DCBL legal court claim pack

Puggles99

Hello everyone, 

firstly I am posting for my own records and to also ask some guidance with my first court claim. 

I have read the sticky thread and will refer to the defence template but ask for some advice on any customisation that should be done - I am slightly autistic and any guidance will make me feel more comfortable in this challenge. 

The PCN arrived by post around 8 months before claim arrived - driver had paid for a set time in the evening, displayed the ticket clearly and returned after the paid period unknowingly, no illuminated signs etc and just paid out of respect. 

The PCN arrived with pictures from a camera and the driver cannot remember whether or not the registration was entered or not. Possibly 30-40 minutes later than paid for/left around 10:30pm ish and is a very small 20 bay car park. 

Is there any suggested way to defend this, the driver did not plan to overstay. 

No longer own the vehicle and all letters regarding these PCN where left in the vehicle when selling it accidentally so not much to refer to. 

Any advice is greatly appreciated, or is it as simple as a direct copy paste of the defence template? 

I have around 8 days for to respond. 

Please let me know if you wish to see the claim form and what to include/grey out.

thank you very much
puggles99

Nellymoser

Post the Claim form after covering
• Your name and address
• Car reg (shown in the Particular of Claim)
• Claim No
• Password (shown in Important Note)

Did you do the AOS?

Puggles99

Nellymoser said:

Post the Claim form after covering
• Your name and address
• Car reg (shown in the Particular of Claim)
• Claim No
• Password (shown in Important Note)

Did you do the AOS?

Hi Nellymoser, 

thank you for your reply, I have attached the claim form for you.

AOS is being posted out today

Gr1pr

Do not post the AOS,  if possible login to MCOL after 5pm today and complete it online,  for free 

Use the defence template,  which is mainly copy it, adapt paragraphs 2 & 3 to suit Your own case 

Once complete,  all of the template is used,  saved as a pdf document 

Attach the completed pdf document to an email,  with the claim reference etc, sending it to the claim responses email address as shown in the defence template thread and in the newbies sticky thread post 2

You do not have to use any paperwork 

Puggles99

Gr1pr said:

Do not post the AOS,  if possible login to MCOL after 5pm today and complete it online,  for free 

Use the defence template,  which is mainly copy it, adapt paragraphs 2 & 3 to suit Your own case 

Once complete,  all of the template is used,  saved as a pdf document 

Attach the completed pdf document to an email,  with the claim reference etc, sending it to the claim responses email address as shown in the defence template thread and in the newbies sticky thread post 2

You do not have to use any paperwork 

Thank you for such clear advice. 

So just to confirm, I have created MCOL and to file AOS after 5PM, and use template and adapt to my needs. 

Could you give me some guidance on a rough idea of what I should/should not put given my situation?

Thank you again!

Gr1pr

Correct 

In paragraph 2 , add a suitable ending to the paragraph,  so if you were the driver,  add and driver 

In paragraph 3, study other recent dcb legal court claim threads from this month only  ( April  2025  )  and look at what their paragraph 3 states, especially if coupon mad approved it , so you may be copying it,  or may be changing the date,  or may be removing a small part of it 

You may decide to write a short concise paragraph 3.1 as well,  based on the circumstances on the date in question,  or not, that may come from somebody else suggesting it 

My point being that most of what you need is already written,  so very few changes,  but to be sure, when you have adapted your 2 or 3 paragraphs, copy and paste below,  for checking by us

Once approved,  replace the paragraphs 2 & 3 in the template with your approved paragraphs,  the rest is unchanged 

You will be adding your details and claim reference number to the start of your draft,  before saving as a pdf and attaching it to your email submission 

Coupon-mad

Puggles99 said:

Gr1pr said:

Do not post the AOS,  if possible login to MCOL after 5pm today and complete it online,  for free 

Use the defence template,  which is mainly copy it, adapt paragraphs 2 & 3 to suit Your own case 

Once complete,  all of the template is used,  saved as a pdf document 

Attach the completed pdf document to an email,  with the claim reference etc, sending it to the claim responses email address as shown in the defence template thread and in the newbies sticky thread post 2

You do not have to use any paperwork 

Thank you for such clear advice. 

