MET Parking via DCB Legal claim 2025

Gr1pr

Study page 2, which tells you the defendant what to do and gives you both the deadline for the WS, which is when exactly. ? ( seems to be 16th July. )

The 2nd post in the newbies sticky thread in announcements tells you what to do once the second half of the game has kicked off ( which I don't think that you have read yet. )

Coupon-mad

They'll probably discontinue this month to avoid doing a WS but read a few WS examples and post 2 of the NEWBIES thread, where of course this stage is fully covered including a list of recommended exhibits.

Rayson

https://forums.moneysavingexpert.com/discussion/comment/82026915#Comment_82026915

great thanks i will have a look!

Rayson

https://forums.moneysavingexpert.com/discussion/comment/82026915#Comment_82026915

Hi there, I hope you’re all doing well. I’ve read through the witness statement but have some confusion do I send my statement as a file attachment through email, or write it directly in the email? Also, do I send it to both the court and DCB Legal? Dcb legal haven’t sent me anything so far as the date to send this through is in 8 days…

Le_Kirk

Your witness statement is sent as a pdf via email not IN the email. Have you checked the example by @JackR1

Coupon-mad

Obviously you can't make a signed court submission in the body of an email!

But they'll discontinue anyway.

Rayson

https://forums.moneysavingexpert.com/discussion/comment/82062993#Comment_82062993

They havent gotten back or anything should i call the court to see if it is confirmed or not? As witness statement deadline is approaching and dcl legal are silent😅

Coupon-mad

Send yours now, with a costs assessment, to your local court & cc in DCB Legal.

That will prompt DCB Legal to send you a Notice of Discontinuance & that is the document we need to see!

Rayson

https://forums.moneysavingexpert.com/discussion/comment/82067321#Comment_82067321

Thank you all for your help! So i have created my witness statement if you could please review it, apologies it may be long and could waste your time. I will also attach or paste exhibit pictures thanks

