DCB Legal | G21 Claim Form

AxelMoney

Hello all, I have received an unexpected DBC LEGAL LTD claim form, done the acknowledgement of service part last week (7 May).

The alleged contravention took place in 2019 (4 May).  Due to the length of time elapsed I have little to no recollection of the likely overstay at Wickes.   Therefore unsure as to what I can put up as a defence? 

I will post the POC shortly.

After reading a few other threads I note there is a 6 year cut-off to chase PCNs. Will this now have to be defended as it has moved past LBC stage?

Many thanks. 

Gr1pr

The 6 year deadline is the deadline to start proceedings,  which I assume they just managed to do , nothing to do with the ongoing proceedings afterwards 

Post the issue date from the top right of the claim form 

Post a redacted picture of the POC on the lower left of the claim form after hiding the VRM details first 

You will be using the template defence,  with a couple of additions or alterations,  so all 30 paragraphs 

Its G24, not 21, and it's DCB Legal who are dealing with the case 

AxelMoney

Poc Snippet

AxelMoney

Hi, thanks for the quick response.  
The issue date was 24 April '25

Coupon-mad

What a shame you didn't get(?) or didn't respond to the LBC with our standard response for that stage, which would have almost certainly got you past the 6 years.

Too late now for that but it's easy to defend: read half a dozen G24 /DCB Legal claim threads and copy!

AxelMoney

Due to this grasping G24 claim from 6 years ago I am unable to recall with certainty the individual facts of the incident.  Am using the oven ready coupon mad defence template and taking from other recent DCB threads.

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 cannot remember whether they were driving on an unremarkable day six years ago.

3. Referring to the POC: paragraph 1 is denied. The Defendant is not indebted to the Claimant. Paragraph 2 is denied. There is no recollection of a PCN "issued on 04/05/2019" (the date of the alleged visit).  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 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.

3.1 Due to the length of time, the defendant has little to no recollection of the specific date in question, which was an unremarkable day.  While the defendant was the only insured driver for the vehicle in question, it is entirely possible that the vehicle may have been borrowed by another family member.  It would not be reasonable to expect a registered keeper to be able to recall who was or was not driving over five years ago.  In any case, there is no such obligation in law and this was confirmed in the POPLA Annual Report 2015 by parking expert barrister and Lead Adjudicator, Henry Greenslade, who also clarified the fact that registered keeper can only be held liable under the POFA Schedule 4 and not by presumption or any other legal argument.

Coupon-mad

I'd remove 3.1. Not needed.