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?

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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]

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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.