Civil Enforcement PCN – Payment not made – Redbridge Institute of Adult Education

Updated to try and make the "double dip" my main point:

1. The Operator Has Failed to Prove a Single Continuous Parking Event
I am the Registered Keeper of the vehicle and submit this appeal in that capacity.

The Operator's case relies entirely upon two ANPR images recording a vehicle entering and exiting the site. From those two isolated timestamps, the Operator asks POPLA to infer that a single continuous parking event occurred.

I dispute that inference.

In my original appeal to the Operator, I specifically advised that the vehicle entered and exited the site on more than one occasion within a short timeframe and requested that the Operator review its full ANPR records, including any unmatched or orphan captures.

Despite this, the Operator's subsequent correspondence failed to address the point. The rejection letter contains no discussion of the multiple-visit issue and provides no evidence that any investigation of additional ANPR records was undertaken.

ANPR systems record vehicles passing camera locations. They do not record whether a vehicle was parked, where it was parked, how long it remained stationary, or whether multiple visits occurred during the relevant period.

The Operator has produced no evidence demonstrating:

* that all ANPR captures relating to the vehicle were reviewed;
* that multiple entry and exit events were excluded;
* that orphan or unmatched records were checked;
* that the timestamps relied upon represent a single continuous stay rather than separate visits.

The Operator's case therefore depends entirely upon an assumption that the two ANPR images relied upon represent a single continuous parking event.

I submit that this has not been proven.

Where a specific challenge regarding multiple visits has been raised and the Operator has failed to demonstrate that the issue was investigated, POPLA cannot safely conclude that the ANPR evidence establishes a single continuous period of parking.

Accordingly, the alleged contravention has not been proven.

2. The Notice to Keeper Does Not Establish Keeper Liability Under PoFA 2012
The Operator seeks to pursue me as Registered Keeper.

As I have not identified the driver, the Operator must demonstrate full compliance with Schedule 4 of the Protection of Freedoms Act 2012 ("PoFA") in order to transfer liability from the driver to the keeper.

The Notice to Keeper relies upon ANPR-generated "From" and "To" timestamps.

However, PoFA requires the Notice to Keeper to specify the relevant period of parking.

Entry and exit timestamps merely record vehicle movements past camera locations. They do not identify a period of parking.

The Operator has not demonstrated that the requirements of Schedule 4 have been met and therefore has not established keeper liability.

Accordingly, the charge cannot be enforced against me as Registered Keeper.

3. The Operator Has Not Proven Any Actual Period of Parking
Even if POPLA were satisfied that keeper liability has been established, the Operator must still prove that a parking contravention occurred.

The evidence supplied consists only of ANPR entry and exit timestamps showing a total site presence of approximately 13 minutes.

Those timestamps do not establish:

* when parking commenced;
* when parking ended;
* whether the vehicle was parked at all;
* how much time was spent driving within the site;
* whether the driver was locating signage, turning around, or exiting.

The Notice to Keeper itself refers only to ANPR-derived "From" and "To" times and does not identify any separately evidenced period of parking.

The Operator has therefore failed to prove the duration of any actual parking event.

4. Failure to Properly Consider the Appeal and Submitted Evidence
After receiving my appeal, the Operator requested additional information.

The Operator directed that this material be submitted via its online portal.

The portal did not permit the requested upload and the material was therefore submitted by email instead.

Despite this, the Operator's rejection letter states:

"As this information has not been received within the specified timeframe..."

The rejection letter contains no acknowledgement of the emailed submission and no discussion of the substantive issues raised.

Furthermore, the Operator's earlier correspondence referred to "emergency circumstances" allegedly raised in my appeal despite no such circumstances having been mentioned.

The subsequent rejection letter also included wording stating:

"Please note that as the parking incident occurred in Scotland or Northern Ireland, only the driver can make the appeal to POPLA."

The site concerned is located in England.

These inaccuracies raise legitimate concerns as to whether the appeal was individually reviewed and whether the specific points raised were properly considered.

Whilst I do not rely upon this as a standalone ground of appeal, it is relevant when assessing the weight that should be attached to the Operator's unsupported assertion that it investigated and verified its ANPR evidence.

5. Inadequate Evidence of Contract Formation
The Operator is put to strict proof that the signage at the site was sufficiently clear, prominent and legible to bring the contractual terms to the attention of motorists before any contract was formed.

