Parkmaven DCB Legal court claim 2025

Coupon-mad

She defends it (not you) using the Template Defence everyone uses daily. Couldn't be easier. 

Gr1pr

You do not defend it, because its nothing to do with you per se, you DID NOT receive the N1SDT claim pack, she did,  it's Parkmaven via DCB Legal using the Money Claim service from the CNBC in Northampton,  so change the thread title to 

Parkmaven DCB Legal court claim 2025 

But you can assist her by both of you following the advice in the 2nd post in the newbies sticky thread in announcements near the top of the forum and also studying and using the advice in the first 2 posts in the defence template thread in announcements 

Everything must be done in her name because she is the defendant ( her government gateway account,  her email,  her details etc, you are her personal assistant,  or P.A , but nothing in your name  )

Post a properly redacted picture of the claim form, after hiding 4 items below, so hide the following 

Name and address 
VRM details 
Claim form reference number 
Password 

Take a picture,  add it to a reply 

Le_Kirk

If you post the date of issue of the claim form, we can give you your deadline for submission of the defence.

StickiPanda

This is her defence draft. Any feedback would be greatly appreciated.

Defence Statement

1. The Claimant’s sparse case lacks specificity and does not comply with CPR 16.4, 16PD3, or 16PD7, failing to “state all facts necessary for the purpose of formulating a complete cause of action.” The added costs/damages are an attempt at double recovery of capped legal fees (already listed in the claim) and are not monies genuinely owed to, or incurred by, this Claimant. The claim also exceeds the Code of Practice (CoP) £100 parking charge (“PC”) maximum. Exaggerated claims for impermissible sums are good reason for the Court to intervene. Whilst the Defendant reserves the right to amend the defence if details of the contract are provided, the Court is invited to strike out the claim using its powers under CPR 3.4.
2. The allegation(s) and heads of cost are vague, and liability is denied for the sum claimed, or at all. At the very least, interest should be disallowed; the delay in bringing proceedings lies with the Claimant. This also makes retrieving material documents/evidence difficult, which is highly prejudicial. The Defendant seeks fixed costs (CPR 27.14) and a finding of unreasonable conduct and further costs (CPR 46.5). The Defendant has little recollection of events, save as set out below, and admits only to being the registered keeper.
3. With regard to the Particulars of Claim in question, two recent persuasive appeal judgments — Civil Enforcement Limited v Chan (Ref. E7GM9W44) and Car Park Management Services Ltd v Akande (Ref. K0DP5J30) — indicate that such POC fail to comply with Civil Procedure Rule 16.4(1)(e) and Practice Direction 16, paragraph 7.5. On 15 August 2023, in Chan, HHJ Murch held that “the particulars of the claim as filed and served did not set out the conduct which amounted to the breach in reliance upon which the claimant would be able to bring a claim for breach of contract.” The same is true in this case, and the Defendant therefore submits that the Court should strike out the extant claim, using its powers pursuant to CPR 3.4. Likewise, in CPMS v Akande (10 May 2024), HHJ Evans held that “Particulars of Claim have to set out the basic facts upon which a party relies in order to prove his or her claim.”
   In the present case, the Claimant has failed to particularise the alleged conduct amounting to a breach. The Claimant’s assertion that the Defendant’s vehicle remained parked on the site for approximately 24 hours is factually incorrect. The Defendant avers that the vehicle made two brief visits on consecutive days solely to access the adjacent petrol station. This demonstrates a clear error in the Claimant’s Automatic Number Plate Recognition (ANPR) system, which has evidently failed to distinguish separate visits — a well-documented issue known as “double dipping.” The Defendant therefore puts the Claimant to strict proof that its ANPR data is accurate, that all entries and exits were properly recorded, and that its evidence complies with the standards and guidance required under the British Parking Association Code of Practice.
4. It is neither admitted nor denied that a term was breached, but to form a contract there must be an offer, acceptance, and valuable consideration — all of which are absent in this case. The Consumer Rights Act 2015 (s.71) mandates a “test of fairness” duty on Courts and sets a high bar for prominence of terms and “consumer notices.” Paying regard to Sch. 2 (examples 6, 10, 14 & 18), as well as s.62 and the duties of fair, open dealing and good faith, the Defendant notes that this Claimant reportedly uses unclear and unfair terms/notices. On the limited information given, this case appears no different. The Claimant is put to strict proof with contemporaneous photographs.
