DCB Legal / UKPC County Court Claim

SpeakUp123

Hi everyone,

I’ve received a County Court claim from DCB Legal acting on behalf of UK Parking Control Ltd.

The original parking charge was issued after I parked in a disabled bay while making a delivery in a van. I used the bay mainly because it made access easier for unloading. After the delivery I went to grab some food and later received a parking charge notice.

At the time, when they sent the original parking notice, the photos only showed my van itself. You could not actually see where the vehicle was parked from the photos provided, which is why I initially ignored it.

I have now received a claim form and have already submitted the Acknowledgment of Service (AOS) through MCOL because I want to see what evidence they actually have before making any decisions.

I do intend to defend the claim, however I’m struggling with the defence wording. I’ve attached the Particulars of Claim, and unlike some of the vague examples I’ve seen online, theirs seems to contain quite a lot of detail and legal wording, so I’m unsure what points are realistically defendable and what my defence should focus on.

My main concerns are:

• The original photos did not clearly show the alleged contravention
• Whether the signage/terms were actually sufficient
• Whether their Particulars being detailed changes how I should defend
• How strong DCB Legal / UKPC claims usually are once defended properly

I’d really appreciate any guidance from people familiar with these claims and what the strongest defence points usually are at this stage.

Thanks

Coupon-mad

1. Don't park even briefly in accessible bays.
2. Use the Template Defence.
3. DCB Legal always discontinue UKPC defended claims in the end, no hearings.

Le_Kirk

because I want to see what evidence they actually have before making any decisions

How do you think you might see that? What is the date of issue of the claim form? If you post that we can give you the deadline for your defence.

SpeakUp123

https://forums.moneysavingexpert.com/discussion/comment/82014247#Comment_82014247

Issue date is 11 May 2026 and AoS has already been completed.

I’m just not really sure what I should include in the defence at this stage. Should I just use the forum template defence and adapt it to my situation?

Gr1pr

Thats Correct, use the template defence, as directed by coupon mad in her reply earlier

Use a generic paragraph 3 that onky refutes the POC, but no stories about what happened

A suitable paragraph 3 that denies the alleged contravention

SpeakUp123

IN THE COUNTY COURT

Claim No:

BETWEEN:

UK Parking Control Ltd

Claimant

and

Defendant

DEFENCE

1. The Claimant’s sparse case lacks specificity and does not comply with CPR 16.4, 16PD3 or 16PD7, failing to state all facts necessary for the purpose of formulating a complete cause of action. Further, the Claimant has improperly added a false fee or damages to the original Parking Charge (PC). This sum is not legally recoverable and constitutes an attempt at double recovery, which is unreasonable conduct under CPR 27.14(2)(g). The binding Supreme Court judgment in ParkingEye Ltd v Beavis [2015] UKSC 67 held that an £85 parking charge more than covered all costs of enforcement. The same heads of cost cannot lawfully be counted twice and interest should also be disallowed. Exaggerated claims for impermissible sums are good reason for judges to intervene and the court is invited to strike out the claim using its powers under CPR 3.4.
2. The allegation(s) are vague and liability is denied for the sum claimed, or at all. The delay in bringing proceedings lies with the Claimant, making retrieval of material evidence difficult, which is highly prejudicial. The Defendant has little knowledge of events, save as set out below and admits only to being the registered keeper of the vehicle in question. The Defendant does not admit to being the driver and the Claimant is put to strict proof.
3. The Particulars of Claim allege that the vehicle was parked in a disabled bay without displaying a valid badge. Liability is denied. The Claimant is put to strict proof regarding the adequacy and prominence of the signage and contractual terms relied upon, together with strict proof that the alleged breach gave rise to the exaggerated sum now claimed.
4. It is neither admitted nor denied that a term was breached but to form a contract, there must be an offer, acceptance, and valuable consideration. The Consumer Rights Act 2015 mandates a test of fairness duty on Courts and sets a high bar for prominence of terms and consumer notices. On the limited information given, this case looks no different. The Claimant is put to strict proof with contemporaneous photographs.
5. DVLA keeper data is only supplied on the basis of prior written landowner authority. The Claimant is put to strict proof of their standing to sue and the terms, scope and dates of the landowner agreement, including the contract, updates, schedules and a map of the site boundary set by the landowner.
6. To impose a PC, as well as a breach, there must be a strong legitimate interest extending beyond compensation for loss and adequate notice of the PC and any relevant obligations. None of which have been demonstrated. This PC is a penalty arising as a result of poor signage and is fully distinguished from Beavis.
7. Attention is drawn to:

(i) paragraphs 98, 100, 193 and 198 of Beavis, where an £85 PC covered all costs and generated profit shared with the landowner, and

(ii) the binding judgment in ParkingEye v Somerfield Stores ChD [2011] EWHC 4023(QB), which remains unaffected by Beavis and stands as the only parking case law that references costs abuse. HHJ Hegarty held that costs inflating a parking charge were disproportionate and would appear penal.

1. The Parking (Code of Practice) Act will curb rogue conduct by operators and debt recovery agents. The Government launched a Public Consultation likely to herald a ban on double recovery fees, which a Minister described as extorting money from motorists.
2. Pursuant to Schedule 4 of the Protection of Freedoms Act 2012, the claim exceeds the maximum sum and is unrecoverable. There is no keeper liability for added false fees and POFA specifically states that double recovery is not allowed if a creditor uses any other remedy.
3. The Defendant seeks fixed costs pursuant to CPR 27.14 and a finding of unreasonable conduct and further costs pursuant to CPR 46.5.

STATEMENT OF TRUTH

I believe that the facts stated in this Defence are true.

Signed: _______________________

Name:

Date: _______________________

Does this defense look ok before I submit through MCOL?

Gr1pr

Definitely do not use an old out of date defence as that old one above

SpeakUp123

https://forums.moneysavingexpert.com/discussion/comment/82018106#Comment_82018106

Where can I find the current up to date template defence?

Gr1pr

https://forums.moneysavingexpert.com/discussion/comment/82018119#Comment_82018119

Top of this forum, in announcements

Coupon-mad

Use the Template Defence.

Don't add a Statement of Truth.

SpeakUp123

https://forums.moneysavingexpert.com/discussion/comment/82018121#Comment_82018121

The template I used was from Coupon-mad’s second post in the “Template Defence Suggestion” thread and it says it was last edited on 12 February.

I genuinely cannot see any newer updated template than that one, which is why I’m a bit confused.