UKPC via DCB Legal (4 PCNS)

11A11S

Hello everyone,

Have received the claim form from DCB Legal acting on behalf of UK Parking Control. I have submitted my "the Acknowledgement of Service". Now time has come to send my defence. As I have not received any letter from the claimant prior to the "Claim form", is there anything I should add?

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 04/12/2024, 05/12/2024, 13/12/2024, 16/12/2024  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 quantum is hugely exaggerated (no PCN can be £170 on private land) and there were no damages incurred whatsoever.

3.1 Due to the length of time, the Defendant has no recollection of the day in question. The Defendant was unaware of parking restrictions in place. The Defendant had not noticed any ‘Prominent’ signage close to where the vehicle was parked, showing the terms and conditions for use. The small signage was not suitable to alert a motorist, leading to an unawareness of any parking restrictions.

3.2 Prior to the claim form, no other correspondence has been received.

To make sure I am following the right steps, should I send these paragraphs with all the rest of the defence paragraphs to the ClaimResponses.CNBC@justice.gov.uk, adding the claim number in the title?

Gr1pr

Can't see the issue date from the top right of the claim form 

The password is unredacted on the lower right of the claim form 

Ukpc via DCB Legal,  4 pcns 

Yes you will slot them into the defence template thread replacing the original ones,  when approved 

Yes it will be emailed to claim.responses,  eventually 

Cant see a paragraph 2 with a suitable ending

3.1 contradicts itself,  no recollection followed by discussion of the case 

The defence does not rebut the allegation of parking, because no parking on red lines cannot form a parking contract,  no contract was offered,  it's a forbidden action 

3,2 is no defence,  usually its because the keeper has moved and failed to update the dvla with the new details,  a legal requirement,  not their problem,  even if the letters went to an old address provided by the dvla

11A11S

29.05.2025 ISSUE DATE.
15.06.2025 THE ACKNOWLEDGEMENT OF SERVICE.

Is there any way to remove/edit my comment with a picture to remove the password?

"Ukpc via DCB Legal,  4 pcns 
Yes you will slot them into the defence template thread replacing the original ones,  when approved"

Not sure what you meant by this?

PARAGRAPH 2:

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 and driver.

"3.1 contradicts itself,  no recollection followed by discussion of the case 
The defence does not rebut the allegation of parking, because no parking on red lines cannot form a parking contract,  no contract was offered,  it's a forbidden action "

Suggesting to remove the paragraph at all, as the defence is invalid?

3,2 is no defence,  usually its because the keeper has moved and failed to update the dvla with the new details,  a legal requirement,  not their problem,  even if the letters went to an old address provided by the dvla

Have been at this address for a long time, however, have not received any correspondence before the claim form. 

Gr1pr

As a newbie,  you would have to report the post and ask the admins to delete the picture,  then you

can properly redact the form with a minimum of 4 crucial redactions , not less

I mean that you will remove the template paragraphs 2 & 3, then you will slot in your numbered adapted paragraphs,  so will replace the ones in the template with your own paragraphs which we have approved once finalised 

I am suggesting that you adapt it to rebut the POC 

I know for a fact that the parking company have an electronic link to the dvla database,  they pay for the Registered Keeper details and they post more than one letter to that address,  plus so do the debt collectors as well,  before tracing the new or actual address,  so they all went somewhere,  and they only have to show that they sent them to the address obtained from the dvla database,  regardless of if they were received or not 

The 4 pcns were issued 6 months ago,  so either your post is haywire, times 4, or times 8 with the 4 reminders, or your V5c log book details are incorrect   (  it's happened before,  so check   )

Not receiving paperwork is no defence 

I wont word it for you, that is your job as the defendant,  we provide feedback 

I have no idea if it wants removing or if it's invalid or not,  the aim is to get the defendant to think about it and to improve it such that it's ready to go