5. DVLA keeper data is only supplied on the basis of prior written landowner authority. The Claimant (an agent) is put to strict proof of their standing to sue and of the terms, scope, and dates of the landowner agreement, including the contract, updates, schedules, and a map of the site boundary set by the landowner (not an unverified Google Maps aerial view).
6. To impose a PC, as well as a breach, there must be: (i) a strong legitimate interest extending beyond compensation for loss, and (ii) adequate notice (prominence) of the PC and any relevant obligation(s), none of which have been demonstrated. This PC is a penalty arising as a result of a concealed pitfall or trap, poor signage, and covert surveillance, thus fully distinguished from ParkingEye v Beavis [2015] UKSC 67.
7. Attention is drawn to (i) paras. 98, 100, 193, and 198 of Beavis (an £85 PC comfortably covered all letter-chain costs and generated a profit shared with the landowner) and also to (ii) the binding judgment in ParkingEye v Somerfield Stores ChD [2011] EWHC 4023 (QB), which remains unaffected by Beavis and stands as the only parking case law that deals with costs abuse. HHJ Hegarty held in paras. 419–428 (High Court, later ratified by the CoA) that “admin costs” inflating a £75 PC (already increased from £37.50) to £135 were disproportionate to the minor cost of an automated letter chain and “would appear to be penal.”
8. The Parking (Code of Practice) Act will curb rogue conduct by operators and their debt-recovery agents (DRAs). The Government recently launched a public consultation considered likely to bring in a ban on DRA fees, which a 2022 Minister called “extorting money from motorists.” They have identified in July 2025 that “profit being made by DRAs is significantly higher than ... by parking operators” and that “the high profits may be indicative of these firms having too much control over the market, thereby indicating that there is a market failure.”
9. Pursuant to Sch. 4 of the Protection of Freedoms Act 2012 (“POFA”), the claim exceeds the maximum sum and is unrecoverable: see Explanatory Note 221 — “The creditor may not make a claim against the keeper ... for more than the amount of the unpaid parking-related charges as they stood when the notice to the driver was issued (para 4(5)).” Late fees (unknown to drivers and not specified on signs) are not “unpaid parking-related charges.” They are the invention of “no win, no fee” DRAs. Even in the (unlikely) event that the Claimant complied with POFA and the CoP, there is no keeper-liability law for DRA fees.
10. This claim is an utter waste of court resources and is indicative of systemic abuse that parking cases now make up a third of all small claims. False fees fuel bulk litigation that has overburdened HMCTS. The most common outcome of defended cases is late discontinuance, making Claimants liable for costs (r.38.6(1)). Whilst this does not “normally” apply to the small claims track (r.38.6(3)), the White Book has this annotation: “Note that the normal rule as to costs does not apply if a claimant in a case allocated to the small claims track serves a notice of discontinuance, although it might be contended that costs should be awarded if a party has behaved unreasonably (r.27.14(2)(dg)).”

1505grandad

"Post a properly redacted picture of the claim form, after hiding 4 items below, so hide the following 

Name and address 
VRM details 
Claim form reference number 
Password 

Take a picture,  add it to a reply "

If you can fulfil the above post request it will be immensely helpful.

StickiPanda

Here are the letters redacted.

StickiPanda

Hope this is helpful

Gr1pr

Issue date was 15th October,  the defendant must complete the AOS online on MCOL ASAP,  to extend the defence deadline to November 

The deadline will then be 4pm on November 17th for submission on MCOL 

1505grandad

1505grandad said:

"Post a properly redacted picture of the claim form, after hiding 4 items below, so hide the following 

Name and address 
VRM details 
Claim form reference number 
Password 

Take a picture,  add it to a reply "

If you can fulfil the above post request it will be immensely helpful.

You have left the password in the highlighted "Important Note" box.

Can you state who signed the claim form  -  probably on the back at the top?

Le_Kirk

With an issue date of 15/10/25 and providing you complete(d) the AoS after 20/10/25 and before 03/11/25 your defence deadline date is 4.00 p.m. on 17/11/25