Form submission: Private Parking Ticket Details

[RandG]

Type of parking ticket: Parking Charge Notice (PCN) or Charge Notice (CN)

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Country: England/Wales

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Parking operator: New Generation Parking Management Ltd (IPC)

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Operator (Other):

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First Awareness: Reminder/Final Notice from the operator

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Awareness (Other):

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Date of Alleged Contravention: Thu 23/05/2024

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Issue Date on Notice: Tue 21/01/2025

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Method of Issue: By post (ANPR/camera)

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Issue Method (Other):

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Driver Identified: No – the driver has not been identified

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Who Identified Driver: Not applicable

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Driver Disability/Protected Characteristic: No

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Location Known: Yes

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Location Type: Retail park/supermarket

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Location Name: Malpas road Shopping Centre

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Responded to Notice: No

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Initial Appeal Made: No

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Appeal Response Received: Not applicable

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Secondary Appeal: Not applicable

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Secondary Appeal Outcome: Not applicable

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Debt Recovery Letters: Yes

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Letter of Claim: Yes

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County Court Claim: Yes

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Court Stage: Hearing date set

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Evidence Available: Yes

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Your role in this case?: Acting on behalf of the Registered Keeper

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Role Explanation:

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Additional Information: Hi b789

You have been supporting my case over on ftla for the past 12 months.

I have received letter of 'Notice of Allocation to the Small Claims Track (Hearing)'and have been given a hearing date of 31 March 2026 at the County Court Newport.

We've been given a deadline of 16 February to submit witness statements.

DCB Legal have been set a deadline to pay the court fee of 3rd March 2026.

I have seen your advice on other posts regarding writing to the court to get the deadline pushed back because they wont pay the court fee. Could you help me write the letter please. Many thanks.

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[b789]

Hi @RandG and welcome to the forum. Based on what you have entered on the forum, I will summarise it below and then go find the thread over on FTLA so I can catch up on the detail.

What you've described is a private parking claim that has now reached the small-claims hearing stage.

The matter concerns a Parking Charge Notice (PCN) issued by New Generation Parking Management Ltd, an IPC member, in England/Wales. The alleged contravention took place on 23 May 2024 at Malpas Road Shopping Centre, a retail park/supermarket location. The charge was not issued contemporaneously; the first notice the Registered Keeper became aware of was a reminder/final notice, with the Notice itself dated 21 January 2025 and issued by post using ANPR evidence.

The driver has never been identified, and you are acting on behalf of the Registered Keeper only. No appeal was made at any stage, and the matter escalated through debt recovery, a Letter of Claim, and ultimately to a County Court claim.

The claim has now been allocated to the small claims track. A Notice of Allocation has been received confirming a hearing date of 31 March 2026 at Newport County Court. The court has ordered that witness statements be filed by 16 February 2026. The Claimant’s solicitors, DCB Legal, have been ordered to pay the hearing fee by 3 March 2026.

Your specific request is procedural rather than substantive. Having seen advice in other cases, you are asking for assistance in drafting a letter to the court seeking to push back or manage deadlines on the basis that DCB Legal frequently fail to pay the hearing fee on time, which can render the existing witness statement deadline premature or unnecessary. You are seeking help to draft that letter to the court.

[b789]

So, having reviewed the thread over on FTLA, I want to be clear about where things now stand and what you need to do next.


The original problem was that you never received the claim because of an IT failure at the Civil National Business Centre. After advising you to complain, The court accepted that this was an administrative error and set the judgment aside using its own powers. The claim has therefore been restored and re-allocated to the small claims track, with fresh directions. We are now bound by those directions.

The court has ordered that witness statements must be filed and served by 16 February 2026. Separately, DCB Legal have been ordered to pay the hearing fee by 3 March 2026, with the hearing listed for 31 March 2026.

Although it looks illogical that the witness statement deadline comes before the trial fee deadline, the court is extremely unlikely to change that simply because DCB Legal may not pay the fee. This sequencing is common in small claims. The court expects parties to comply with directions as given, not to assume that the claimant will later abandon the claim.

Based on experience, it is overwhelmingly likely that DCB Legal will discontinue before the hearing fee deadline. They do this routinely and very late in the process. Unfortunately, that likelihood does not remove your current obligations.

Two things are important.

First, even if DCB Legal fail to file a witness statement by the deadline, you are still required to file yours. Your obligation is independent of theirs. If you do not file a witness statement on time, you risk being barred from relying on your defence or evidence.

