PCN - Overstay - 22/12/24 @ Southgate Park, Stansted

[CD!]

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)

[b789]

@CD!, did you submit an Acknowledgement of Service (AoS) before 4pm Monday 16th March?

[CD!]

@CD!, did you submit an Acknowledgement of Service (AoS) before 4pm Monday 16th March?

Hi, Yes I logged on to the HM Tribunals Service and completed an acknowledgement of Service on the 04/03/26, indicating I would be contesting the claim.

I believe I have until the end of next week to send my defence (around 28-30th) so am keen to put something together asap and send it back.

Any advice would be appreciated!

Thanks

CD!

[b789]

@CD!, having submitted an AoS before 16 March, you have until 4pm Monday 30 March to submit your defence. Please follow this advice on how to proceed:

Until very recently, I never advised using the MCOL to submit a defence. However, due to recent systemic failures within the CNBC, I feel that it is safer to now submit a short defence using MCOL as it is instantly submitted and entered into the "system". Whilst it will deny the use of some formatting or inclusion of transcripts etc. these can always be included with the Witness Statement (WS) later, if it ever progresses that far.

You will need to copy and paste it into the defence text box on MCOL. It has been checked to make sure that it will fit into the 122 lines limit.

1. The Defendant denies the claim in its entirety. The Defendant asserts that there is no liability to the Claimant and that no debt is owed. The claim is without merit and does not adequately disclose any comprehensible cause of action.

2. There is a lack of precise detail in the Particulars of Claim (PoC) in respect of the factual and legal allegations made against the Defendant such that the PoC do not adequately comply with CPR 16.4.

3. The Defendant is unable to plead properly to the PoC because:

(a) The contract referred to is not detailed or attached to the PoC in accordance with PD 16, para 7.3(1);

(b) The PoC do not state the exact wording of the clause (or clauses) of the terms and conditions of the contract (or contracts) which is/are relied on;

(c) The PoC do not adequately set out the reason (or reasons) why the claimant asserts the defendant has breached the contract (or contracts);

(d) The PoC do not state with sufficient particularity exactly where the breach occurred, the exact time when the breach occurred and how long it is alleged that the vehicle was parked before the parking charge was allegedly incurred;

(e) The PoC do not state precisely how the sum claimed is calculated, including the basis for any statutory interest, damages, or other charges;

(f) The PoC do not state what proportion of the claim is the parking charge and what proportion is damages;

(g) The PoC do not provide clarity on whether the Defendant is sued as the driver or the keeper of the vehicle, as the claimant cannot plead alternative causes of action without specificity. The location is not relevant land for the purposes of PoFA, so there can be no keeper liability.

4. The Defendant submits that courts have previously struck out materially similar claims of their own initiative for failure to adequately comply with CPR 16.4, particularly where the Particulars of Claim failed to specify the contractual terms relied upon or explain the alleged breach with sufficient clarity.

5. In comparable cases involving modest sums, judges have found that requiring further case management steps would be disproportionate and contrary to the overriding objective. Accordingly, strike-out was deemed appropriate. The Defendant submits that the same reasoning applies in this case and invites the court to adopt a similar approach by striking out the claim due to the Claimant’s failure to adequately comply with CPR 16.4, rather than permitting an amendment. The Defendant proposes that the following Order be made:

Draft Order:

Of the Court's own initiative and upon reading the particulars of claim and the defence.

AND the court being of the view that the particulars of claim do not adequately comply with CPR 16.4(1)(a) because: (a) they do not set out the exact wording of the clause (or clauses) of the terms and conditions of the contract which is (or are) relied on; and (b) they do not adequately set out the reason (or reasons) why the claimant asserts that the defendant was in breach of contract.

AND the claimant could have complied with CPR 16.4(1)(a) had it served separate detailed particulars of claim, as it could have done pursuant to PD 7C, para 5.2, but chose not to do so.

AND upon the Court determining, having regard to the overriding objective (CPR 1.1), that it would be disproportionate to direct further pleadings or to allot any further share of the Court’s resources to this claim (for example by ordering further particulars of claim and a further defence, with consequent case management).

ORDER:

1. The claim is struck out.

2. Permission to either party to apply to set aside, vary or stay this order by application on notice, which must be filed at this Court not more than 7 days after service of this order, failing which no such application may be made.

Let me know when you have submitted the defence.

[CD!]

@CD!, having submitted an AoS before 16 March, you have until 4pm Monday 30 March to submit your defence. Please follow this advice on how to proceed:

Until very recently, I never advised using the MCOL to submit a defence. However, due to recent systemic failures within the CNBC, I feel that it is safer to now submit a short defence using MCOL as it is instantly submitted and entered into the "system". Whilst it will deny the use of some formatting or inclusion of transcripts etc. these can always be included with the Witness Statement (WS) later, if it ever progresses that far.

You will need to copy and paste it into the defence text box on MCOL. It has been checked to make sure that it will fit into the 122 lines limit.

1. The Defendant denies the claim in its entirety. The Defendant asserts that there is no liability to the Claimant and that no debt is owed. The claim is without merit and does not adequately disclose any comprehensible cause of action.

