UKPC , DCB LEGAL court claim

jrc123

The date when i got that documents have to be sent is on the second page a 1/4 of the way down - can you check yours and let me know?

Are you starting to write a witness statment?

Is your ticket based on the same thing parked outside the white lne?

K_S

This is the only reference (No.6) to a deadline (other than the fee payment and hearing date) in my NoA.

My plan was to only submit a WS if an NoD didn't come through by end October as I figured that still gives me more than a week to do so.

My original "offence" was indeed parked outside markings.

Gr1pr

Each NOA will give 3 deadlines, not necessarily the same as each other, courts do differ

As for WS , there are NO TEMPLATE witness statements , just examples like from JackR1 , poshmosh , hondawonda, Cappy182 and other victims

jrc123

interesting we have different styles of papers recieved! Noted on that @Gr1pr thanks for the input.

i guess i will have to start writing my witness statement, going to use my friend Claude for the first draft this evening and will post it here in due course.

Any points surrounding parking outside a white line which would be useful for me to have a look at or include?

thanks all

Gr1pr

Study other cases from this year

Study the WS stage advice in the newbies sticky thread in announcements near the top of the forum too

But you may not find those specifics in any

As for courts, they each set their own timetables, so it would be foolish to rely on somebody else's NOA, only the one sent by the local court to the actual defendant should matter

K_S

Thanks @Gr1pr , it's good to know that WS deadlines can differ across courts! I was getting worried I'd missed something after coming this far in the process 😂

jrc123

So i have started on my Witness Statement with the help of my friend Claude. The main arguements I am relying upon are:

Summary of my main arguments (UKPC / DCB Legal, “not parked correctly within the markings of the bay”)

1. I wasn’t the driver. I’m the registered keeper and was a passenger. The claim pursues me first “as the driver”, which is wrong. I’m declining to name the driver. If they rely on POFA keeper liability instead, I’m putting them to strict proof. POPLA did find their Notice to Keeper compliant, so I’m not relying on POFA failures.
2. The £70 add‑on isn’t owed. The sign and the Notice to Keeper say £100, and the NtK shows “Additional Charges £0.00”. The claim is for £170 described as “the PC and damages”, plus £50 legal costs on top. I’m arguing it’s double recovery (Beavis paras 98, 100, 193, 198; HHJ Moloney para 3.4), above the POFA Sch 4 para 4(5) keeper cap, and penal (Somerfield; Excel v Wilkinson).
3. The sign’s wording doesn’t match the allegation. The sign says “Park only within marked bays”. The car was across two marked bays, not outside them. The PCN alleges something stricter, “not parked correctly within the markings of the bay”. Ambiguous terms go in the consumer’s favour (CRA 2015 s.69).
4. The term wasn’t prominent. The bay rule is one of six small boxes on the sign, under “Customers Only” and “Maximum stay 4 hours”. The entrance sign doesn’t mention bays. UKPC’s only entrance sign photo is from April 2023, two years before the event.
5. Mitigation and no legitimate interest. The car was positioned so a baby could be lifted safely out of a

If it is too honest i can change some stats too

Witness Statement

Names, addresses, the claim number, registration, PCN numbers and the site name have been removed. Items in [bold square brackets] are still to be completed.

IN THE COUNTY COURT AT [XXXX]

Claim No: [XXXX]

UK PARKING CONTROL LIMITED (Claimant) v [DEFENDANT] (Defendant)

WITNESS STATEMENT OF [DEFENDANT]

I, [Defendant], of [address], am the Defendant. I will say as follows:

Introduction

1. The facts in this statement are within my own knowledge, unless I say otherwise. Where they are not, I give the source and I believe them to be true.
2. I refer to exhibits in the bundle attached to this statement, marked [XX]1 to [XX]9. I rely on my Defence.
3. I am a litigant in person with no legal training. I have tried to set out my evidence clearly and honestly.

The vehicle and who was driving

1. I am, and was on 13 April 2025, the registered keeper of a [vehicle] ("the Vehicle").
2. I was not driving the Vehicle on 13 April 2025. I was a passenger. The Particulars of Claim pursue me first "as the driver". That is wrong.
3. I have always dealt with this charge as the registered keeper. My appeal to the Claimant dated 28 April 2025 stated that I disputed the charge "as the keeper of the vehicle". I do not know why the Claimant's appeal record shows "Driver" in its "Relationship To Vehicle" field.
4. I am not under any legal obligation to name the driver, and I respectfully decline to do so.