Second, even if the claim is later discontinued, the court will expect to see that you complied fully with the directions up to that point. Non-compliance can seriously weaken any later position on costs or unreasonable conduct.

The practical consequence is that you now have to prepare and submit a witness statement by the deadline. I appreciate that this is a lot of work and that there is a very real chance it will never be tested at a hearing because DCB Legal are likely to discontinue anyway. However, there is no safe procedural shortcut around this.

Given the time pressure, the aim is not to overcomplicate things. The witness statement needs to be clear, factual, and focused on why you are not liable. Judges tend to skim witness statements, so clarity and structure matter far more than volume or heavy legal argument.

If DCB Legal discontinue, the effort will feel wasted, but it was still necessary. If they do not, having a compliant and properly prepared witness statement in place is essential.

In short, you must proceed on the basis that the claim is live, comply with the witness statement deadline, and treat any later discontinuance as a bonus rather than something you can rely on.

Here is a draft WS you can use. However, do NOT submit anything until the last possible moment which is 4pm on Monday 16 February.

IN THE COUNTY COURT AT NEWPORT     Claim No: [Claim Number]

BETWEEN:

New Parking Generation Management Ltd

Claimant

- and -

[Defendant's Full Name]

Defendant

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WITNESS STATEMENT

1. I am the Defendant in this claim and the registered keeper of the vehicle. I make this witness statement from matters within my own knowledge to address the issues of service of any Notice to Keeper, the alleged transfer of liability to me as keeper, and the absence of any evidence identifying me as the driver.

2. The claim concerns an alleged parking event said to have occurred on 23 May 2024.

3. At the time the Defence was filed, I had not been provided with any evidence capable of establishing keeper liability, driver identity, or effective service of a Notice to Keeper. The Particulars of Claim were sparse and did not plead the facts necessary for me to understand or respond to the claim beyond a general denial. In those circumstances, and in the absence of any contemporaneous evidence or properly particularised allegations, the Defence was necessarily framed on the basis that the Claimant had failed to plead or disclose a viable cause of action.

4. I did not receive any Parking Charge Notice or Notice to Keeper at the time of the alleged event, nor did I receive any such notice within the weeks following it. My first awareness of any alleged parking charge was many months later, via third-party debt-recovery correspondence.

5. At the material time, I was in the process of moving home. I had access to my new property from 9 May 2024 but remained resident at my previous address until the end of May 2024.

6. The alleged parking event occurred on 23 May 2024.

7. On 25 May 2024, I put a Royal Mail redirection in place from my previous address to my new address. That redirection ran for a period of three months. I permanently vacated my previous address on 31 May 2024.

8. I updated the vehicle’s V5C with the DVLA on 1 June 2024. That update was made promptly once I had permanently moved, and I have confirmation of the update date.

9. Accordingly, during the period immediately following the alleged event, I had taken reasonable and responsible steps to ensure continuity of postal service by way of Royal Mail redirection, and I updated the DVLA without delay once the move was complete. I did nothing wrong and did not fail in any obligation to notify the DVLA.

10. The alleged parking event occurred on 23 May 2024. Under Schedule 4 paragraph 9(3)(b) of the Protection of Freedoms Act 2012, any Notice to Keeper must be given to the registered keeper within the relevant period of 14 days beginning with the day after the parking event, namely no later than 6 June 2024.

11. The Claimant relies on a document described as a Notice to Keeper dated 31 May 2024. The Claimant has acknowledged that at the time of the parking event it obtained keeper details from the DVLA showing my former address and that correspondence was sent on that basis. Any Notice to Keeper sent to that address was not received by me. This is despite the fact that a Royal Mail redirection was in force at the time, further demonstrating that the notice was not effectively served.

12. The Claimant has produced no proof of posting, no certificate of posting, and no other evidence demonstrating that the Notice to Keeper dated 31 May 2024 was correctly addressed, posted, and given to me. The Claimant has disclosed only the date the notice was generated. Under the applicable Private Parking Single Code of Practice, operators are required to retain evidence of posting of notices. In the absence of such proof, the Claimant cannot establish that the Notice to Keeper was “given” within the meaning of paragraph 9 of Schedule 4 of the Protection of Freedoms Act 2012. Accordingly, keeper liability cannot arise.

