DCB Legal claim on behalf of G24

cunners

Hi all,

First thankyou for the help provided on these forums for everyone fighting against these claims.

I have (hopefully) followed the newbies thread up until now, in that I now have a claim lodged against me after I ignored all the threatening letters. I have acknowledged service on MCOL and am now drafting my defence using the template on here.

My defence is that I used said car park after the land was sold and wasn't aware that it was now chargeable (or sold). I believe sufficient notice is meant to be allowed for customers to adjust to new parking charges and a grace period of 4 months should exist with extra signage (BPA code of conduct clause 3.4). I use the car park once a year on Remembrance Sunday to park on the outskirts of my home town. This car park is on council premises (council office block) which has always been free on Sundays, but unbeknownst to me it was sold just before November last year and became chargeable, even on Sundays.

My question is, how do I word this in my own paragraph 3 of my defence to put the onus on them to prove they applied the temporary notices of a grace period for new charges for 4 months, which I don't believe they did?

Any help appreciated.

Gr1pr

You dont tell stories in a defence,  you defend against the POC 

Your story, if it happens,  comes at the WS stage next year,  because you are the first person witness as well as the defendant and your statement as a witness is required at the WS stage 

Post the Issue date from the top right of the claim form below and also post a redacted picture of the POC from the lower left of the claim form below after hiding the VRM details first 

cunners

This is what I have art the moment, is this suitable?

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 to 

admit that they were the registered keeper.

3. Under the British Parking Association Code of Practice v1.1, a 

grace period of 4 months and extra, temporary signage should exist 

where there is any material change to any pre-existing terms and 

conditions that would not be immediately apparent to a driver 

entering controlled land that is or has been open for public 

parking. The Claimant is put to strict proof with contemporaneous 

photographs.

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 (absent in this case). The Consumer Rights 

Act 2015 (s71) mandates a 'test of fairness' duty on Courts and 

sets a high bar for prominence of terms and 'consumer notices'. 

Paying regard to Sch2 (examples 6, 10, 14 & 18), also s62 and the 

duties of fair, open dealing/good faith, the Defendant notes that 

this Claimant reportedly uses unclear (unfair) terms/notices. On 

the limited information given, this case looks 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 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 signs and covert surveillance, thus it is fully 

distinguished from ParkingEye v Beavis [2015] UKSC67.

7. Attention is drawn to (i) paras 98, 100, 193, 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: 'profit 

being made by DRAs is significantly higher than ... by parking 

operators' and '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 Sch4 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, 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 the POFA and CoP, there is 

no keeper liability law for DRA fees.

10. This claim is an utter waste of court resources and it is an 

indication 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))'.

cunners

Gr1pr said:

You dont tell stories in a defence,  you defend against the POC 

Your story, if it happens,  comes at the WS stage next year,  because you are the first person witness as well as the defendant and your statement as a witness is required at the WS stage 

Post the Issue date from the top right of the claim form below and also post a redacted picture of the POC from the lower left of the claim form below after hiding the VRM details first 

Thankyou, I just wanted to provide some context for anyone that may be able to help on the wording of the defence.

The Issue date is 31 July. 

Here is the particulars:

Gr1pr

Have you completed your AOS online on MCOL and when was it done  ? ( you never gave the date  ) 

If its not been done, check your MCOL claim history in case they pulled the trigger 

cunners

Gr1pr said:

Have you completed your AOS online on MCOL and when was it done   ?

If its not been done, check your MCOL claim history in case they pulled the trigger 

I did my AOS online on MCOL 06/08/25

Coupon-mad

OK! Your defence looks fine except that G24 aren't in the BPA AOS. They are in the IPC.

And please take an hour out to do this on or before 5th September (end of next week). PLEASE do the government's Public Consultation while you can:

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

We understand that you may need some pointers. It looks laborious but you can call their worst conduct out with little preparation needed and you'll protect millions of motorists and help change the law.

I've written some guidance on that thread. Respond with your opinion and experience if the dodgy debt crawlers.

Ordinary people like you are falling victim to this scam 15 million times per annum. Motorists need your voice added please!

cunners

Coupon-mad said:

OK! Your defence looks fine except that G24 aren't in the BPA AOS. They are in the IPC.

And please take an hour out to do this on or before 5th September (end of next week). PLEASE do the government's Public Consultation while you can:

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

We understand that you may need some pointers. It looks laborious but you can call their worst conduct out with little preparation needed and you'll protect millions of motorists and help change the law.

I've written some guidance on that thread. Respond with your opinion and experience if the dodgy debt crawlers.

Ordinary people like you are falling victim to this scam 15 million times per annum. Motorists need your voice added please!

Ok Thankyou. The DCB Legal letters show they are members of BPA but the G24 letters do indeed say IPC. Nice and confusing then. I've changed it to IPC as they have a similar clause but no specific timeframe. With that change is it ok to submit as is?

I will fill in the public consultation too, thanks.

cunners

3. Under the International Parking Community Code of Practice v7

Schedule 1, a grace period of 'appropriate' length and extra,

temporary signage should exist where there is any material change

to any pre-existing terms and conditions that would not be

immediately apparent to a driver entering controlled land that is

or has been open for public parking. The Claimant is put to strict

proof with contemporaneous photographs.

Gr1pr

cunners said:

Coupon-mad said:

OK! Your defence looks fine except that G24 aren't in the BPA AOS. They are in the IPC.

And please take an hour out to do this on or before 5th September (end of next week). PLEASE do the government's Public Consultation while you can:

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

We understand that you may need some pointers. It looks laborious but you can call their worst conduct out with little preparation needed and you'll protect millions of motorists and help change the law.

I've written some guidance on that thread. Respond with your opinion and experience if the dodgy debt crawlers.

Ordinary people like you are falling victim to this scam 15 million times per annum. Motorists need your voice added please!

Ok Thankyou. The DCB Legal letters show they are members of BPA but the G24 letters do indeed say IPC. Nice and confusing then. I've changed it to IPC as they have a similar clause but no specific timeframe. With that change is it ok to submit as is?

I will fill in the public consultation too, thanks.

They probably are members of the BPA,  corporate members,  most parking companies are, but what really matters is the AOS list,  different section,  different logos 

So like coupon mad said, they are NOT in the BPA AOS list 

The current joint code of practice applies to both

Coupon-mad

Gr1pr said:

The current joint code of practice applies to both

Yep. And an event occurring in late 2024 doesn't fall under the IPC CoP version 7.