2. There is a lack of precise detail in the Particulars of Claim (PoC) in respect of the factual and legal allegations made against the Defendant such that the PoC do not adequately comply with CPR 16.4.

3. The Defendant is unable to plead properly to the PoC because:

(a) The contract referred to is not detailed or attached to the PoC in accordance with PD 16, para 7.3(1);

(b) The PoC do not state the exact wording of the clause (or clauses) of the terms and conditions of the contract (or contracts) which is/are relied on;

(c) The PoC do not adequately set out the reason (or reasons) why the claimant asserts the defendant has breached the contract (or contracts);

(d) The PoC do not state with sufficient particularity exactly where the breach occurred, the exact time when the breach occurred and how long it is alleged that the vehicle was parked before the parking charge was allegedly incurred;

(e) The PoC do not state precisely how the sum claimed is calculated, including the basis for any statutory interest, damages, or other charges;

(f) The PoC do not state what proportion of the claim is the parking charge and what proportion is damages;

(g) The PoC do not provide clarity on whether the Defendant is sued as the driver or the keeper of the vehicle, as the claimant cannot plead alternative causes of action without specificity. The location is not relevant land for the purposes of PoFA, so there can be no keeper liability.

4. The Defendant submits that courts have previously struck out materially similar claims of their own initiative for failure to adequately comply with CPR 16.4, particularly where the Particulars of Claim failed to specify the contractual terms relied upon or explain the alleged breach with sufficient clarity.

5. In comparable cases involving modest sums, judges have found that requiring further case management steps would be disproportionate and contrary to the overriding objective. Accordingly, strike-out was deemed appropriate. The Defendant submits that the same reasoning applies in this case and invites the court to adopt a similar approach by striking out the claim due to the Claimant’s failure to adequately comply with CPR 16.4, rather than permitting an amendment. The Defendant proposes that the following Order be made:

Draft Order:

Of the Court's own initiative and upon reading the particulars of claim and the defence.

AND the court being of the view that the particulars of claim do not adequately comply with CPR 16.4(1)(a) because: (a) they do not set out the exact wording of the clause (or clauses) of the terms and conditions of the contract which is (or are) relied on; and (b) they do not adequately set out the reason (or reasons) why the claimant asserts that the defendant was in breach of contract.

AND the claimant could have complied with CPR 16.4(1)(a) had it served separate detailed particulars of claim, as it could have done pursuant to PD 7C, para 5.2, but chose not to do so.

AND upon the Court determining, having regard to the overriding objective (CPR 1.1), that it would be disproportionate to direct further pleadings or to allot any further share of the Court’s resources to this claim (for example by ordering further particulars of claim and a further defence, with consequent case management).

ORDER:

1. The claim is struck out.

2. Permission to either party to apply to set aside, vary or stay this order by application on notice, which must be filed at this Court not more than 7 days after service of this order, failing which no such application may be made.

Let me know when you have submitted the defence.

b789

Thank you so much! I have just submitted the defence on the MCOL and it stated as it has been submitted before 4pm it should be processed the same day. 
Sounded very professional and knowledgable - certainly something I would not be familiar with, (I guess that's what they prey on!)
Is it a case of now waiting to hear back from the court on their decision & do they usually have a set timeframe to respond?

Without wanting to repeat myself - I really appreciate your help and advice in this matter, it's been quite worry getting to this point and fighting the PCN, but felt I needed to make a stand against them as it was so outrageous and without merit!

CD!

[b789]

@CD!, you will receive a letter from DCB Legal telling you that hater client has reviewed your defence and has decided to proceed. They will include with that a copy of 'their' N180 Directions Questionnaire (DQ). There is nothing for you to with that except to file it.

Keep checking your MCOL history to see when your own N180 has been issued or just wait to receive it in the post. Having received your own N180 (make sure it is not simply a copy of the claimants N180) or been notified on MCOL that yours has been sent, do not use the paper form. Ignore all the other forms that came with it. You can discard those. Download your own N180 DQ here and fill it in on your computer. You sign it by simply typing your full name in the signature box.

https://assets.publishing.service.gov.uk...0_1124.pdf

Here are the answers to some of the less obvious questions:

• The name of the court is "Civil National Business Centre".

• To be completed by "Your full name" and you are the "Defendant".

• C1: "YES"

• D1: "NO". Reason: "I wish to question the Claimant about their evidence at a hearing in person and to expose omissions and any misleading or incorrect evidence or assertions.
Given the Claimant is a firm who complete cut & paste parking case paperwork for a living, having this case heard solely on papers would appear to put the Claimant at an unfair advantage, especially as they would no doubt prefer the Defendant not to have the opportunity to expose the issues in the Claimants template submissions or speak as the only true witness to events in question.."

• F1: Whichever is your nearest county court. Use this to find it: https://www.find-court-tribunal.service....rch-option

• F3: "1".

• Sign the form by simply typing your full name for the signature.