13. I have never identified the driver of the vehicle to the Claimant or to any of its agents. I have made no admission at any stage as to the identity of the driver.
The burden of proof rests with the Claimant to establish that I was the driver at the material time. The Claimant has produced no evidence capable of proving the identity of the driver.

14. No adverse inference can be drawn against me as registered keeper in respect of driver identity. In the absence of evidence, any assertion that I was the driver is unsupported.

15. In summary, I did not receive a Notice to Keeper within the relevant period, the Claimant has failed to prove that any Notice to Keeper was given in accordance with Schedule 4 of the Protection of Freedoms Act 2012, the driver has never been identified, and the Claimant has no evidence capable of proving that I was the driver. On that basis, the Claimant cannot establish that I am liable for the alleged charge.

Statement of truth

I believe that the facts stated in this Defence are true. I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth.

Signed:

Date:

In the meantime, review it and let me know if there is anything missing or wrong in it. You will need all the evidence you have from correspondence between yourself and the claimant/DCB Legal which you will need to index on separate pages with the court header on each page and referenced with your initials and numbered sequentially as they will appear in the WS. Eg; "Exhibit XX-01" and then you need to mention in the WS, the reference to that exhibit with "See exhibit XX-01" etc.

[RandG]

Hi b789, 

Thank you very much for your reply and best of luck with your own forum. 

I've reviewed your draft WS and have a few questions:

1. On point 11, DCB Legal sent two NtK in the same file. One dated 31st May 2024 and the other dated 1st July 2024. Both of these are addressed to the new address. What is confusing is that the V5C was not updated till 1st June, so I'm not sure where they the got the new address from for the letter dated 31st May, as NGPM Ltd claimed in an email they used the DVLA at the time of the offence. So my question would be, should this confusion be mentioned and should the second letter be mentioned at all (as neither were received). 

2. Should I provide screenshot evidence for the Royal Mail redirect and DVLA log book update. 

Many thanks as always.

[b789]

I’ve looked at both points and this is how I suggest we deal with them...

On the two letters dated 31 May and 1 July: only the 31 May 2024 letter is relevant for Keeper liability. That is the only document that could potentially count as a Notice to Keeper for PoFA purposes. The 1 July 2024 letter is just a reminder and cannot create or repair Keeper liability, so it is not treated as an NtK and does not need to be analysed as one.

That said, the address inconsistency is worth mentioning, but only in a limited way. NGPM have said they obtained your details from the DVLA at the time of the event, which would have shown your old address. However, the 31 May letter is addressed to your new address, even though your V5C was not updated until 1 June. The Claimant has never explained how or when they obtained the new address. This doesn’t need to be framed as an accusation — it simply shows that their evidence is internally inconsistent and that they have not proved proper service.

The key point remains that neither letter was received, and the Claimant has produced no proof of posting or service. The 1 July letter is mentioned only to show that multiple documents were generated, none of which were received, and none of which are supported by proof of posting.

On evidence: yes, you should provide screenshots or confirmations for both the Royal Mail redirection and the DVLA V5C update. These are strong, straightforward pieces of evidence. They show that you took reasonable steps to ensure continuity of post and updated the DVLA promptly. They also help rebut any suggestion that non-receipt was your fault.

Used together, this keeps the focus exactly where it should be: the Claimant cannot prove that any Notice to Keeper was properly given within the required period, and therefore cannot rely on keeper liability.

Here is adjusted paras 10-11 that will cover that:

10. The Claimant relies on a document described as a Notice to Keeper dated 31 May 2024. The Claimant has stated that it obtained my keeper details from the DVLA at the time of the alleged event, which it accepts showed my former address. Any Notice to Keeper sent to that address was not received by me. This is despite the fact that a Royal Mail redirection from my former address to my new address had been in force since 25 May 2024, further demonstrating that the notice was not effectively served.

11. The Claimant has produced no proof of posting, no certificate of posting, and no other evidence demonstrating that the Notice to Keeper dated 31 May 2024 was correctly addressed, posted, and given to me. The Claimant has disclosed only the date the notice was generated. The Claimant has also provided no explanation as to how my new address appears on its correspondence dated 31 May 2024 when my DVLA V5C was not updated until 1 June 2024. In the absence of proof that a Notice to Keeper was properly given to me by 6 June 2024, as required by paragraph 9 of Schedule 4 of the Protection of Freedoms Act 2012, the Claimant cannot rely on Schedule 4 to transfer liability to me as registered keeper.

