline, and case law belong in the defence and witness statement if/when they issue the claim.

Only ask for documents which they are likely to rely on and which matter to the dispute: the full unedited video, all stills, the contemporaneous signage pack, a site plan showing sign positions, the landowner contract or chain of authority, and the basis for the added £70.

A suitable response should probably be no more than a page. Something along these lines would be proportionate:

Dear Sirs,

Re: National Parking Management Limited
PCN: NPM207017
Your reference: 104542.2148

I dispute the debt in full. No admission is made as to liability, and your client is put to strict proof of its cause of action.

The alleged contravention is denied. Your client’s own evidence appears to show no more than a brief stop of less than three minutes at night, immediately beyond an unlit and inadequately positioned sign at the entrance to a cul-de-sac. The sign was not prominent, was not lit, and the alleged contractual terms were not capable of being read and accepted by a motorist before any alleged contract could be formed.

Further, the visible wording appears to be “E-Permit Holders Only”. That is prohibitive wording. It does not make any contractual offer to non-permit holders to park for £100. Your client is therefore put to strict proof that any contract was offered, that the terms were adequately brought to the driver’s attention, and that the driver accepted those terms.

The additional £70 is also disputed. It is not a genuine contractual sum owed by the motorist and appears to be an unrecoverable debt recovery enhancement added to inflate the claim.

Please provide the following documents before any claim is issued:

1. The full unedited CCTV/video footage from which the still images were extracted.
   
2. Confirmation that the still images already disclosed are the complete set of still images relied upon, and copies of any additional stills not already disclosed.
   
3. Legible contemporaneous photographs or the signage artwork showing the exact contractual terms displayed on 23 December 2025.
   
4. A site plan showing the exact location of every sign relied upon.
   
5. Evidence that the entrance sign was illuminated, or otherwise readable from a driver’s approach and stopping position, at the material time of night.
   
6. The contract or chain of authority showing National Parking Management Limited’s authority to issue charges and litigate in its own name at this location.
   
7. A full explanation of the legal basis for the additional £70.
   

For the avoidance of doubt, no payment will be made. If your client nevertheless issues proceedings, the claim will be robustly defended and this response will be relied upon when the court considers conduct and costs.

Yours faithfully,

That keeps the response tight. It does not try to write the defence early. It does not get dragged into irrelevant template material. It preserves the main arguments and forces Gladstones either to engage with them or ignore them, which is usually useful later.

[armz247]

@b789

Thanks, that makes sense.

One practical point before I send the response: Gladstones’ Letter Before Claim says I can respond via their website, which requires creating a login, or request a paper version of the Information Sheet and Reply Form. It does not expressly give email as a response method, although their enquiries email appears on the letter.

Should I:

1. send the response by email to [enquiries@gladstonessolicitors.co.uk](mailto:enquiries@gladstonessolicitors.co.uk) and CC myself;
2. also post a copy first class with proof of posting;
3. request a paper Reply Form as well; or
4. use their online portal?

I would prefer not to use the portal if avoidable, but I also do not want Gladstones later arguing that I failed to respond properly under the PAPDC.

[b789]

@armz247, do not overthink the portal point. Gladstones are almost certainly going to issue a claim whatever you do. That is their usual conveyor-belt process. When the claim arrives, it will almost certainly be their usual vague template Particulars of Claim (PoC), and any CPR 16.4/PD16 deficiencies can be dealt with at that stage.

The purpose of replying to the Letter of Claim is not to persuade Gladstones, because they are not going to be persuaded. The purpose is simply to create a clean paper trail showing that the debt was disputed, the core issues were identified, and the relevant evidence was requested.

I would not use their portal. There is no requirement to create a Gladstones login just to dispute a debt. Send the response by email to their enquiries address and, if you really want to, also send a hard copy by first-class post with a free certificate of posting from the Post Office. However, it is not really necessary to send your response by post. That would be more than enough to show engagement. If they later pretend you failed to engage with the PAPDC because you did not use their portal, that would be nonsense.

Do not worry about trying to perfect the PAPDC stage. It is not the trial and it is not the defence. Just send the denial, request the key evidence, keep proof of sending, and wait for the inevitable defective claim. The detailed CPR 16.4 point comes later.

[armz247]

@b789

Just to update, I followed your advice and emailed the LoC response to Gladstones’ enquiries address on 19 June 2026, CC’ing myself and keeping proof of sending.

Gladstones have now replied saying they have attached “Evidence Packs”, that their client is satisfied the case should proceed unless £170 is paid by 18 August 2026, and that if payment is not made they are instructed to issue proceedings.