The Operator must demonstrate that:

* signage was clearly visible on entry;
* signage was prominent throughout the site;
* the terms were capable of being read and understood before any contractual agreement was formed.

Absent such proof, no contract can be established.

6. Operator Authority
The Operator is put to strict proof that it has the necessary authority from the landowner to:

* manage parking at this site;
* issue Parking Charge Notices in its own name;
* pursue unpaid charges; and
* defend appeals relating to those charges.

As the Operator is not the landowner, I require it to demonstrate that it possesses sufficient authority to undertake these activities at the material location.

Conclusion
The Operator has failed to prove that a single continuous parking event occurred.

The Operator has failed to address or investigate the specific multiple-visit issue raised in the original appeal.

The Operator has failed to establish keeper liability under PoFA 2012.

The Operator has failed to prove any actual period of parking.

Accordingly, I respectfully request that POPLA allow this appeal and direct Civil Enforcement Ltd to cancel the Parking Charge Notice.

Redbridge Institute of Adult Education is the adult education service of London Borough of Redbridge - this makes it a council owned / provided.

London Borough of Redbridge is a traffic authority for the purposes of PoFA.

The land is therefore excluded from PoFA keeper liability as it is not 'relevant land' - this is set out under Schedule 4 Paragraph 3(1)(b) which states;

3(1) In this Schedule “relevant land” means any land (including land above or below ground level) other than—

(a)a highway maintainable at the public expense (within the meaning of section 329(1) of the Highways Act 1980);

(b)a parking place which is provided or controlled by a traffic authority;

(c)any land (not falling within paragraph (a) or (b)) on which the parking of a vehicle is subject to statutory control.


As long as the driver is not identified then liability cannot be moved onto the Registered Keeper.

3(2)(e) establishes London Borough of Redbridge as a traffic authority.

Civil Enforcement have provided their POPLA Pack, I'm not sure quite what to make of it, but want to comment on it as I have the chance. I don't believe they have fully engaged with the @InterCity125 point, but then they've produced Confirmation of Authority from 2017 at the back of the evidence pack.

CE POPLA Pack

My comments for what they're worth:
My comments are restricted to the Operator's evidence and matters arising from it.

The Operator has failed to answer the central issue: whether this was a single continuous parking event
My primary appeal point was that the ANPR evidence relied upon by the Operator may represent two separate visits to the site rather than one continuous parking event.

I specifically requested that the Operator review its complete ANPR records, including any additional captures, unmatched reads or orphan entries, to establish whether multiple visits had occurred.

The Operator's response is simply that it has checked its ANPR footage and that:

"If there has been any further entrances/exits on that day, these would be shown on our photographic evidence."

This does not answer the issue raised.

The Operator also relies upon a screenshot in support of its assertion that there were no further entries or exits for the vehicle on the date in question.

However, the screenshot itself provides no meaningful context as to what information it displays. The Operator has not explained:

what system the screenshot has been taken from;
what search parameters were used;
whether it represents the complete ANPR record for the vehicle on that date;
whether unmatched or non-chargeable movements have been included; or
whether any filtering has been applied.

A screenshot without this supporting explanation cannot, by itself, prove that no additional vehicle movements occurred. This is particularly relevant because my appeal specifically challenged whether the ANPR evidence represented one continuous visit or multiple visits.

The Operator has also not provided evidence demonstrating:

what ANPR records were reviewed;
whether all vehicle movements on the date in question were checked;
whether unmatched or orphan ANPR captures were considered;
how the possibility of multiple visits was excluded.

The Operator has simply relied upon the two images already used to issue the Parking Charge Notice.

My appeal was not that those two images do not exist. My appeal is that those two images, without further evidence, do not prove a single continuous parking event.

The burden remains on the Operator to prove the alleged contravention occurred.

The Operator incorrectly states that additional evidence was not provided
The Operator states that my appeal was rejected because I failed to provide the additional evidence requested.

This is incorrect.

The Operator requested further information through its appeals process. When attempting to comply, the online portal did not allow the requested evidence to be uploaded. I therefore submitted the information by email to the Operator's published data protection email address.

The Operator's evidence pack does not acknowledge receipt of that email, explain why it was disregarded, or explain why it continued to state that no evidence had been provided.

