DCB Legal & First Parking - 2 x university parking court claims 3 weeks apart

Pandemonium78

Hello all,

my defence is due for submission 

My first draft was rubbish and deemed by a trusted relative to be not at all compelling, so I deleted it and have re-drafted as below.  Any feedback will be greatly appreciated (altered slightly again after @Gr1pr comment, sorry).  

It's due by 4pm tomorrow so I will send tonight (sending at this late date as I was waiting for second claim to arrive, but it didn't show).


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 contract 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, allegations(s) and what heads of cost are being pursued, making it difficult to respond.  However, the vehicle is recognised and it is admitted that at the time of the alleged incident the Defendant was the registered keeper and driver.

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 30/10/2024, as alleged.  Whilst the Defendant was the registered keeper at the time of the alleged contravention, 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 £145 on private land) and there were no damages incurred whatsoever.  The Claimant is put to strict proof on all of their allegations.  

i) The vehicle in question was parked displaying a daily parking permit which was  provided to the Defendant by the university/landowner for use in the car park, and it was displayed for the duration in question.  The Defendant, a sessional employee of the university/landowner, was performing duties in the university building adjacent to the car park on the date in question.  The same type of permit had been displayed in the same car park on various dates over a period of months prior to the date in question, and no PCNs issued.  Vehicles displaying permits provided by the university/landowner park in this car park on a daily basis.  It is a known fact that permanent members of staff with yearly permits on display in their vehicles also received multiple PCNs around the date in question, which were subsequently cancelled by the Claimant.   

ii) There was not any ‘prominent’ signage close to where the vehicle was parked or at the exit of the car park leading to the university building at all, let alone showing terms and conditions stating that university/landowner provided permits are invalid. 

iii) The PCN was appealed with the Claimant, who rejected the appeal stating “the opportunity to appeal has now passed”.  The university/landowner also contacted the Claimant to request the PCN be cancelled and was told there is nothing that can be done, for the same reason.    

Followed by the rest of the points up to 30.

Thank you kindly in advance

Gr1pr

Looks good to me 

Pandemonium78

Thank you.  I altered it slightly again, mostly in point 3 (i).  Due tomorrow, so will aim to email it tonight.

Le_Kirk

Make sure you receive the Auto-reply and even though they state they will deal with it in 10 days, they won't but don't panic.  As long as you have the reply, keep checking your status on MCOL to see when they have logged your defence.

Pandemonium78

Got the auto-reply.  

It states:

"When sending us documents please ensure you comply with the Practice Direction 5B

 https://www.justice.gov.uk/courts/procedure-rules/civil/rules/part05/pd_part05b

 Documents not complying will not be accepted, in particular if it is over 10MB or 25 printed pages in size."

So I sent it again including my name/phone number/contact email, just in case.  Don't want to give these cretins the slightest reason to cause me any more stress.  I'll keep checking MCOL from in about 10 days time.

Pandemonium78

QUESTION: Should I start new thread for a new claim or keep both in this thread?  Both DCB Legal.

Issue date for second claim is 31 JUL 2025 (received in post on 05 AUG 2025).

I know to add "cause of action estoppel" to defence for second PCN (issued 3 weeks after the first one).

MCOL have still not logged the defence for the first claim which was submitted 01 JUL 2025.

Coupon-mad

By the way the Template defence has changed and we also no longer email it.

If it is the same parking firm and same POC / same location, keep them both on this thread and change the thread title to:

DCB Legal & First Parking - Two university court claims a month apart

Gr1pr

Pandemonium78 said:

MCOL have still not logged the defence for the first claim which was submitted 01 JUL 2025.

Then email the defence again to the claim.responses address,  heading it URGENT UNPROCESSED DOCUMENTS and add the claim reference number to it as well,  plus add receipt proof of the email auto response too, from 01 July 

Should have been logged last month   !

Pandemonium78

@Gr1pr - done!  

Have now emailed Claimresponses.cnbc@justice.gov.uk again as advised with screenshot of auto reply and defence document attached. 

Pandemonium78

@Coupon-mad

Where can I find most up to date Template defence please?

If we no longer email it to Claimresponses.cnbc@justice.gov.uk, what do we do instead?