UKPC DCBLegal LoC draft advice

Big_Herc

Hi all,

I have received an LoC from DCB Legal with regards to a parking contravention at a retail park, I responded with the default appeal template which they asked to identify the driver and referred to POPLA but I never pursued that as the response email got lost. The actual contravention was parking over the line as I could see from the the NTK, the car next to my car was over the line and so my car was parked over the next line but it was the last space in the row so was not interfering with another spot. It was Xmas Eves' eve and not 100% sure who was driving myself or my wife as it was a bit manic, probably also had the disabled badge up not that that would make any difference but there you go.

My question is, is it worth mentioning any of this in the LoC response or just follow the standard template?

Anyway go easy on me I have tried to research as much as possible and understand I'm only at the LoC stage but here's my draft response based on the newbies thread:

RE: Letter of Claim – Ref: 

Client: UK Parking Control Ltd
Vehicle Reg: 
Amount claimed: £170.00

Dear Sir/Madam,

I refer to your Letter of Claim dated 14 July 2025.

I confirm that my correct address for service is as stated above. Please ensure that your records are updated accordingly and that any prior address is erased in accordance with data protection legislation.

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Preliminary Observations Regarding the Allegation

Having reviewed the photographs associated with this claim, it appears the vehicle may have been parked slightly over a bay line due to the adjacent vehicle already encroaching into that space. The vehicle in question was parked in the final space at the end of the row and was therefore not impeding the next bay or causing any obstruction to other users.

These observations are made without confirmation as to whether I was the driver at the time, as I cannot recall the incident or who was driving the vehicle on that occasion.

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Dispute of Alleged Debt

The alleged debt is entirely denied. I do not accept any liability for the sum claimed. Should proceedings be issued, I will defend the matter robustly.

I have no recollection of the event in question and was not the driver at the time. Furthermore, I do not believe your client has established any lawful basis to pursue me as the registered keeper, as they have not complied with the strict provisions of Schedule 4 of the Protection of Freedoms Act 2012 (POFA). I also question whether the location in question qualifies as “relevant land” under POFA, and therefore dispute any basis for keeper liability.

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Request for Further Time

I am currently seeking independent legal and debt advice. In accordance with the Pre-Action Protocol for Debt Claims (2017), I formally request that the matter be placed on hold for a minimum of 30 days from the date of your receipt of this letter.

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Unreasonable Additional Charges

Your claim includes an amount of £170.00, which is a significant uplift from the original Parking Charge Notice. I understand that £70.00 of this sum represents a purported “debt recovery” fee, which has been widely criticised – including by the Government – as excessive and unjustified.

Under the Pre-Action Protocol, I am entitled to request clarification on the following points, and I expect full, clear responses:

1. Is the additional £70.00 claimed by your client classified as a “debt recovery” charge?

   • If so, is this amount net or inclusive of VAT?

   • If inclusive, please explain the legal basis on which I am being asked to pay your client’s VAT.

2. Regarding the core £100 charge:

   • Will your client be pleading this sum as liquidated damages for breach of contract, or as consideration for a contractual licence to park?

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Formal Request for Documents

To properly respond to your Letter of Claim, and in compliance with the PAP, I request the following:

• A copy of the original Parking Charge Notice (PCN);

• All photographs taken of the vehicle at the time of the alleged incident;

• A copy of the signage at the location, showing terms and conditions clearly;

• A copy of your client’s contract with the landowner authorising them to issue and enforce PCNs;

• Evidence of POFA compliance, including delivery dates and notice wording;

• A detailed breakdown of the £170.00 claimed;

• A copy of the completed Information Sheet and Reply Form.

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Unless and until these documents are received and the issues above are addressed, no further response will be made. If your client proceeds to issue a claim without complying with the Pre-Action Protocol, I will draw this to the attention of the court and seek costs for unreasonable conduct.

Le_Kirk

Don't tell 'em Pike; there is no law that requires you to inform them of the name of the driver.

Big_Herc

ok thanks for all the help with this.....So a little bit has passed in the interim they filed a claim and I filed a defence and have now received this:

Good Morning

Having reviewed the content of your defence, we write to inform you that our client intends to proceed with the claim.

In due course, the Court will direct both parties to each file a directions questionnaire. In preparation for that, please find attached a copy of the Claimant's, which we confirm has been filed with the Court.

Without Prejudice to the above, in order to assist the Court in achieving its overriding objective, our client may be prepared to settle this case - in the event you wish to discuss settlement, please call us on 0203 434 0433 within 7 days and make immediate reference to this correspondence.

If you have provided an email address within your Defence, we intend to use it for service of documents (usually in PDF format) hereon in pursuant to PD 6A (4.1)(2)(c). Please advise whether there are any limitations to this (for example, the format in which documents are to be sent and the maximum size of attachments that may be received). Unless you advise otherwise, we will assume not.

 

Kind Regards,

Litigation Support

DCB Legal Ltd

so the next step will be directions questionnaire which I guess will be available in the MCOL portal?

Gr1pr

Download the N180 DQ document pdf from the gov website