The Operator cannot reasonably rely upon an alleged failure to provide evidence where the evidence was submitted following a failure of its own portal.

The Operator's evidence contains multiple objective inaccuracies
The Operator's evidence pack contains several factual inconsistencies which undermine confidence in its reliability.

The evidence refers to correspondence allegedly issued on:

5 August 2025; and
18 August 2025.

However, the alleged parking event occurred on 18 March 2026.

More significantly, the Operator states:

"The Appellant's details as the registered keeper were obtained from the DVLA on 28/06/2025 and the PCN was sent on 28/06/2025."

This is a chronological impossibility.

The alleged parking event had not occurred at that time, meaning the Operator could not have obtained my keeper details or issued a Notice to Keeper in relation to this alleged incident approximately nine months before the event.

The Operator's correspondence also refers to "emergency circumstances", despite no such circumstances forming part of my appeal.

Additionally, the Operator's rejection letter incorrectly states:

"Please note that as the parking incident occurred in Scotland or Northern Ireland..."

The location of the alleged incident is Redbridge Institute of Adult Education, Ilford, England.

Whilst individual administrative errors can occur, the number of inaccuracies within the Operator's evidence pack raises concerns as to whether this appeal has been individually reviewed or whether template material has been applied without proper verification.

The Operator has not demonstrated that keeper liability has been established
I appeal as the Registered Keeper only.

I have not identified the driver and I am under no legal obligation to do so.

The Operator therefore relies upon Schedule 4 of the Protection of Freedoms Act 2012 to transfer liability from the driver to the Registered Keeper.

The Operator is required to demonstrate compliance with all mandatory requirements of Schedule 4.

The Notice to Keeper was received by me on 7 April 2026 following an alleged event on 18 March 2026. The Operator is therefore put to strict proof that the Notice to Keeper was delivered within the statutory timeframe required by paragraph 9(4) of Schedule 4.

A date printed on a Notice to Keeper is not, by itself, proof of the date of posting or delivery.

Furthermore, the Operator has not demonstrated that the land falls within the definition of "relevant land" for the purposes of Schedule 4.

Accordingly, keeper liability has not been established.

The Operator has not proven the duration of any actual period of parking
The Operator relies upon ANPR entry and exit timestamps.

These timestamps record vehicle movements past cameras but do not, without further evidence, establish an actual period of parking.

The evidence does not demonstrate:

when any parking commenced;
when any parking ended;
that the vehicle remained parked continuously;
that no intervening visit occurred.

Given the specific challenge regarding multiple visits, the ANPR evidence should not be accepted as proof of a single continuous parking event without further supporting evidence.

Conclusion
The Operator has not addressed the central issue raised in my appeal: whether the ANPR evidence represents one continuous parking event.
Instead, it has relied upon unsupported assertions and evidence containing multiple factual inaccuracies.
The Operator has also failed to demonstrate that keeper liability has been established.
For these reasons, I respectfully request that POPLA allows the appeal and directs Civil Enforcement Ltd to cancel the Parking Charge Notice.

Absolute shambles from CE.

I would also 'make hay' in the conclusion - pose the question, "Given the absolute shambles of an evidence pack, how can be rely on anything they say?"

Just had an update from POPLA, unsuccessful. I guess now it's a waiting game to see what CE do next?

Decision
Unsuccessful
Assessor Name
Natasha Rhodes
Assessor summary of operator case
The parking operator has issued a parking charge notice (PCN) as payment was not made in accordance with the notified terms.

Assessor summary of your case
The appellant has raised the following points from their grounds of appeal • The operator relies on two ANPR images of the vehicle entering and exiting the site. They explain that the vehicle entered the site on more than one occasion, within a relatively short period and request the operator complete a full review of the ANPR records. • The operator failed to address this in either its further information or rejection letter. • The ANPR images record vehicle movements, and do not prove that a vehicle remained parked continuously between the timestamps. • The Notice to Keeper was received outside of the 14-day timeframe stated within the Protection of Freedom’s Act 2012. • The operator has not demonstrated the site constitutes "Relevant Land" for the Purposes of Schedule 4. • The operator has failed to prove any actual period of parking. • The operator has failed to properly consider their appeal. After reviewing the parking operator’s evidence, the appellant reiterates their grounds of appeal To support their appeal, the appellant has provided a copy of the correspondence with Civil Enforcement as evidence The evidence provided will be viewed as part of my decision.

