MET Parking via DCB Legal claim 2025

Rayson

Coupon-mad said:

Just read the Template Defence thread. Easy!

And show us the claim form again but this time with the usual 4 things redacted that you saw on all the other similar threads we hope you must have read first, before posting.

Hi there thank you very much at first i didn't read properly but i have done so as you guys have told! Here is the attached picture! Thank you so much

Le_Kirk

With an issue date of 30/09/25 and providing you complete the AoS after 05/10/25 and before 19/10/25

your defence deadline date is 4.00 p.m. on 03/11/25

Rayson

Le_Kirk said:

With an issue date of 30/09/25 and providing you complete the AoS after 05/10/25 and before 19/10/25

your defence deadline date is 4.00 p.m. on 03/11/25

Great thank you! I have reviewed the defence template and I still have time before the deadline. Since this happened a year ago, I don’t remember everything, but what I do recall is that it was late at night.

Gr1pr

Stick to the template defence,  save any details for your Witness statement plus Exhibits stage next year

Rayson

Gr1pr said:

Stick to the template defence,  save any details for your Witness statement plus Exhibits stage next year

Hi may i share defence here please? 

1. The Particulars of Claim are sparse and fail to comply with CPR 16.4, PD16 paras 3 and 7. They do not “state all facts necessary for the purpose of formulating a complete cause of action”. The Claimant’s case lacks specificity, is embarrassing, and prejudices the Defendant’s ability to respond. The court is invited to strike out the claim under CPR 3.4.

2. The Defendant denies liability for the sum claimed, or at all. The added costs/damages are an attempt at double recovery of capped legal fees and are not genuine losses.

3. The Defendant has little recollection of events given the passage of time (over a year ago) but recalls that signage at the site is misleading and poorly visible, particularly in dark conditions. The Defendant was unable to read or understand the terms. No contract can be formed where the terms are not sufficiently prominent or clear.

4. The Consumer Rights Act 2015, sections 62 and 71, requires a test of fairness and transparency for consumer notices. The signage used by this Claimant fails that test. The Claimant is put to strict proof, including contemporaneous photographs showing the visibility and content of the signs.

5. The Claimant is put to strict proof of their legal standing to issue and pursue charges. DVLA keeper data is only provided to parking firms with prior written landowner authority. The Claimant is required to produce the landowner contract showing the scope, dates and boundaries of their authority.

6. This case is fully distinguished from ParkingEye v Beavis [2015] UKSC 67, which relied on clear, prominent signage and a legitimate interest. Here, the terms were unclear, misleading, and caused drivers (including many others at this site) to be unfairly ticketed. The Claimant has shown no legitimate interest beyond revenue generation.

7. Pursuant to Schedule 4, paragraph 4(5) of the Protection of Freedoms Act 2012, the Claimant cannot recover more than the original parking charge as stated on the notice. Additional “debt recovery” or “admin” fees are unrecoverable and amount to double recovery.

8. The Defendant also invites the court to consider that this claim exemplifies the systemic abuse of the small claims track by parking firms and their solicitors. The court is asked to find that the Claimant has acted unreasonably and to award the Defendant’s costs under CPR 27.14(2)(g).

Coupon-mad

The claim also exceeds the DLUHC’s statutory Code of Practice £100 maximum parking charge.

There is no such thing and no such department!

Don't change the template defence, except for adding your own para 3 and you can remove paras 9 & 10 and replace those with the Mazur paragraphs seen in other defences. e.g. see the recent Bay Sentry thread.

No link. Your search is as good as mine!

Rayson

Coupon-mad said:

The claim also exceeds the DLUHC’s statutory Code of Practice £100 maximum parking charge.

There is no such thing and no such department!

Don't change the template defence, except for adding your own para 3 and you can remove paras 9 & 10 and replace those with the Mazur paragraphs seen in other defences. e.g. see the recent Bay Sentry thread.

No link. Your search is as good as mine!

I have sent off my AOS now will do more research on the defence i have copy pasted all from 1 to 8 and removed 9 and 10 as you mentioned which i switched with mazur paragraph from the other threads as for my 3rd paragraph it is the same as what i wrote down is that okay?

Coupon-mad

Yes but you could add other wording you find when you search for

unauthorised parking defendant prohibitive

or

unauthorised parking defendant forbidding