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Money Claim: Draft Defence for G24/DCBL PCN – Advice Needed Please

Hi all,

I’ve received a Money Claim from HMCTS regarding a PCN issued by G24, now pursued through DCB Legal. I am the registered keeper but was not the driver. I completed the AOS and am preparing my defence.

Context:

  • PCN issued: 24th Dec 2024, allegedly exceeded free parking by 35 minutes

  • Two letters from DCBL, then a Letter of Claim from DCB Legal

  • I emailed DCB Legal on POFA compliance with no response

  • Money claim issued 22nd July 2025

I am using the MSE template. Paragraph 2 remains unchanged as it reflects that I was the registered keeper, not the driver. I believe POFA guidelines were followed but can amend if anyone thinks otherwise.

Paragraph 3 (only change from template):

  1. The Particulars of Claim are vague, merely stating “Reason: Unauthorised Parking At” without specifying conduct, terms breached, or how the sum is calculated. In line with Civil Enforcement Ltd v Chan (2023) and CPMS v Akande (2022), such pleadings should be struck out. The Defendant denies any parking charge is owed, was not the driver, and puts the Claimant to strict proof of POFA 2012 compliance, formation of a valid contract by signage, and standing to claim a sum exceeding £100. Liability is denied in full.

I have uploaded images of:

  • Original PCN from G24

  • Letter of Claim from DCB Legal

  • Money Claim Form from HMCTS

  • I can provide images of the two other letters from DCBL following the first PCN if required.

I’d appreciate advice on this draft and my overall approach before submitting via MCOL as this is my first time dealing with something like this.

Thank you so much!


Comments

  • Coupon-mad
    Coupon-mad Posts: 153,063 Forumite
    Part of the Furniture 10,000 Posts Name Dropper Photogenic
    That defence looks fine.

    Please also stick around to do the Public Consultation. It's vital. See the thread about it!
    PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT (except N.Ireland).
    CLICK at the top or bottom of any page where it says:
    Home»Motoring»Parking Tickets Fines & Parking - read the NEWBIES THREAD
  • That defence looks fine.

    Please also stick around to do the Public Consultation. It's vital. See the thread about it!
    Thank you!

    Definitely will.
  • Coupon-mad
    Coupon-mad Posts: 153,063 Forumite
    Part of the Furniture 10,000 Posts Name Dropper Photogenic
    That defence looks fine.

    Please also stick around to do the Public Consultation. It's vital. See the thread about it!
    Thank you!

    Definitely will.
    Great!

    Here's some more info for you and all drivers in your family re completing the Public Consultation if you haven't done it yet.

    See this thread: -

    https://forums.moneysavingexpert.com/discussion/6617396/parking-code-of-practice-consultation-8-weeks-from-11th-july-2025/p1

    We need every poster to come back & complete this vital Consultation before the deadline! Just 2 weeks left but please don't rush it. You can do some then save it and come back to it as you have time.

    And we understand that you may need some pointers.

    I'm taking a closer look this week and we'll walk you through it. I should have all the first post 'how to respond to each question' advice ready by the end of this week.

    There are vital points to safeguard motorists interests to make, that many people won't think of/need focus. There won't be a template - the survey is for you to reply in your words - but we'll help everyone with what to focus on. 

    PRIVATE 'PCN'? DON'T PAY BUT DON'T IGNORE IT (except N.Ireland).
    CLICK at the top or bottom of any page where it says:
    Home»Motoring»Parking Tickets Fines & Parking - read the NEWBIES THREAD
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