DCB Legal £9,000 Smart Parking Claim – Need Help Fighting Back

A4BZ

Claim (Removed by Forum Team) issue date 5th August 205 for total £12,587.40

Claim (Removed by Forum Team) issue date 6th May 2026 for total £2204.04

A4BZ

(Images removed by Forum Team)

Hi all,

Thank you again for the replies and help so far.

I have now prepared two draft documents and have attached them for review:

1. Draft witness statement for the earlier/main claim — Claim No. (Removed by Forum Team).
2. Draft Defence for the second claim — Claim No. (Removed by Forum Team).

The second claim Defence is the more urgent document because the defence deadline is likely to be Monday 8 June 2026, so my intention is to file it no later than Sunday 7 June 2026 to avoid cutting it fine.

The draft Defence for the second claim currently includes the following points:

• insufficient / vague Particulars of Claim;
• Henderson v Henderson / abuse of process / improper claim-splitting;
• request that the second claim be struck out or dismissed as an abuse of process;
• same Claimant, same solicitors, same Defendant, same vehicle, same location and same alleged parking scheme as the earlier claim;
• all 9 PCNs in the second claim existed before the first claim was issued on 5 August 2025;
• no admission as driver;
• strict proof of POFA Schedule 4 compliance;
• strict proof of signage and contractual terms;
• strict proof of landowner authority;
• challenge to the £170 per PCN figure / inflated sums;
• Consumer Rights Act 2015 sections 62 and 68, including transparency / fairness of any alleged term allowing additional costs;
• strict proof of interest calculation;
• and DCB’s failure/non-failure to provide documents following the CPR 31.14 request, depending on whether they respond before the defence is filed.

I would be grateful for any thoughts on whether the Henderson / claim-splitting wording is strong enough, and whether the request for strike-out/dismissal is framed correctly.

Separately, following the AOS being filed for Claim No. (Removed by Forum Team) on 18 May 2026, DCB Legal wrote again to the residential address requesting written authority for me to act on (Removed by Forum Team)'s behalf. Their letter is dated 22 May 2026. I assume this relates to the second claim, as the DCB reference differs from the earlier/main claim reference.

I did not simply sign and return the slip without context. Instead, I emailed DCB on 1 June 2026, attaching the Power of Attorney / authority documents and making clear that I am authorised to assist (Removed by Forum Team) because of his incarceration. However, I also made clear that this does not mean DCB should continue sending case correspondence to the residential address.

I explained that DCB and the Court have already been informed numerous times that (Removed by Forum Team) is in custody and that all documents, evidence and correspondence must be sent directly to his custodial address. This has been raised previously in correspondence with DCB, including around October 2025, and again in the March 2026 correspondence with Holly Slater. The Court has also been informed of (Removed by Forum Team)'s custodial address and prison movement position.

The concern is that DCB continuing to send correspondence to the residential address is creating unnecessary procedural difficulty. (Removed by Forum Team) cannot personally receive documents at the flat. He needs documents sent directly to him in custody so that he can properly understand and defend the proceedings himself. I have also informed DCB that (Removed by Forum Team) may be moved between prison establishments again and that any further custodial address will be notified once known.

On the earlier/main claim, Claim No. (Removed by Forum Team), the hearing fee is due by 4 June 2026 and the final hearing is currently listed for 2 July 2026 by CVP at Norwich County Court. A draft witness statement has also been prepared for that claim, but it will need to be amended once/if the Claimant pays the hearing fee and serves its evidence bundle.

In the main-claim witness statement, Henderson / claim-splitting is mentioned only as background conduct and proportionality, not as an invitation for the Court to add the second claim PCNs into the first claim. The wording currently says that (Removed by Forum Team) does not ask the Court at the final hearing of the first claim to add or determine the separate PCNs pleaded in Claim No. (Removed by Forum Team), and that the second claim is raised only as background to the Claimant’s litigation conduct, proportionality and the procedural difficulty caused by fragmented proceedings.

Does that sound like the correct strategic approach — i.e. plead Henderson strongly in the second claim Defence, but keep it as background only in the main claim witness statement?

Any thoughts on the attached second-claim Defence and main-claim witness statement draft would be really appreciated.

Thanks again.

Umkomaas

The Statements of Truth are out of date. Google will find the current SoT to use.

Le_Kirk

The second claim Defence is the more urgent document because the defence deadline is likely to be Monday 8 June 2026, so my intention is to file it no later than Sunday 7 June 2026 to avoid cutting it fine.

Claim (Removed by Forum Team) issue date 6th May 2026 for total £2204.04

With an issue date of 06/05/26 and providing you complete(d) the AoS before or on 25/05/26 your defence deadline date is 4.00 p.m. on 08/06/26

A4BZ

Hi all,

Thank you again for the replies and help so far.

