DCB Legal - Court Letter

Jimbojohn

Hi Team,

Thanks for all the information on this forum, its been so helpful sitting down and reading through.

I have received a claim form data 05/06/2025

I acknowledged the claim on the money claim gov.uk site after the 1st 5 days.

I am know preparing to submit my defence (need to send in the next few days) and would like to have some feedback, if possible?

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 doesn’t know who was driving at the time.

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 xx/06/2024, 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 defendant has been provided grainy photographs by the claimants representatives of recognised vehicle entering a location at 19:18, and an unrecognisable vehicle exiting at 21:09 on 06/06/2024, with no further evidence that a breach of prominent terms occurred. The quantum is hugely exaggerated (no PCN can be £170 on private land) and there were no damages incurred whatsoever.

Thanks for your help and advice!

Jimbojohn

I've made a tweak to section 3

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 06/06/2024, 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.

(i) The defendant has been provided grainy photographs of recognised vehicle entering a location at 19:18, and an unrecognisable vehicle exiting at 21:09 on 06/06/2024, with no further evidence that a breach of prominent terms occurred.

Le_Kirk

In view of the sparse POC, I would say you could use Chan & Akande - it's in the Template Defence thread first post.

Coupon-mad

Yes.

You've missed the version that I clearly advise people to use for DCB ParkingEye claims. First post of the Template Defence thread.