DCB Legal Defence Para 3 November 2025 help

Le_Kirk

The Particulars of Claim are vague and inadequate, failing to disclose sufficient detail of the alleged contravention,

The POC quite clearly state that the breach is unauthorised parking, so that is what your paragraph 3# has to refute.

Rinkydinkpanic

Apologies for slow response, unfortunately had a short hospital stay which has exacerbated my stress over this. I need to finish this today so really hoping I've got there now.

As my last para 3 wasn't correct, I've seen a very recent post which looks good and received the thumbs up from admin. Does this work for my particular charge?

Referring to the Particulars of Claim, paragraph 1 is denied. The Defendant is not indebted to the Claimant. Although the Defendant is the registered keeper, paragraphs 3 and 4 are denied. The Defendant is not liable and has been provided with no evidence of any breach of clear or prominent terms. The Defendant denies the claim in its entirety. Given the passage of more than 3 years and the lack of detail in the inadequate Particulars of Claim, it is impossible for the Defendant to provide a full response. Signage at the material time was unclear and insufficient. The claimed sum is grossly inflated, as no private parking charge can lawfully amount to £170, and no loss or damages were incurred  

Regarding the Particulars of Claim paragraph 4, research has proved that this Claimant has never used the POFA 2012 and has never been able to hold registered keepers liable. The solicitor signatory of the statement of truth on this claim is knowingly or negligently misleading the court by citing that law. Because of the age of the claim and the lack of evidence produced by the Claimant the pleaded breach of unauthorised parking is refuted. 

Accordingly, the Claimant is put to strict proof of: 

• the alleged breach; 

• the contractual terms purportedly relied upon 

• the identity of the driver; and 

• full compliance with Schedule 4 of the Protection of Freedoms Act 2012 (POFA) if the Claimant seeks to transfer liability to the keeper.                                                                                                                              If this looks ok I'll publish full statement incl para 11 for final check if that's ok?

Many thanks again, hoping to destress.

Coupon-mad

Rinkydinkpanic said:

I appealed this charge back in 2022.

I dropped off my partner who had recently suffered an ACL injury and was on crutches. She was collecting medication from a store.  I waited a few minutes in the bay as permitted and then sent her a text to say I was moving from the bay to park elsewhere as drop off bay had restrictions.

I left via the barrier with immediate effect. I parked briefly on the public highway and shortly afterwards she rang me to say she was ready to be collected so I returned via the entry barrier and collected her from the initial drop off point.

When I received the parking fine claim from Smart Parking I submitted the text I sent her as evidence (which was date / time stamped) as proof of my manoeuvres. This was ignored. I heard nothing further until 17/10/25 claimant letter.

Rinkydinkpanic said:

Apologies for slow response, unfortunately had a short hospital stay which has exacerbated my stress over this. I need to finish this today so really hoping I've got there now.

As my last para 3 wasn't correct, I've seen a very recent post which looks good and received the thumbs up from admin. Does this work for my particular charge?

Referring to the Particulars of Claim, paragraph 1 is denied. The Defendant is not indebted to the Claimant. Although the Defendant is the registered keeper, paragraphs 3 and 4 are denied. The Defendant is not liable and has been provided with no evidence of any breach of clear or prominent terms. The Defendant denies the claim in its entirety. Given the passage of more than 3 years and the lack of detail in the inadequate Particulars of Claim, it is impossible for the Defendant to provide a full response. Signage at the material time was unclear and insufficient. The claimed sum is grossly inflated, as no private parking charge can lawfully amount to £170, and no loss or damages were incurred  

Regarding the Particulars of Claim paragraph 4, research has proved that this Claimant has never used the POFA 2012 and has never been able to hold registered keepers liable. The solicitor signatory of the statement of truth on this claim is knowingly or negligently misleading the court by citing that law. Because of the age of the claim and the lack of evidence produced by the Claimant the pleaded breach of unauthorised parking is refuted. 

Accordingly, the Claimant is put to strict proof of: 

• the alleged breach; 

• the contractual terms purportedly relied upon 

• the identity of the driver; and 

• full compliance with Schedule 4 of the Protection of Freedoms Act 2012 (POFA) if the Claimant seeks to transfer liability to the keeper.                                                                                                                              If this looks ok I'll publish full statement incl para 11 for final check if that's ok?

Many thanks again, hoping to destress.

Yep that's fine, as long as you do not admit to driving in para 2.

You could add that it is believed that this may have been what the Code of Practice calls a 'double dip' (two separate short stopping events read wrongly by AI as a single period of parking) and the Claimant is put to strict proof of ALL their camera captures of the vehicle's movements on site and in/out that day.

Job done!

Follow the easy 8 steps in the Template Defence thread.

No stress at all and DCB Legal will discontinue the claim just before they have to pay the hearing fee in 2026. You are on the well trodden road to killing this scam claim.

  

Rinkydinkpanic

@Coupon-mad submitted, fingers crossed now. Many thanks for your help, you are one of life's good people.

I'll let you know how it goes, hoping thats the end🤞