OP, how did this PCN end?
I'm still trying to identify the breach of the order because 19(d), which seems to be the reference condition, only appears to stipulate that a vehicle parked in a disabled bay but without displaying a BB etc. is not entitled to park without time limit or payment.
But you did pay.
And as for their General definitions regarding 'owner', there isn't a definition in the 1984 Act which applies in the sense it's used in the order. And it's unnecessary because enforcement doesn't take place pursuant to the provisions of an order but to. in this case, the TMA. But hey-ho.