They also state my email was dated 19 July 2026, but it was actually sent on 19 June 2026.

From what I can see, the evidence pack includes the NtK, appeal material, stills/photos and a surrounding sessions lookup, but it does not appear to include the key items requested: full unedited video, site plan, evidence of sign illumination/readability at night, landowner authority/chain of authority, or a proper explanation of the added £70.

I understand the point is not to persuade Gladstones and that a claim is likely anyway.

Is there any tactical value in sending one short reply saying the debt remains disputed and the requested key documents remain outstanding, or should I now say nothing further and wait for the claim?

Thank you.

[b789]

There is some tactical value in sending one final, very short reply. It should correct their false date, record that they have not complied with the document request, and prevent them later claiming that their "Evidence Packs" answered it. Do not repeat the substantive defence or enter into further correspondence.

I would respond:

Dear Sirs,

Re: National Parking Management Ltd
PCN NPM207017
Your reference: 104542.2148

Your email incorrectly states that my response was dated 19 July 2026. It was sent on 19 June 2026, as my retained email records confirm.

The alleged debt remains disputed in full.

The "Evidence Packs" supplied do not answer my document request. In particular, you have not provided:

1. the full, unedited video footage;
   
2. a site plan showing the location of every sign relied upon;
   
3. evidence that the signage was illuminated or readable at the material time;
   
4. the landowner contract or complete chain of authority; or
   
5. a proper explanation of the contractual or other legal basis for the additional £70.
   

Please provide those documents, or explain why they are unavailable, in accordance with paragraph 5.2 of the Pre-Action Protocol for Debt Claims.

Your client's position has been noted. If proceedings are issued without the requested documents being provided, the claim will be defended and this correspondence will be relied upon when the court considers the parties' pre-action conduct.

Yours faithfully,

Send it by email and then say nothing further unless they provide something genuinely requiring a response. Their arbitrary demand for payment by 18 August does not require you to pay, negotiate or restate the entire defence. After that, simply await the claim.

[armz247]

@b789

Gladstones have now replied again after my final short response. Their full reply is below:

---

Dear [my name],

Further to your email dated 18th August 2026.

Please see attached signage along with the site map as requested.

As the content of the Landowner Agreement is commercially sensitive, a (redacted) copy of the same will only be released at the direction of the Court. This is usually, but not limited to, 14 days prior to the hearing.

The amount due includes £70.00 claimed by our client for the time/resources spent facilitating the recovery of the unpaid parking charge notice(s) pursuant to its ATA’s Code of Practice and the Terms and Conditions of the Contract, which was entered into upon the driver of the vehicle entering the Relevant Land.

We remind you it is the responsibility of the driver to ensure they comply with the parking regulations on site and thus, as it is abundantly clear you have failed to do so, we are satisfied the charges have been issued correctly and all sums owing are due in full.

As a gesture of goodwill, we have extended the date within which to make payment to the 21st September 2026. In the event you do not make payment, we carry instructions to issue legal proceedings to recover the debt in full. Should it become necessary to issue legal proceedings, we strongly recommend you follow the steps on the claim form upon receipt of the same.

For the avoidance of doubt, we confirm we will not accept any further submissions from you.

---

They attached a PDF headed “Site Map”, which i've attached. They still have not provided the full unedited video footage. They have also refused to provide the landowner agreement at this stage, saying it is commercially sensitive and will only be released at the direction of the court.

Their explanation for the added £70 also appears to be the usual time/resources/debt recovery wording.

Given they say they will not accept further submissions, should I now leave it and wait for the claim, or is there any tactical value in sending one final reply?

[Brenda_R2]

Given they say they will not accept further submissions, should I now leave it and wait for the claim, or is there any tactical value in sending one final reply?

And what are you going to say?

They've already told you the drawbridge is up.

As @b789 correctly surmised: "Send it by email and then say nothing further".

Listen to the excellent advice you are receiving here.

[armz247]

Given they say they will not accept further submissions, should I now leave it and wait for the claim, or is there any tactical value in sending one final reply?

And what are you going to say?

They've already told you the drawbridge is up.

As @b789 correctly surmised: "Send it by email and then say nothing further".

Listen to the excellent advice you are receiving here.

@Brenda_R2 Understood, thank you.

Just to clarify, I did follow b789’s previous advice and sent the short tactical reply he drafted. I was only updating the thread with Gladstones’ latest response so the full context is recorded in case it becomes relevant later.

I’ll now wait for the claim unless b789 advises otherwise.

