CCJ sent to my old address - Set aside application and fee payments

cappy182

Hi all,

I received a CCJ to an old address from G24 ltd regarding a parking event in May 2025. 

I was able to collect my old mail from my previous address included the POC and all threatenings mails from DCBL Baliffs.

After reading the NEWBIES posts and related subthreads, I prepared a letter for DCBL to set aside the court judgment and sent to them by email. 

I’ve used the template from the post of troublemaker22 on the thread “Out of the Blue: CCJ Debt letter (for an alleged pcn) – dcbl (/UK Parking Control ltd)”.

I’ve changed a few things since my situation is slightly different:

- I only realised about the CCJ checking the credit score on my bank account. 

• I’ve never received any communication regarding the parking event, including the original PCN, letter of claim and claim forms from the court (CNBC) to the new address. 
• The claimant is G24 Ltd which is member of the ICP and not BPA

Other important information for context:

• alleged parked event happened in May 2025
• I changed address in July 2025
• Updated address on 27th August 2025
• Court paper sent to old address on 21/11/25 and CCJ letter on the 11/12/25

IMPORTANT: DBCL issued me two more debt collection letters (3 Dec and 31st Dec 2025) from a more recent PCN (July 2025) at my new address from the same car park company G24. All the initial communication of the second PCN were sent to the old address instead and they magically found my new one. For this reason I've submitted a SAR request to G24. 

The following is the letter I’ve sent to the solicitors DCB Legal as they are the legal representatives of G24.

URGENT
Dear Sirs,
G24 LTD (THE ‘CLAIMANT’)  V XXX CLAIM REFERENCE xxxx
On the 6th January 2026, I realised that a CCJ had been sent to my old address after checking my credit score through my bank account.  
After collecting the old mail from that address I found a letter dated 11th December 2025 from HM Courts & Tribunals Service.
This came as a tremendous shock as it is the first and only communication I have received from G24 Ltd or any organisation representing the Claimant in relation to this claim.   
I made immediate enquiries of the CNBC from which I was able to establish that:
1.       the claim relates to an alleged parking event in May 2025;
2.       the claim form was sent to an old address at which I no longer reside; and
3.       if I had been given the opportunity to do so, I would have successfully defended the claim.
I did not receive any pre-claim correspondence, not even a letter of claim as required by the PAP. Nor did I receive the claim form or any particulars of claim and was thus deprived of the ability to defend the claim. The Claimant is well aware that people move home from time to time. They also know that I did not respond to any communications sent to me at my old address.
This situation is explicitly dealt with in the Civil Procedure Rules which provide at CPR 6.9(3):
 (3) Where a claimant has reason to believe that the address of the defendant … is an address at which the defendant no longer resides or carries on business, the claimant must take reasonable steps to ascertain the address of the defendant’s current residence or place of business (‘current address’).
If the Claimant had taken the actions required by the Civil Procedure Rules and the Code of Practice, my current address would have been found easily. If those actions had been performed at the correct time rather than after judgment, I would not have been deprived of the ability to defend the claim.
By reason of the Claimant’s breach of the Civil Procedure Rules, which amounts to an abuse of the process of the Court, the claim form was never properly served and the judgment must be set aside at the Claimant’s expense and the claim dismissed because it is now too late for the particulars of claim to be re-served.
In view of the foregoing, I invite the Claimant to join with me in an application to set aside the judgment and dismiss the claim, with the Claimant paying the court fee and no order as to costs.
Please respond to the above offer as soon as possible so that, if the offer is acceptable to the Claimant, we can work together to right the wrong that the Claimant has done to me.
To give you a reasonable time to take instructions and for us to agree a suite of documents for the Court, I am willing to defer making a unilateral application to set aside the judgment until 4 pm on 31 January 2026. If a joint application has not been made by that time, I intend to instruct a solicitor to apply to the Court unilaterally for an order setting the judgment aside, striking out the particulars of claim, dismissing the claim and awarding costs against the Claimant on a full indemnity basis.
Pease respond by immediate return.
Yours faithfully,

From what I’ve understood by reading the information on the forum, if DCLegal does not respond within 2 weeks time, I will need to apply for a set aside with N224 form and pay the fee. 

I would appreciate any advice on the matter and how to proceed from now on. 

Especially regarding how to redact the WS, Defence and claiming back the costs.

Thank you!

Coupon-mad

You aren't doing a defence.

You will be doing a N244 with WS proving your address change and a Draft Order (what you want the judge to order at your hearing) which includes setting aside the CCJ, striking out the claim for failure to serve it within 4 months, and awarding your costs to be paid by the C.

You'll be relying on VCS v Carr and Mazur v Speechlys. Search the forum for a 2025 CCJ case with those authorities cited. Copy! 

cappy182

Hi,

thanks for your support. 