For the exhibits, keep it simple and neutral. You only need to reference each document once, at the point it becomes relevant, using standard court wording. There’s no need to explain the document in detail or repeat what the judge already knows.

You can label exhibits as “Exhibit A”, “Exhibit B” etc, but it is often clearer to use your initials followed by a sequential number, for example RG-01, RG-02, RG-03. This makes it immediately obvious which party the exhibits belong to and avoids confusion if the Claimant also uses lettered exhibits. Either approach is acceptable, but initials plus numbering is generally cleaner and preferred in practice.

I suggest using the following exhibits:

XX-01 – Royal Mail redirection confirmation showing the redirection start date of 25 May 2024.
XX-02 – DVLA confirmation showing the V5C update date of 1 June 2024.
XX-03 – A copy of the document described by the Claimant as the Notice to Keeper dated 31 May 2024.

In the witness statement, simply refer to each document at the first relevant paragraph (for example, “a copy is exhibited at Exhibit XX-01”). That is sufficient. The judge can read the exhibit if needed; your job is only to anchor it to the factual point you are making.

For example:

6. On 25 May 2024, I put a Royal Mail redirection in place from my former address to my new address. That redirection remained in force for a period of three months. A copy of the redirection confirmation is exhibited at Exhibit XX-01.


7. I permanently vacated my former address on 31 May 2024. I updated the vehicle’s V5C with the DVLA on 1 June 2024. Confirmation of the DVLA update date is exhibited at Exhibit XX-02

8. Accordingly, during the period immediately following the alleged event, I had taken reasonable steps to ensure continuity of postal service by way of Royal Mail redirection, and I updated the DVLA promptly once the move was complete.

9. The alleged parking event occurred on 23 May 2024. Under Schedule 4 paragraph 9(3)(b) of the Protection of Freedoms Act 2012, any Notice to Keeper must be given to the registered keeper within the relevant period of 14 days beginning with the day after the parking event, namely no later than 6 June 2024.

10. The Claimant relies on a document described as a Notice to Keeper dated 31 May 2024, a copy of which was disclosed by the Claimant and is exhibited at Exhibit XX-03. The Claimant has stated that it obtained my keeper details from the DVLA at the time of the alleged event, which it accepts showed my former address. Any Notice to Keeper sent to that address was not received by me. This is despite the fact that a Royal Mail redirection had been in force since 25 May 2024.

11. The Claimant has produced no proof of posting, certificate of posting, or other evidence demonstrating that the Notice to Keeper dated 31 May 2024 was correctly addressed, posted, and given to me. The Claimant has disclosed only the date the notice was generated. The Claimant has also provided no explanation as to how my new address appears on correspondence dated 31 May 2024 when my DVLA V5C was not updated until 1 June 2024. In the absence of proof that a Notice to Keeper was properly given to me by 6 June 2024, as required by paragraph 9 of Schedule 4 of the Protection of Freedoms Act 2012, the Claimant cannot rely on Schedule 4 to transfer liability to me as registered keeper.

Important drafting notes (not for the WS)

   • Each exhibit is referenced once, at the first logical point
   • No exhibit is over-explained
   • No exhibit is used to argue law
   • The judge can read the document if they want — you just anchor it

[RandG]

Thanks b789

Just looking for some advice. I have put the witness statement together and am waiting to send to the court and DCB Legal. 

The only email address I can find is enquiries.newportgwent.countycourt@justice.gov.uk - do you think that is the correct email if I quote the case number in the Subject. For DCB Legal I presume it's info@dcblegal.co.uk.

Cheers

[b789]

Yes, enquiries.newportgwent.countycourt@justice.gov.uk is the correct email address for the court. Send a single email addressed to both the court and info@dcblegal.co.uk and CC yourself. You quote the claim number in the subject field of the email and just add something in the body to say that this is your WS in claim number: xxxxxxx, New Parking Generation Management Ltd v your name.

Do you want to show it to us here before you submit anything?

[RandG]

Hi b789

Thank you for confirming the email addresses. 

The file is ready to go now. I don't feel the need to share it here as I am happy and confident with what we have produced. I have reviewed your WS, amended based on the preceding discussion, included and referenced the Exhibits, and checked details carefully. 

Should I send at 4pm or just before hand?

[b789]

You can send it just before 4pm. Can you confirm that you have not received the Claimants WS?

[RandG]

I have not received any WS. I checked my spam as well and nothing there.

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Correction - it has just come through. 

Is there anything I should do?