[b789]

@armz247, @Brenda_R2 is right. You have already done exactly what was advised: you sent the short tactical response, Gladstones replied, and you have now updated the thread so their latest position is recorded. There is no need to send them anything further. I would now leave the utter incompetents at Gladstones alone and wait for the claim.

Their latest response has actually given you several useful points to preserve for the defence and, later, the witness statement.

First, their position on the landowner agreement is pathetically ridiculous. They have confirmed that the document exists, but refuse to provide even a redacted copy because it is supposedly "commercially sensitive", saying it will only be disclosed at the direction of the court, usually 14 days before the hearing.

Commercial sensitivity is not the same as the document being unavailable, nor does it give them some automatic entitlement to conceal the provisions which establish whether NPM actually had authority/standing to operate on this land, issue parking charges, enter into contracts with motorists and litigate in its own name. Irrelevant commercial information can obviously be redacted.

More importantly, 14 days before a small-claims hearing is ordinarily the standard deadline for serving the documents relied upon. It is not some special disclosure privilege enjoyed by the idiots at Gladstones. If the court orders the usual simultaneous exchange of evidence 14 days before the hearing, how is a Defendant supposed to receive the alleged landowner authority for the first time on the same day their own evidence is due, scrutinise it for defects and then address those defects in their witness statement? That issue can be dealt with after the claim is issued, including, if necessary, asking the court for a specific direction requiring earlier disclosure. For now, keep their written refusal.

Their supposed signage evidence is also useful for entirely the wrong reasons. The site photographs they have supplied are dated 13 January 2023. The alleged event was 23 December 2025. So their photographs are nearly three years old and were taken in daylight, whereas the alleged contravention occurred at about 21:08 on a dark December night. Those photographs do not establish what signs were actually present on the material date, still less that they were illuminated and readable in darkness.

The clean image of the sign at the end of their pack is simply a specimen/artwork image. It proves what NPM says its sign looks like; it does not prove that that sign was actually installed, in that form, at the relevant location on 23 December 2025.

There is then a more fundamental problem with the wording of the sign itself. The prominent operative term says:

"Parking is permitted for pre-authorised vehicles (NPM E-Permit)".

So what contractual offer is being made to a vehicle which is NOT pre-authorised?

The sign does not say that an unauthorised motorist may park for £100. It says that parking is permitted for pre-authorised vehicles. The £100 wording lower down says that by parking or remaining the driver accepts liability for failing to comply with the terms, but that does not automatically resolve the basic contractual problem. NPM must still identify an offer made to this particular driver, consideration provided by NPM and conduct amounting to acceptance. If permission to park is expressly confined to pre-authorised vehicles, there is an exceptionally strong argument that a non-permit holder was never offered parking at all. At most, that potentially leaves a question of trespass, which makes NPM's withheld landowner agreement and the precise extent of its authority even more important.

There is also still no proper evidence of a compliant entrance sign at the material date and time. Their site map marks alleged sign locations and one of their old 2023 daytime photographs appears to show a sign near the entrance, but the wording is unreadable. A diagram with green stars does not prove that a particular sign was physically present, positioned correctly and readable to a driver entering the road almost three years later at 21:08 in darkness.

The issue is not simply whether there was "a sign somewhere". Before NPM can rely upon detailed terms further inside the site, it needs to establish that a driver was adequately alerted that they were entering controlled private land and directed to the contractual terms. Their evidence does not establish that. Nor does it establish that the detailed signs themselves were illuminated or otherwise readable at night.

That matters particularly because their own evidence shows the vehicle there for only about 2 minutes 43 seconds. The driver exited shortly after stopping, returned and left. On those facts there is a very obvious issue as to whether the driver was doing no more than stopping long enough to identify the restrictions, consider them and leave, rather than accepting any supposed contractual offer.

So there is no benefit in educating the dimwits at Gladstones any further. They have said they will accept no further submissions anyway, and, as you have already confirmed in reply to @Brenda_R2, you are now simply waiting for the claim unless there is some genuinely new development.

Preserve everything they have sent, including:

• the refusal to disclose the landowner agreement;
  
• the nearly three-year-old daytime signage photographs;
  
• the specimen sign artwork;
  
• the absence of contemporaneous evidence of illuminated/readable entrance signage;
  
• the wording restricting permission to pre-authorised vehicles; and
  
• the absence of the full unedited video which was specifically requested.
  

Let them issue the inevitable claim. We can then deal with whatever defective template Particulars of Claim (PoC) they produce and plead these points properly in the Defence. The detailed evidential demolition comes later. I can guarantee that the PoC in any claim issued by Gladstones is defective.