I am XXXXXXXX of XXXXXXXXXXXX, and I am the Defendant against whom this claim is made. The facts below are true to the best of my belief and my account has been prepared based upon my own knowledge.
2. In my statement I shall refer to exhibits within the evidence supplied with this statement, referring to page and reference numbers where appropriate. I am a litigant in person with no formal legal training. I have done my best to present my case and evidence clearly and truthfully, and I respectfully ask the court to take this into account. My defence is repeated, and I will say as follows.
FACTS AND SEQUENCE OF EVENTS
3. I confirm that I was the registered keeper and the driver of vehicle XXXXXXX on 12 August 2024.
4. The alleged event took place at Lombardy Retail Park, Hayes, UB3 3EX. This is a large retail park with many units, including Sainsbury’s, Argos, Currys, Next and McDonald’s. The car park is listed as having around 865 spaces (Exhibit 1).
5. The alleged event is now nearly two years ago and I attended at night. I do not have a clear recollection of the exact times I arrived or left, and I do not intend to pretend otherwise. What I can say is that I had no reason to think I was doing anything other than parking normally in an ordinary free retail car park.
6. The Particulars of Claim give the reason for the charge only as “Unauthorised Parking”. They do not say which term of the alleged contract I am supposed to have breached, nor how long the vehicle was there. I am left unable to properly answer a case that has not been set out.
THE SITE HAS TWO DIFFERENT PARKING OPERATORS WITH CONFLICTING TERMS
7. Having researched the site, I have discovered that Lombardy Retail Park does not have one set of parking terms. It has at least two, imposed by two different parking companies, and they contradict each other.
8. Exhibit 2 is the sign at the entrance to Lombardy Retail Park. It is a Euro Car Parks Limited sign. It reads “WELCOME TO LOMBARDY RETAIL PARK — CUSTOMERS ONLY — MAXIMUM STAY 4 HOURS — CAMERAS IN OPERATION AT ALL TIMES”.
9. Exhibit 3 is the sign relied upon by the Claimant. It is a MET Parking Services Limited sign, said to be on behalf of Pizza Hut. It reads “Pizza Hut Customers Only — 2 HOURS MAXIMUM STAY (NO RETURN WITHIN 60 MINUTES)” and requires customers to enter their registration at a reception desk.
10. These are fundamentally different terms, from different companies, on what to a driver appears to be one continuous retail park. One says four hours. The other says two hours, plus a reception requirement that exists nowhere else on the site.
11. Exhibit 4 is a publicly available listing for Lombardy Retail Park, which states that parking is “Free — 2 hours”. That is a third, different statement of the terms.
12. There is no boundary, barrier, gate or marking that tells a driver where the Euro Car Parks land ends and the MET Parking land begins. A driver entering this retail park, seeing the entrance sign, has no way of knowing that they have crossed into a separate car park operated by a different company under stricter terms.
13. This is precisely the sort of concealed pitfall or trap which my defence identified. I put the Claimant to strict proof of the boundary of the land it claims to control, by way of the landowner agreement and a proper site plan, and not an unverified aerial view.
THE SIGN DOES NOT SUPPORT THE SUM CLAIMED
14. The Claimant’s own sign (Exhibit 3) states the parking charge in large red lettering as “£100.00 PARKING CHARGE”.
15. The Claimant claims £170, plus interest and costs.
16. The sign is the contract the Claimant relies upon. It says £100. The Claimant cannot recover a sum greater than the one stated in the very contract it says I entered into. There is nothing on that sign that warns a driver of any additional sum of £70 or of any “debt recovery” or administration charge whatsoever.
17. That additional £70 is not a genuine cost, is not money owed to this Claimant, and duplicates the capped legal costs already claimed on the claim form. It is double recovery.
18. In ParkingEye v Somerfield Stores [2011] EWHC 4023 (QB), HHJ Hegarty held at paragraphs 419 to 428 that administration costs inflating a £75 charge to £135 were disproportionate to the minor cost of an automated letter chain, and would appear to be penal. The same applies here.
19. In July 2025 the Government identified that profits made by debt recovery agents are significantly higher than those made by parking operators themselves, and that this may indicate a market failure. A Minister in 2022 described such fees as extorting money from motorists.
THE SIGNAGE COULD NOT BE READ AT NIGHT
20. I attended at night. As pleaded in my defence, the signage at this site was misleading and poorly visible in the dark, and I was not able to read or understand the terms.
21. The sign at Exhibit 3 is dense. Below the headline, there are several paragraphs of small print setting out the terms and conditions of use. On the photograph in evidence, parts of that small print are not even legible in daylight.
22. The Claimant has produced nothing to show that this sign was illuminated, or that it was legible to a driver at night in August 2024. I put the Claimant to strict proof by way of contemporaneous, dated photographs taken at night, from a driver’s eye level, at the point of entry and at the parking area.
DELAY AND PREJUDICE TO ME
23. The Claimant delayed a long time before bringing these proceedings. That delay is entirely of the Claimant’s own making and it prejudices me directly, because I cannot now go back and photograph the site as it was on the night in question.
24. That prejudice is real and not theoretical. The Pizza Hut at this site has now closed permanently (Exhibit 5). The site today is not the site as it was in August 2024. Any signage the Claimant now produces cannot simply be assumed to be the signage that was in place, in that position, and in that condition, on that night.
NO CONTRACT WAS FORMED
25. For a contract to exist there must be an offer, acceptance and valuable consideration. Terms cannot bind me where they were not sufficiently prominent or clear and where I had no realistic opportunity to read and understand them.
26. Where a site displays three different sets of terms from three different sources, none of them agreeing with each other, no clear offer has been made at all. There was nothing for me to accept.
27. As pleaded in my defence, the Consumer Rights Act 2015 imposes a test of fairness and sets a high bar for the prominence and transparency of terms and consumer notices. Contradictory signage, from different operators, in small print, at night, meets neither the fairness nor the transparency requirement.
28. This charge is distinguished from ParkingEye v Beavis [2015] UKSC 67, where the signage was large, bold, consistent and clearly positioned throughout the site. That is the opposite of the position here.
THE CLAIMANT’S STANDING
29. DVLA keeper data is only released on the basis of prior written landowner authority. The Claimant is put to strict proof of its standing to sue and of the terms, scope and dates of the landowner agreement, including the contract, any updates and schedules, and a map of the site boundary set by the landowner.
30. This is particularly important here, given that a different company (Euro Car Parks) evidently operates parking enforcement at the same retail park.
CONCLUSION AND COSTS
31. The claim is without merit. No contract was formed. No term has been identified. The signage at this site is contradictory and could not be read at night. The sum claimed exceeds the sum stated on the Claimant’s own sign. I ask that the claim be struck out or dismissed.
32. In the matter of costs, I ask:
a) at the very least, for standard witness costs for attendance at court, pursuant to CPR 27.14; and
b) for a finding of unreasonable conduct by this Claimant, with costs pursuant to CPR 46.5.
33. I draw attention to the real possibility of an unreasonably late Notice of Discontinuance. Although the normal rule in CPR 38.6(1) does not usually apply to the small claims track (r.38.6(3)), the White Book notes at 38.6.1 that costs may still be awarded where a party has behaved unreasonably.
STATEMENT OF TRUTH
I believe that the facts stated in this witness statement are true. I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth.
Signed:
Print name: XXXXXXXX
Date:

Rayson

I hope it will be useful, as signage isn’t clear and misleading also my witness statement could have bad points if that's the case please do assist! Thank you