DCB Legal - G24 Ltd - Defence Assistance required Please

e11even

Hi all,

Today I received a County Court Claim Form issued by the Civil National Business Centre on behalf of DCB Legal, acting for G24 Limited. They are now claiming £332.84 (up from an original £170) for a PCN allegedly issued in 2019.

Claim Details:

• Issue Date: 24 April 2025

• Claimant: G24 Ltd

• Legal Rep: DCB Legal

• Acknowledgement of Service (AoS): Submitted via MCOL on 01/05/2025

• Current Status: Nothing else done on MCOL — treating it as read-only

I’m now in the process of drafting my defence, which I aim to submit next week. I've based it on the forum’s template and tailored the facts accordingly.

The core of my defence is that I was not the driver at the time, although I was the registered keeper. The location is a residents-only car park, and at the time of the alleged incident, I was a resident with a valid permit. I no longer have the physical permit as it was returned when I moved out, but I do have a tenancy agreement covering that period.

Paragraph 3 of My Defence (Draft):

1. Referring to the Particulars of Claim: Paragraph 1 is denied. The Defendant is not indebted to the Claimant. Paragraph 2 is denied — no PCN was "issued on 27/11/2019" as alleged. While the Defendant was the registered keeper, Paragraphs 3 and 4 are denied. Paragraph 3 refers to “Unauthorised Parking At” — a vague and insufficient basis for a claim. The Defendant is not liable and has seen no evidence of any breach of clear or prominent terms. The claimed amount is grossly exaggerated — a private land PCN cannot lawfully reach £170, and no damages were incurred. The car park was for residents only, and the Defendant was a resident with a valid permit at the time. The Claimant is put to strict proof of all allegations.

I would greatly appreciate any feedback on whether I’ve redacted too much or too little, and if there’s anything critical I might have missed or need to adjust.

Many thanks in advance for your support and guidance!

e11even

Wondering if ChatGpt did a better job below? 

DEFENCE

 

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 sparse and boilerplate 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. The POC fail to comply with CPR 16.4, PD16 paras 7.3 to 7.5, and CPR 22. The Claimant has not provided the required concise statement of facts, nor any evidence of a cause of action. It is denied that the Defendant entered into any contractual agreement with the Claimant.

 

3. Referring to the POC: paragraph 1 is denied. The Defendant is not indebted to the Claimant. Paragraph 2 is denied. No PCN was "issued on 27/11/2019" (the date of the alleged contravention). While the Defendant was the registered keeper of the vehicle, the Defendant was not the driver at the time. Paragraphs 3 and 4 are also denied. Paragraph 3 merely states “Unauthorised Parking At” — a vague, insufficient, and unsubstantiated allegation.

 

The Defendant is not liable and has seen no evidence of a breach of any clearly displayed or prominent terms. The amount claimed is grossly inflated — a private land PCN cannot lawfully amount to £170 — and no damages were incurred. The car park in question is a **residents-only** car park, and at the time, the Defendant was a **resident with a valid parking permit**. The Defendant has a tenancy agreement as proof of residency. The Claimant is put to strict proof of all their allegations and the existence of any lawful authority to override a resident’s right to park.

 

4. The signage in the car park was unclear, not prominently placed, and did not meet the strict requirements of the British Parking Association (BPA) Code of Practice. There was no clear offer or contract capable of binding the driver. The Claimant is put to strict proof of the signage terms and locations in place on the date in question.

 

5. The Claimant is also put to strict proof that the alleged contract (if any) complied with the Protection of Freedoms Act 2012 (Schedule 4) if they are attempting to rely on 'keeper liability'. The Defendant asserts that the requirements of POFA were not met, including failure to deliver a Notice to Keeper within the prescribed time limits and failure to state explicitly the required wording.

 

6. The Claimant will concede that no financial loss has arisen and that, in order to justify an inflated parking charge, as well as proving a term was breached, they must demonstrate:

 

(i) a 'legitimate interest' extending beyond mere compensation for loss, and 

(ii) 'adequate notice' of the 'penalty' charge as established in the ParkingEye Ltd v Beavis [2015] UKSC 67 case.