I've been doing my research on this forum and there are lot of information that I have to put together for my N244 application.

I followed the instructions and drafted that letter by troublemaker22 (Out of the Blue:CCJ Debt letter for pcn) and sent to the solicitors (DCBL), but I haven't received any answers yet and it's been already two weeks since then.

I'd like to proceed with the set aside within this week as stated in that letter I've sent to them. 

I found out that I can do the application online on this website 'MoneyClaimOnline' linked to HM Courts&Tribunal. 
A friend of mine suggested me to do this way because she had to fight a CCJ for a car park a few months ago and she managed to do it through this website. 

On the website there are different sections, and the first one it's about the Draft Order that you mentioned before I guess 

You'll be relying on VCS v Carr and Mazur v Speechlys. Search the forum for a 2025 CCJ case with those authorities cited. Copy! 

I'm preparing the set aside based on these threads. Is there one in particular that I should look into it related to my case? 

I'll try to post the Draft order and WS within Thursday.

Thanks again 

Coupon-mad

We don't have a particular thread in mind but a forum search for that case law plus the words CCJ set aside will find one.

cappy182

Hi, thanks again for your answer.

Also, I've got a doubt about mentioning the VCS vs Carr regarding the 4 months matter. I'm not sure if relates to me as the claim form that I managed to collect from my old address is dated on 21st Nov 2025 and I'm requested a set aside 90 days after the CCJ was issued the wrong address (11 Dec 2025).

Is this still apply to my case? Can I add it on my WS?

Finally, I hope I can have a review of my draft order below

DRAFT ORDER


CLAIM No: XXXXXXX


BETWEEN: 


G24 limited (Claimant)


-- and –


(Defendant)


IT IS ORDERED THAT:

1. The default judgment dated 11 NOVEMBER 2025 CLAIM No: XXXXXXX ) be set aside. 

2. The claim struck out due to the claim form having not been served at the correct address

3. The Claimant do pay the Defendants costs of this application of £283.xx on an indemnity basis.

4. The Claimant shall pay the Defendant’s costs of this application, summarily assessed at £313.00 (the court fee), within 14 days of this order.

Thanks again

Coupon-mad

Who signed the Claim Form on the back?

You are right not to mention the 4 months expiry (yet). But the CCJ isn't dated 11th November. Check again.

Remove para 3 which makes no sense.

The Draft Order has this at the top, not where you put it in the Order.

CLAIM No: XXXXXXX

cappy182

Hi, thanks for the correction.

I'm sorry I've got the dates wrong and the claim forms that I managed to collect from my old address are both from CNBC and can't find any other signatures on these letters apart from the stamp of the Civil Court.

The first claim form from CNBC was issued on 21st Nov 2025 and they gave me two weeks to reply. Then, they sent the CCJ Judgment for Claimant on the 11th Dec saying that I have to pay the it within a month.

I've got another letter delivered on the 22 Dec at the old address signed by (Removed by Forum Team).

Unfortunately I realised about the CCJ from my credit score when I came back from my Christmas holidays and it was around the 6-7th Jan before I've collected these letters from my old address.

Then, on the 16th January I've received this 'Notice of Debt recovery' from DCBL 'magically' at my NEW address and that has been signed by (Removed by Forum Team)

(Image removed by Forum Team)

I've got my WS almost ready but not sure which cases you mentioned I should really use at my defence because VS Carr doesn't apply to my case just yet.

I really need to submitt the N244 by tomorrow because I don't want get any other delays despite I gave DCB Legal the chance to answer my letter I've sent to them more than a couple of weeks ago.

I'll post it here soon.

Thank you so much for reviewing my case 🙏🏻

Coupon-mad

You can find the name of who signed it off. It's obviously not a signature.

Look again. Not at the daft £170 threatograms. Only the CLAIM FORM.

cappy182

Also, this is my draft of my WS

WITNESS STATEMENT

I, XXXNameXXX, of address, will say as follows:

1.     I make this statement in support of my application to set aside the default judgment entered against me. The judgment was obtained without proper service of the claim form, and I had no knowledge of the proceedings until after the judgment was entered. I respectfully request the Court set aside the judgment under CPR 13.2 and/or CPR 13.3.

2.     I believe I have a strong and legitimate defence to the claim. In the event that the claim is not dismissed, I respectfully request the opportunity to defend it fully and fairly, in accordance with CPR 13.3, which provides for the setting aside of a default judgment where the defendant has a real prospect of successfully defending the claim.

3.     I understand that the Claimant obtained a Default Judgment against me on 21/11/2025. I am aware that G24 Limited is the Claimant, and the claim appears to relate to an unpaid Parking Charge Notice.