When you have completed the form, attach it to a single email addressed to both dq.cnbc@justice.gov.uk and info@blegal.co.uk and CC in yourself. Make sure that the claim number is in the subject field of the email.

After that, you will receive notice of a telephone appointment for a mediation call. For the mediation call, the only requirement is for you "attend" the call. It is not part of the judicial process and no judge is involved.

This is what I advise you to say when you receive the call from the mediator:

“Before I set out my position, please confirm from the claimant’s side:

• the full name of the person attending for them;
  
• their role/position at their legal representative’s firm; and
  
• whether they hold written authority to negotiate and settle today.[/indent]
  

Please relay that back to me before we continue.”

After the mediator calls back...

If identified and authority confirmed:

   “Thank you. I’m content to proceed on that basis. My settlement offer is £0, or I invite the claimant to discontinue with no order as to costs.”

If no/unclear authority:

   “Please record that the claimant’s attendee has not confirmed settlement authority. My position remains that liability is denied and my offer is £0, subject to prompt approval by an authorised solicitor if they choose to discontinue.”

If the mediator probes your defence:

   ”In what capacity are you asking that question? Are you legally trained?  If not, please refrain from offering opinions. I will be reporting any attempt to do so as inappropriate.”

All you need to know is the name and the position of the person acting for the claimant and report that back to us. It will be over within minutes. It's a complete waste of time but you have to go through the motions. Should take less than 5 minutes.

Once that has been done, the claim will be transferred to your local court and you will receive a Notice of Allocation with a hearing date and a deadline for the claimant to pay the £27 trial fee. It is usually just before that deadline that they discontinue.

Just keep me informed of any correspondence you receive. Ignore all contact with DCB Legal. They will try and call or text you to offer a settlement. Ignore it and they will discontinue.

[CD!]

@CD!, you will receive a letter from DCB Legal telling you that hater client has reviewed your defence and has decided to proceed. They will include with that a copy of 'their' N180 Directions Questionnaire (DQ). There is nothing for you to with that except to file it.

Keep checking your MCOL history to see when your own N180 has been issued or just wait to receive it in the post. Having received your own N180 (make sure it is not simply a copy of the claimants N180) or been notified on MCOL that yours has been sent, do not use the paper form. Ignore all the other forms that came with it. You can discard those. Download your own N180 DQ here and fill it in on your computer. You sign it by simply typing your full name in the signature box.

https://assets.publishing.service.gov.uk...0_1124.pdf

Here are the answers to some of the less obvious questions:

• The name of the court is "Civil National Business Centre".

• To be completed by "Your full name" and you are the "Defendant".

• C1: "YES"

• D1: "NO". Reason: "I wish to question the Claimant about their evidence at a hearing in person and to expose omissions and any misleading or incorrect evidence or assertions.
Given the Claimant is a firm who complete cut & paste parking case paperwork for a living, having this case heard solely on papers would appear to put the Claimant at an unfair advantage, especially as they would no doubt prefer the Defendant not to have the opportunity to expose the issues in the Claimants template submissions or speak as the only true witness to events in question.."

• F1: Whichever is your nearest county court. Use this to find it: https://www.find-court-tribunal.service....rch-option

• F3: "1".

• Sign the form by simply typing your full name for the signature.

When you have completed the form, attach it to a single email addressed to both dq.cnbc@justice.gov.uk and info@blegal.co.uk and CC in yourself. Make sure that the claim number is in the subject field of the email.

After that, you will receive notice of a telephone appointment for a mediation call. For the mediation call, the only requirement is for you "attend" the call. It is not part of the judicial process and no judge is involved.

This is what I advise you to say when you receive the call from the mediator:

“Before I set out my position, please confirm from the claimant’s side:

• the full name of the person attending for them;
  
• their role/position at their legal representative’s firm; and
  
• whether they hold written authority to negotiate and settle today.[/indent]
  

Please relay that back to me before we continue.”

After the mediator calls back...

If identified and authority confirmed:

   “Thank you. I’m content to proceed on that basis. My settlement offer is £0, or I invite the claimant to discontinue with no order as to costs.”

If no/unclear authority:

   “Please record that the claimant’s attendee has not confirmed settlement authority. My position remains that liability is denied and my offer is £0, subject to prompt approval by an authorised solicitor if they choose to discontinue.”

If the mediator probes your defence:

   ”In what capacity are you asking that question? Are you legally trained?  If not, please refrain from offering opinions. I will be reporting any attempt to do so as inappropriate.”

All you need to know is the name and the position of the person acting for the claimant and report that back to us. It will be over within minutes. It's a complete waste of time but you have to go through the motions. Should take less than 5 minutes.

Once that has been done, the claim will be transferred to your local court and you will receive a Notice of Allocation with a hearing date and a deadline for the claimant to pay the £27 trial fee. It is usually just before that deadline that they discontinue.

Just keep me informed of any correspondence you receive. Ignore all contact with DCB Legal. They will try and call or text you to offer a settlement. Ignore it and they will discontinue.

b789

Ok - will wait to hear back from them and follow your steps as you've set out then report back. 

Thanks - have a good weekend CD!