Thank you also for pointing out the statement of truth issue. I have now amended the statement of truth in the second claim Defence so that it includes the current contempt warning wording.

The remaining live claim is Claim No. (Removed by Forum Team). This was issued on 6 May 2026 for £2,204.04 and concerns 9 alleged PCNs involving the same Claimant, same Defendant, same solicitors, same vehicle, same location and same alleged parking scheme.

The Defence for the second claim remains based on:

• vague / insufficient Particulars of Claim;
• Henderson v Henderson / improper claim-splitting;
• request for strike-out / dismissal as abuse of process;
• no admission as driver;
• strict proof of POFA Schedule 4 compliance;
• POFA Schedule 4 paragraph 4(5), namely that if the Defendant is pursued as keeper, the maximum sum recoverable is the amount specified in the Notice to Keeper;
• strict proof of signage / contract;
• strict proof of landowner authority;
• challenge to the £170 per PCN figure;
• ParkingEye v Beavis, distinguishing it on the basis that it concerned the enforceability of a clearly displayed parking charge, not later-added unspecified / duplicated sums;
• CPR 3.4(2)(b), on the basis that inflated / unspecified additional sums may amount to double recovery and/or abuse of process;
• Consumer Rights Act 2015 sections 62 and 68, plus Schedule 2 unfair terms points, in relation to transparency, fairness and any alleged term permitting additional costs;
• Excel Parking Services Ltd v Wilkinson as persuasive, non-binding authority on inflated parking claims / abuse of process;
• strict proof of interest;
• and DCB’s failure/non-failure to provide documents requested under CPR 31.14.

Major update: DCB Legal have now emailed confirming that Smart Parking Limited has instructed them to discontinue the earlier/main claim, Claim No. (Removed by Forum Team), and close their file.

This is the larger claim for £12,587.40, involving 53 alleged PCNs at St Paul’s Centre, Enfield, with alleged contravention dates between 7 December 2020 and 21 June 2022.

The email came from (Removed by Forum Team), Case Manager at DCB Legal. She attached an N279 Notice of Discontinuance, signed by (Removed by Forum Team), who I understand is the COLP at DCB Legal, and stated that it has also been filed with the Court.

That claim had been listed for a CVP hearing on 2 July 2026 at Norwich County Court. Because the hearing is already on (Removed by Forum Team)'ss prison file, I have emailed Norwich County Court and copied CaseProgression.CNBC@justice.gov.uk, attaching DCB’s email and the N279, asking the Court to confirm in writing that the claim is discontinued, the 2 July hearing is vacated, and (Removed by Forum Team) is no longer required to attend by video link. I have specifically asked for written confirmation to be posted to (Removed by Forum Team) at HMP (Removed by Forum Team) so the prison has court-originated confirmation and does not move him unnecessarily between establishments for a hearing that is no longer taking place.

The remaining issue is the second claim, Claim No. (Removed by Forum Team). The alleged contravention dates are between 27 June 2022 and 3 November 2022, so they start only six days after the period covered by the discontinued main claim.

Unless DCB / Smart discontinue the second claim in writing and provide an N279 for Claim No. (Removed by Forum Team), the plan remains to file the Defence by Sunday 7 June 2026, because the deadline is Monday 8 June 2026.

My questions now are:

1. In light of the main claim being discontinued, should the second claim Defence still mention the discontinued earlier claim as the related proceedings for the Henderson / claim-splitting point?
2. Does the discontinuance of the larger earlier claim strengthen the position that the second claim should also be discontinued, or struck out / dismissed as improper claim-splitting / abuse of process?
3. Would it be sensible to email (Removed by Forum Team) at DCB Legal now, asking whether Smart will also discontinue Claim No. (Removed by Forum Team) given that they have discontinued Claim No. (Removed by Forum Team)?

Regardless of whether it is prudent to write to (Removed by Forum Team), I still intend to file the Defence on Sunday 7 June 2026 in readiness for the Monday 8 June 2026 deadline unless a formal Notice of Discontinuance for Claim No. (Removed by Forum Team) is received before then.

Thanks again for all the help — it is genuinely appreciated.

Umkomaas

The email came from (Removed by Forum Team), Case Manager at DCB Legal. She attached an N279 Notice of Discontinuance, signed by (Removed by Forum Team), who I understand is the COLP at DCB Legal, and stated that it has also been filed with the Court.

Would you mind posting a redacted copy of the N279 so I can get this discontinuance counted in the DCB Legal discontinuations thread of shame. This will be the highest value discontinuance since I commenced recording them. Thank you.