In addition to the above, it should be highlighted that the integrity and law-abiding intention of the Defendant should be taken into consideration on the basis that;

SEQUENCE OF EVENTS

4.     The address listed on the claim form is previous address . I moved from this address to my current residence at new addressin July 2025. In support of this, I provide evidence of most recent DVLA updated in August 2025 and a copy of my credit file, showing dates my address changed on the Electoral roll. 

[see Exhibit A - proof V5C updated in Aug 2025 and electoral Roll updated in Sep 2025 ].

 5.     I was unaware of the claim made against me until I obtained a credit report from TransUnion and Experian on 06/01/2026 through my bank app. 

6. After collecting the old mail from my old address I found a letter dated 11th December 2025 from HM Courts & Tribunals Service. I was at this point that I discovered a Country Court Judgment had been entered against me.

7.     On the 9th January 2025, I called CNBC and made immediate enquiries regarding the claim against me from which I was able to establish that: 

- the claim relates to an alleged parking event in May 2025;

- the claim form was sent to an old address at which I no longer reside; and if I had been given the opportunity to do so, I would have successfully defended the claim.

CNBC instructed me that that I had to submit a N244 form if I would like to dispute the Judgment for the set aside and pay the fee 313£.

8.  On the 11th January 2025, I contacted the Claimant G24 Ltd and requested a SAR  in order to get all the information in their possess about me [see Exhibit B]

9. On 12th January 2025, I contacted DCB Legal and I invited the Claimant to join with me in application to set aside the judgment and dismiss the claim, with the Claimant paying the court fee and no order as to costs. I offered them time to reply till 31st January 2025 [see Exhibit C - letter send to DCB legal]

10. A notice of debt recovery (Unpaid CCJ £283,85) was sent to my current address by DCBL on 16 January 2026 (reference number 11195400) [see Exhibit D]. This shows that the Claimant was aware their original address was incorrect, and had successfully traced and identified my correct address as of January 2026. 

11. Despite having the correct address, the Claimant issued proceedings in November 2025 using an outdated address—believed to be the vehicle’s registered keeper address held by the DVLA, which was no longer valid. The Claimant's continued use of the old DVLA address, despite having it updated in August 2025, [see VC5 attachment], renders service of the claim form invalid. The default judgment was consequently entered without proper notice, denying me the opportunity to respond or defend the claim. 

12.  On Monday 26th January, I carried out a research on CheckMyFile and I got an extract of my credit file which demonstrated I was registered on the Electoral roll at my current address (XXXXXX) from September 2025. [see Exhibit F - credit file attachment]. The Claimant failed to take reasonable steps to verify the Defendant’s current address, as required by CPR 6.9(3) and the BPA Code of Practice 24.1c. A simple and inexpensive “soft trace” (costing around 28 pence) would have revealed the Defendant’s current address. 

13. The claimant demonstrated that they could have easily found the defendant’s current address to properly serve the clam and thus could have easily complied with CPR 6.9, having very quickly sent notice of Debt recovery to the correct address, once a default CCJ had been obtained in the defendant’s absence.  Additionally, this appears to be a common method of operation used by the clamant to obtain default judgments. This failure to take proper steps is not an isolated case. Many individuals across the country have been similarly affected by the parking industry's failure to confirm accurate addresses, resulting in undue stress and legal burdens. This failure mirrors the principles established in VCS Ltd v Carr (CA-2024-001179, Court of Appeal, 4 March 2025), where the court held that claimants must take reasonable steps to ensure service is effective. The court emphasised that serving a claim at an outdated address, without reasonable diligence, renders the judgment void. Initial findings from the Court of Appeal hearing are provided separately for the court’s reference: Phillip Carr v Vehicle Control Services LTD Neutral Citation Number[2025] EWCA Civ 713 (points. 39).

14.   The defendants lack of response to ANY correspondence from the clamant, up to and including pre court action (Letter before Claim) should have reasonably put the clamant on notice that the address was likely not current and suitable to serve the claim, therefore requiring further reasonably steps to be taken to ensure proper service of claim.

16.  The KADOE (Keeper at Date of Event) system offers only a snapshot of where a vehicle was registered at a particular time, not a reliable service address for court claims.

17.  Operators are permitted to query the DVLA only once. Therefore, the IPC Code mandates that reasonable steps be taken to confirm the defendant’s current address prior to issuing a claim.

18.  The use of an outdated DVLA address, without soft trace checks (which are inexpensive and readily available), breaches the IPC Code of Practice, the Pre-Action Protocol for Debt Claims, and CPR requirements to take reasonable steps to ensure proper service.

19.  In “Civil Enforcement Ltd v Chan” (2018), the court held that sending court documents to a previous address when a more recent one is known is not proper service [see Exhibit G]. The court struck out a claim due to the Claimant’s failure to comply with CPR 16.4 and Practice Direction 16.7.5. The court held that the particulars of claim must specify the conduct constituting the breach, which was not done in that case. Similarly, in this case, the Claimant has failed to provide sufficient details of the alleged breach, rendering the claim defective and liable to be struck out.