Assessor supporting rational for decision
When assessing an appeal POPLA considers if the parking operator has issued the parking charge notice correctly and if the driver has complied with the terms and conditions for the use of the car park. The appellant states the Notice to Keeper was received outside of the 14-day timeframe stated within the Protection of Freedom’s Act 2012. I have reviewed the copy of the original PCN and can see the alleged breach happened on 18th March 2026. Section 9. (5) of the Protection of Freedoms Act (PoFA) 2012 states, “The relevant period for the purposes of sub paragraph (4) is the period of 14 days beginning with the day after that on which the specified period of parking ended. (6) A notice sent by post is to be presumed, unless the contrary is proved, to have been delivered (and so “given” for the purposes of sub-paragraph (4)) on the second working day after the day on which it is posted; and for this purpose, “working day” means any day other than a Saturday, Sunday or a public holiday in England and Wales”. The PCN was issued to the keeper on 24th March 2026, 6 days after the alleged breach occurred. As such, the Notice to Keeper was issued within the 14 days required in line with PoFA. As such, the Notice to Keeper is complaint with PoFA and I can consider the registered keeper liable for the PCN. The appellant states the operator relies on two ANPR images of the vehicle entering and exiting the site. They explain that the vehicle entered the site on more than one occasion, within a relatively short period and request the operator complete a full review of the ANPR records. They state the ANPR images record vehicle movements, and do not prove that a vehicle remained parked continuously between the timestamps. The appellant states the operator has failed to prove any actual period of parking. The operator uses ANPR technology to record only the times a vehicle enters and exits the site, and these timestamps are used to calculate the total duration of a motorist’s stay. It is not possible for the operator to determine what a driver is doing during this period, whether they are parking, reading signage, or carrying out any other activity. As such, it is the motorist’s responsibility to note the time they arrive on site and ensure that payment is made to cover the full duration of their stay. Within the operator’s case file, Civil Enforcement has provided evidence of the signage present on site. From reviewing this, it confirms that payment can be made with RingGo or at the machine. It warns that failure to comply with the terms and conditions will result in a PCN of £100. In this case, the vehicle entered the site at 14:24 and exited at 14:37 therefore, was on site for 13 minutes. As per the tariff signage, the appellant needed to make a payment of £1.00 to cover the full duration of their stay. Furthermore, Civil Enforcement has provided a system search of the ANPR data. This shows only one entry and exit. As such, I have seen no evidence to suggest the vehicle visited the site on more than one occasion within a short period. The appellant states the operator failed to address this in either its further information or rejection letter. They also state the operator has failed to properly consider their appeal. While I note the appellant’s comments, POPLA’s role is to determine if the PCN was issued correctly. It is not within POPLA’s remit to comment on the operator’s actions, as this has no bearing on the motorist’s ability to comply with the terms of the site. Any questions regarding this should be addressed directly with the parking operator as per their complaint process, which can be found on their website. The operator has not demonstrated the site constitutes "Relevant Land" for the Purposes of Schedule 4. In this case, the operator has provided that the site is private land and therefore it is not one of the types of land excluded within the POFA as such I are satisfied that the land is relevant land Within the operator’s case file, Civil Enforcement has provided a payment report taken from the site. This shows the vehicle did not have a valid parking session for their stay. As such, a breach of the terms and conditions was identified. After considering the evidence from both parties, the vehicle did not have a valid parking session and therefore the appellant did not comply with the terms and conditions of the site. As such, I am satisfied the parking charge has been issued correctly and I must refuse the appeal.

First thing which jumps off the page is that Natasha Rhodes contradicts herself.

She says the following;


The operator has not demonstrated the site constitutes "Relevant Land" for the Purposes of Schedule 4. In this case, the operator has provided that the site is private land and therefore it is not one of the types of land excluded within the POFA as such I are satisfied that the land is relevant land.


First she states that operator has not demonstrated that the land is relevant land - on that point she is correct, the operator's evidence contains no evidence which covers the non relevant land issue and therefore the operator has not rebutted that appeal point and therefore she should allow the appeal.

But then she says (in bad English) that "the operator has provided that the site is private land" - what does that mean? The operator doesn't cover this point in their evidence??

Another shocking assessment from POPLA where the Assessor simply 'makes up' missing evidence in order to favour the operator.