Coupon-mad

"Major update: DCB Legal have now emailed confirming that Smart Parking Limited has instructed them to discontinue the earlier/main claim, Claim No. (Removed by Forum Team), and close their file.

This is the larger claim for £12,587.40, involving 53 alleged PCNs at St Paul’s Centre, Enfield, with alleged contravention dates between 7 December 2020 and 21 June 2022."

Wow!

ANOTHER ONE BITES THE DUST!

Biggest value discontinuance we've ever seen! Knew they would. Please show the NoD, so Umkomaas can count it!

Yes, the second claim should still use Henderson v Henderson and should point out they wasted his time and that of his family who had to deal with the paperwork - putting them in fear of bailiffs turning up at the family home that the Claimants wrongly used for service - before a late discontinuance of that first claim. Now, despite knowing that this Defendant is incarcerated and lives and should be served at xxxxxx Prison, this notorious boilerplate 'roboclaim' legal firm has auto-churned out a second claim - also to the family address where they know he can't be reached - and which deals with mirror image subject matter, which will also (no doubt) be discontinued because that's what DCB Legal do with defended Smart Parking claims where defendants stand up to them.

Answers to your questions: three yeses.

Had your partner thought of a counterclaim for this repeated 'roboclaim to the wrong address' course of conduct which has caused him and you immense distress and harassment?

Might be fun. Has to be done at the same time as defending. Might not even cost him a fee if he qualifies for Help With Fees!

Even if he doesn't fancy throwing in an actual counterclaim for a few hundred quid…you could certainly rattle this (Removed by Forum Team)'s cage by telling her he will!

By the way is her email address at DCB Legal or at DCB Ltd? I can't find any record of her because her name matches a B list celeb!

ChirpyChicken

Fantastic news

A weight of both your shoulders

A4BZ

(Images removed by Forum Team)

Hi all,

Please see attached the redacted N279 Notice of Discontinuance for Claim No. (Removed by Forum Team), together with the redacted email from (Removed by Forum Team) removed at DCB Legal that the N279 was attached to.

The email confirms that Smart Parking Limited instructed DCB Legal to discontinue the earlier/main claim and close their file, and that the N279 has also been filed with the Court.

In response to Coupon-mad’s point about Henderson v Henderson, we have kept the Henderson / claim-splitting point in the Defence for the second claim, but framed it carefully. We are not putting it as though there are still two live claims running together, because the first claim has now been discontinued. However, the discontinuance does not take away from the fact that the Claimant originally chose to issue fragmented proceedings.

The second claim still concerns the same Claimant, same solicitors, same Defendant, same vehicle, same location and same alleged parking scheme. The first claim covered alleged contravention dates between 7 December 2020 and 21 June 2022, and the second claim covers alleged contravention dates between 27 June 2022 and 3 November 2022, starting only six days later. All of the 9 alleged PCNs in the second claim already existed before the first claim was issued on 5 August 2025. So our position remains that they could and should have been dealt with together, or at least raised with the Court for proper case management.

We have also linked this to the wider procedural difficulty caused by DCB repeatedly writing to the residential address despite being notified that (Removed by Forum Team) is incarcerated and that documents should be served at his custodial address. The Court managed to correspond with him at the correct custodial address, including the Norwich allocation / video-link order, so there does not seem to be any proper reason why DCB continued sending correspondence to the family home.

For (Removed by Forum Team), her email address appears in the redacted email screenshot attached. She is a Case Manager at DCB Legal.

We have also emailed (Removed by Forum Team) on a “Without Prejudice Save as to Costs” basis, asking whether Smart Parking will also discontinue the second claim, Claim No. N5KF1F68. In summary, we pointed out that:

• the first/main claim has now been discontinued;
• the second claim concerns the same Claimant, same Defendant, same solicitors, same vehicle, same location and same alleged parking scheme;
• the second claim starts only six days after the date range pleaded in the discontinued first claim;
• all 9 alleged PCNs in the second claim existed before the first claim was issued;
• the Defence is ready and will be filed;
• and (Removed by Forum Team) reserves his position regarding any complaint, costs application or other application arising from the repeated use of the wrong address, the fragmented claims and the unnecessary procedural burden caused.

The secondary Defence for Claim No. (Removed by Forum Team) will still be filed on Sunday 7 June 2026 ahead of the Monday 8 June 2026 deadline. It is now practically ready to go.

Thanks again to everyone who has helped. It is genuinely appreciated.

Coupon-mad

Thankyou for that evidence - the biggest DCB Legal claim ever seen discontinued.

ANOTHER SEVERAL PCNs BITE THE DUST!

Calling @Umkomaas