CLAIM SHOULD BE STRUCK OUT

20.  I respectfully bring to the Court’s attention that I was never served with the Particulars of Claim. As a result, I have been denied a fair opportunity to understand or respond to the allegations made.

21.  Under CPR 3.4(2), the Court may strike out a statement of case if it: (a) discloses no reasonable grounds for bringing the claim; or (b) constitutes an abuse of the Court’s process or is otherwise likely to obstruct the just disposal of the proceedings. This claim satisfies both of these grounds.

22.  In Venulum Property Investments Ltd v Space Architecture & Others [2013] EWHC 1242 (TCC), the Court held that a failure to serve claim forms properly, combined with deliberate procedural delays, amounted to an abuse of process and warranted the claim being struck out under CPR 3.4 .

23.  Similarly, in Nugent v Nugent [2019] EWHC 1151 (Ch), the Court struck out proceedings on the basis that the claim had not been properly served and the claimant had failed to adhere to principles of procedural fairness.

24.  These authorities reinforce the proposition that where a party fails to comply with fundamental service requirements and undermines the fair progression of proceedings, striking out the claim is not only justified but necessary to uphold the integrity of the judicial process.

25.  The Claimant should not be permitted to waste further Court time or resources, particularly where they have failed to comply with key procedural obligations, including the Pre-Action Protocol for Debt Claims, the IPC Code of Practice, and CPR 6.9, which obliges a claimant to take ‘reasonable steps’ to verify a defendant’s current address prior to service. The failure to do so is particularly egregious given the Claimant had access to an Experian trace identifying the correct address, yet chose to ignore it.

26.  If the Claimant believes they still have a cause of action, the correct course is to commence proceedings afresh—this time complying with all relevant procedural requirements. This includes sending a proper Letter Before Claim to the correct address, as required by the Pre-Action Protocol. To date, I have received no claim form or Particulars of Claim at my current address, and therefore have had no opportunity to understand or respond to the case.

27.  For these reasons, I respectfully request that the Court strike out the claim under CPR 3.4(2)(a) and (b). The claim is procedurally defective and was never validly served.

CONSIDERATION OF PROMPTNESS

28. I respectfully request that the Court take this into account when considering the issue of promptness under CPR 13.3(2). Once I became aware of the judgment and was able to understand the situation fully, I acted as swiftly as I reasonably could in making this application.

COSTS

29. In accordance with CPR 46.5, I respectfully request that the Court allow a reasonable amount of preparation time at the Litigant in Person rate of £19 per hour. I estimate that I have spent approximately:

• 6 hours dealing with DCB Legal correspondence and N244 preparation @ £19/hr = £114

• 20 hours studying case law and preparing this Witness Statement £15/hr = £380

• £150 Emotional distress of getting a CCJ on my credit file and unable to get loans or credit.

I also respectfully request that the Court consider ordering the Claimant to reimburse the £313 court fee I was required to pay in order to apply for this set-aside, as well as my reasonable costs for attending any hearing.

Total: £957

I submit that is a fair and proportionate amount in the circumstances and ask the Court to include this in any costs award.

RELIEF SOUGHT

30. In light of the above, I was unable to file a defence or properly respond to the claim. I therefore submit that the Default Judgment was entered incorrectly and respectfully request that it be set aside. The Defendant respectfully requests the Court to:

• Set aside the Default Judgment dated XXXX under CPR 13.2 and/or 13.3;

• Strike out the underlying claim as it was improperly served and lacks merit; and

• Order the Claimant to reimburse the Defendant’s costs as detailed above.

STATEMENT OF TRUTH:

31.  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:
Date:

Also, I'.m not sure to add the Mazur case in according to that letter I've received at the old address from Sarah Ensall or leave it for later on

5. Improper or Unauthorised Claim Signature

5.1 The Defendant has not yet been provided with a copy of the original claim form but notes that Vehicle Control Services claims issued around November 2024 were frequently signed by non-solicitors, including individuals such as (Removed by Forum Team).

5.2 If this claim was similarly signed, it would amount to a breach of the Legal Services Act 2007, as reaffirmed in Mazur v Speechlys LLP (2025), where the Court held that unauthorised signing of claim forms constituted improper conduct.

5.3 The Defendant reserves the right to rely on this authority once disclosure of the claim form is made.

cappy182

https://forums.moneysavingexpert.com/discussion/comment/81865155#Comment_81865155

I'm sorry, just realised the signature is not a proper signature as you said but it's (Removed by Forum Team) on statement of Truth

(Image removed by Forum Team)

Coupon-mad

No it's (Removed by Forum Team). But forget that line of query. I was just checking it was signed by a solicitor, and he is.

So you cannot use Mazur.