03-19-2026, 02:31 PM
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)
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)