The visit on 13 April 2025

1. On Sunday 13 April 2025 we visited [a retail park in East London] to look around a few shops. We did not buy anything, so I have no receipts.
2. I have visited the retail park a few times a year for many years without any problem.
3. Our baby was with us. [He/She] was then [X] months old.
4. The baby's car seat was fitted on the driver's side of the car. It is a swivel seat. It rotates and pulls out through the open doorway so the baby can be lifted in and out safely. This needs the door to open wide and leaves extra space beside the car.
5. There were no parent and child bays available to us. Many car parks provide these for exactly this reason.
6. When we arrived, the car park was only about 15 to 20% full. When we left it was about half full. I understand the car park has around 2,000 spaces.
7. When we arrived, the car in the bay on the driver's side was parked close to the line of the bay we used. To open the driver's door wide enough to swivel the car seat out and lift our baby out safely, the Vehicle was positioned across the line between two marked bays. It remained within the marked bays at all times. [Confirm: had that car left by 12:18, when the Claimant's photographs show the bays either side empty? If so, add: "That car appears to have left by the time the Claimant's photographs were taken."]
8. CCTV images supplied by the retail park's Centre Manager (Exhibit [XX]5) show the Vehicle arriving at 12:03 and leaving at 13:04. We were on site for about an hour.
9. The Claimant's photographs of the Vehicle are timed at 12:18. The Centre Manager's CCTV list describes the Vehicle as "parked" at 12:22. I ask the Claimant to explain this difference.
10. No one from the Claimant spoke to us, and no ticket was placed on the Vehicle. The Vehicle caused no obstruction. Large parts of the car park were empty throughout our visit. It is not admitted that any term of parking was breached (see paragraph 19).

The signs

1. I did not see any sign near where the Vehicle was parked. I did not see any sign telling motorists that a £100 charge applied to a car parked over a bay line.
2. The Claimant's own sign (Exhibit [XX]2) is headed "Customers Only" and "Maximum stay 4 hours". "Park only within marked bays" appears in small type in one of six small boxes. The charge itself appears in a line of smaller text. The sign says "Park only within marked bays". The Vehicle was within marked bays throughout: it was across two of them, not outside them. The Claimant's charge alleges something different and stricter, that the Vehicle was "not parked correctly within the markings of the bay".
3. The Claimant's entrance sign says only "Maximum stay 4 hours", "Camera controlled" and "Terms and conditions apply". It says nothing about bay markings.
4. Apart from a single photograph taken at 12:18 looking up at a sign on a tall pole, every photograph of a sign in the Claimant's evidence is date-stamped 6 April 2023, two years before our visit. That includes all three entrance photographs and all fourteen photographs of signs in the car park (examples at Exhibit [XX]2). The Claimant has produced no evidence that those signs were in the same places, or said the same things, on 13 April 2025.
5. Exhibit [XX]8 is a Google Street View image dated October 2024, six months before our visit and during the Claimant's contract. It shows the approach road to the car park. No parking terms are visible on it.
6. On [date] I visited the site and took the photographs at Exhibit [XX]9. The nearest sign to the bay where the Vehicle was parked is about [X] metres / [X] paces away. [Describe what you found at the entrance: whether there is an entrance sign or privacy notice before the cameras, and whether the signs match the Claimant's signage plan at Exhibit [XX]3.]

Attempts to resolve this before court

1. I appealed to the Claimant on 28 April 2025. On 19 May 2025 the Claimant asked for the driver's details. It rejected the appeal on 10 June 2025.
2. I appealed to POPLA on 19 June 2025. POPLA refused the appeal in August 2025.
3. Requests were also made on my behalf to the site's management to cancel the charge:
   1. On 28 April 2025, the Centre Manager replied that any appeal must go to the Claimant.
   2. On 24 June 2025, a complaint was sent to the site's managing agent, which acknowledged it on 25 June 2025.
   3. On 1 July 2025, the managing agent's Contract Director replied that the charge would be upheld after discussion with the Claimant and the freeholder. On 8 July 2025 she said this was the agent's final communication.
   4. On 5 November 2025, the matter was escalated to the agent's Head of Property Management, who passed it to its Risk Management & Compliance Director. On 20 November 2025, the Director replied that the complaint was not upheld.
   5. On 24 November 2025, the agent's compliance team replied that it could not override the decision of the landowner and the Claimant.
   6. Further emails to the agent's senior management received no reply.