 

7. The Defendant denies that either (i) or (ii) have been met. The circumstances of this claim are fully distinguished from Beavis. The car park was private land reserved for residents, and the Defendant held the right to park there. No legitimate interest exists for penalising residents for parking in their own spaces with a valid permit. The charge is a penalty, unrecoverable under the penalty rule and unfair under the Consumer Rights Act 2015.

 

8. Furthermore, the Claimant has failed to allow the mandatory grace periods required by the BPA Code of Practice, and no evidence has been provided that any breach occurred, let alone one that warrants a charge of this magnitude.

 

9. The Defendant reserves the right to amend and/or supplement this Defence should the Claimant provide further and better particulars.

 

**Statement of Truth:**

 

The Defendant believes that the facts stated in this Defence are true.

 

Gr1pr

ChatGPT should never be used , it's never better than the forum advice 

The POC does not mention the word issued,  their newer POC last month states Contravention,  so that date is probably correct 

The statement of truth is years out of date, ancient 

Ps, your password and VRM details are on show 

e11even

Thanks @Gr1pr - reg ChatGPT, I am aware I was just curious if it can help with the wording.  

I am not sure what you mean by the POC does not mention the word issued. 

I saw a few posts - and I am using shahib_02 defence as it's pretty simialar case to mine, I only changed phar 3. with my circumstances. 

I was looking for a feedback on the defense is there anything else I should add? 

Gr1pr

Not correct,  the POC was different when shahib drafted their defence 

Read the words carefully,  DCB Legal changed their POC a month ago,  but the Shahib_02 defence was a few months ago 

So study the recent cases from April,  not months ago 

Ps , There is no S in the word Defence either,  use UK English spelling for legal cases

I nearly fell of my sofa when I saw that old pre covid statement of truth  ( definitely not what Shahib_02 used  )

Coupon-mad

Just use the template defence.

You certainly DON'T put in a nine paragraph defence!  I don't understand. Isn't it clear from the template defence that you use all 30 paragraphs? I thought that I spell that out unequivocally?

The core of my defence is that I was not the driver at the time, although I was the registered keeper. 

Why doesn't your draft say that then, as I coach people to say at the end of the template paragraph 2?

And your POC is the new version which uses the words 'date of contravention'
 so you can't copy shahib's line about para 2 of the POC.

ChatGPT is awful. Truly appalling at writing in normal English. Why do people use it for writing? 

e11even

Thank you both for your feedback - I have made the edits you suggested - and used the template only changed para2 of the POC and para3 with my circumstances. 

Please let me know if there is anything else to edit before I submit it? 




Defence draft: (With personal details redacted)


IN THE COUNTY COURT

Claim No.:  *********

Between

G24 Limited 

(Claimant) 

- and -  

XXXXXXX                        

 (Defendant)

_________________

DEFENCE

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, but NOT the driver at the time.

3.     Referring to the POC: paragraph 1 is denied. The Defendant is not indebted to the Claimant. Paragraph 2 is denied. The Defendant does not accept that a contravention occurred on 27/11/2019, as alleged. Whilst the Defendant is the registered keeper, paragraphs 3 and 4 are denied. The Defendant is not liable and has seen no evidence of a breach of prominent terms. The car park in question is a residents-only car park at that time the Defendant was a resident and had a valid permit. The Claimant has provided no evidence of any contravention or that a PCN was lawfully served in accordance with POFA 2012. 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.     The Claimant will concede that no financial loss has arisen and that in order to impose an inflated parking charge, as well as proving a term was breached, there must be:

(i). a strong 'legitimate interest' extending beyond mere compensation for loss, and

(Ii). 'adequate notice' of the 'penalty clause' charge which, in the case of a car park, requires prominent signs and lines.

5.     The Defendant denies (i) or (ii) have been met. The charge imposed, in all the circumstances is a penalty, not saved by ParkingEye Ltd v Beavis [2015] UKSC67 ('the Beavis case'), which is fully distinguished.


Then "Exaggerated Claim and 'market failure' currently being addressed by UK Government" onward has all been used from Coupon-Mads "Template Defense thread". All of it, including the links.

Coupon-mad

Much better but is it true that you weren't driving, given you say "Defendant was a resident and had a valid permit"?