So just to confirm, I have created MCOL and to file AOS after 5PM, and use template and adapt to my needs. 

Could you give me some guidance on a rough idea of what I should/should not put given my situation?

Thank you again!

But you aren't doing the defence this week.

AOS online this week. fully shown in walk-through page by page pictures, in a Dropbox link the second post of the NEWBIES thread.

Puggles99

Hello everyone,

I do apologise for the late response - my partner is pregnant and i have had my head elsewhere with worry which is now resolved. (Not an excuse as such but being neurodivergent i have concentrated on the most important matter)

The defense is now drafted and ready to be emailed today - i believe i do not have much time left so would like to post the defense below for checking if you would not mind.

1.  The Defendant denies that the Claimant is entitled to relief in the sum claimed, or at all.  It is denied that any conduct by the driver was in breach of any term.  Further, it is denied that this Claimant (understood to have a bare licence as agents) has standing to sue or form contracts in their own name. Liability is denied, whether or not the Claimant is claiming 'keeper liability', which is unclear from the boilerplate text in the Particulars of Claim ('the POC').

The facts known to the Defendant:

2. The facts in this defence come from the Defendant's own knowledge and honest belief.  Conversely, the Claimant sets out a cut-and-paste incoherent and sparse statement of case. The POC appear to be in breach of CPR 16.4, 16PD3 and 16PD7, and fail to "state all facts necessary for the purpose of formulating a complete cause of action". The Defendant is unable, on the basis of the POC, to understand with certainty what case, allegation(s) and what heads of cost are being pursued, making it difficult to respond. However, the vehicle is recognised and it is admitted that the Defendant was the registered keeper and driver.

3. Referring to the Particulars of Claim: paragraph 1 is denied. The Defendant is not indebted to the Claimant. Paragraph 2 is denied. No PCN(s) was on xx/xx/xxxx. The Defendant is not liable and has seen no evidence of a breach of prominent terms.  The quantum is hugely exaggerated (no PCN can be £170 on private land) and there were no damages incurred whatsoever. The Claimant is put to strict proof of all of their allegations.

4 all unchanged

.

.

30 all unchanged

could you confirm this is the correct way to go ahead?

After my research from recent threads and defenses last month, i feel this is the best adjustment to paragraph 3 and this research has given me a lot of information to learn how this forum works

i did not want to include anything specific as of yet, but my defences if needed are;

That the machine did not function correctly to add more time, arrived late in the evening and it was dark with unclear nor clearly lit signage, creating assumption there was no period to pay for after this point.

I did not receive a PCN attached to vehicle and had sold the car within 2 months of the supposed contravention so may not of received all letters on time (although im sure they posted a few) - i also live in a shared house where post is handled by all members of the household so could be misplaced or lost which has happened before.

Is it worth adding anything from what i have written above? or keep it as it is in the draft above?

I thank you ahead of time for all of the information you have all provided free of charge to all users on this website.

Puggles99

Gr1pr

Paragraph 3, sub section 2 is incorrect,  they changed from ISSUED to CONTRAVENTION a month ago 

Coupon-mad

So put that right by removing "No PCN(s) was on xx/xx/xxxx. "

Puggles99

Coupon-mad said:

So put that right by removing "No PCN(s) was on xx/xx/xxxx. "

this is the updated draft, this is what you mean by removing the above? 

Should I leave everything else untouched? 

Thanks again! 

Referring to the Particulars of Claim: paragraph 1 is denied. The Defendant is not indebted to the Claimant. Paragraph 2 is denied. The Defendant is not liable and has seen no evidence of a breach of prominent terms.  The quantum is hugely exaggerated (no PCN can be £170 on private land) and there were no damages incurred whatsoever. The Claimant is put to strict proof of all of their allegations

Or do you mean for me to update the line “ no PCN can be £170 on private land” to “ no contravention can be £170 on private land”