How the sum claimed grew from £100 to £266.04

1. The Claimant's Notice to Keeper dated 17 April 2025 (Exhibit [XX]1), which I received a few days later, stated a charge of £100, reduced to £60 if paid within 14 days. Its "Additional Charges" line showed £0.00.
2. From September 2025, letters from ZZPS Limited and then GCTT Certificated Enforcement Agents demanded £170. The ZZPS letter breaks this down as a £100 parking charge plus £70 "administration fees" (Exhibit [XX]6).
3. DCB Legal's Letter of Claim dated 30 December 2025 demanded £170 (Exhibit [XX]7).
4. The claim issued on 12 February 2026 is for £170 described as "the PC and damages", plus £11.04 interest, a £35 court fee and £50 legal representative's costs: £266.04 in total (Exhibit [XX]7).
5. The £70 did not appear on any sign or on the Notice to Keeper. I did not agree to pay it, and I do not believe it is owed. I will explain at the hearing why I say it is not recoverable.

Conclusion

1. I was not the driver. The Vehicle was positioned to allow a young baby to be taken out of a swivel car seat safely, in a car park that was largely empty, during a visit of about an hour. I respectfully ask the Court to dismiss the claim.
2. In the alternative, if the Court finds any sum is due, I ask that it is limited to the £100 stated on the Notice to Keeper, and that the £70 and the interest on it are disallowed.
3. I ask for my costs as set out in my Costs Schedule.

Statement of truth

I believe that the facts stated in this witness statement are true. I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth.

Signed: [Defendant] · Date: [XX]

Exhibit List

Exhibit	Document	Date	Source
[XX]1	Notice to Keeper (2 pages), showing £100 charge and £0.00 additional charges	17 April 2025	Claimant
[XX]2	Claimant's terms sign, and examples of its sign photographs date-stamped 6 April 2023 (one in the car park, one at the entrance)	6 April 2023	Claimant's POPLA evidence pack
[XX]3	Claimant's signage plan for the car park	Undated	Claimant
[XX]4	Redacted landowner contract (5 of 34 pages) and Claimant's rolling-contract terms	7 February 2023	Claimant
[XX]5	Centre Manager's letter and six CCTV stills (12:03 to 13:19)	June 2025	Retail park management
[XX]6	ZZPS and GCTT letters showing £100 plus £70	September to November 2025	Debt collectors
[XX]7	DCB Legal Letter of Claim and the Claim Form	30 December 2025 and 12 February 2026	DCB Legal / Court
[XX]8	Google Street View screenshot of the approach road, showing its capture date	October 2024	Google Maps
[XX]9	My own photographs of the entrance, the signs and the bay

Coupon-mad

You could add this because it is true (I first noticed this twelve years ago when running a private PCN appeals company):

I do not know why the Claimant's appeal record shows "Driver" in its "Relationship To Vehicle" field except to say that there are anecdotal accounts that UKPC's webpage defaults back to 'driver' even after an appellant has selected 'registered keeper' and this is seen to happen if the appellant edits what they are typing in the appeal box lower down on the same page. It seems to reset to the default 'driver' and it is most probable that this glitch must have happened (unbeknown to me) because I did not tick that option.

jrc123

Hi @Coupon-mad its pretty mad i have dealt with you on this forum for like the past 10 years - thanks for still being here!

I will add that point into my WS too.

If you spot anything else do let me know!

jrc123

New update alert!

I received an email today from DCB Legal to discuss a settlement.

I called them up and they said they are willing to settle at £100.

I counter offered with an offer of £10. after waiting on the line for 10 minutes for them to decide they approved it! Bit annoyed i paid them but saves me the time and effort on going to court.

Should i email the court? or what is best to do next?