Free Traffic Legal Advice
Live cases legal advice => Private parking tickets => Topic started by: cm6578 on April 03, 2026, 04:10:20 pm
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Hi,
I was wondering if I could have some advice please as I have made an appeal to the IAS after Euro parking rejected my appeal. I read through some comments on here so I used the following but I don't know if I've messed up. I have also receive the prima facie from the operator (below) claiming that the appellant was the drive but at no point has the drivers identity been revealed. I have until tomorrow to respond.
I am the registered keeper of the vehicle. I deny any liability for this parking charge and appeal in full.
The parking operator bears the burden of proof. It must establish that a contravention occurred, that a valid contract was formed between the operator and the driver, and that it has lawful authority to operate and issue Parking Charge Notices (PCNs) in its own name. I therefore require the operator to provide the following:
1. Strict proof of clear, prominent, and adequate signage that was in place on the date in question, at the exact location of the alleged contravention. This must include a detailed site plan showing the placement of each sign and legible images of the signs in situ. The operator must demonstrate that signage was visible, legible, and compliant with the IPC Code of Practice that was valid at the time of the alleged contravention, including requirements relating to font size, positioning, and the communication of key terms.
2. Strict proof of a valid, contemporaneous contract or lease flowing from the landowner that authorises the operator to manage parking, issue PCNs, and pursue legal action in its own name. I refer the operator and the IAS assessor to Section 14 of the PPSCoP (Relationship with Landowner), which clearly sets out mandatory minimum requirements that must be evidenced before any parking charge may be issued on controlled land.
In particular, Section 14.1(a)-(j) requires the operator to have in place written confirmation from the landowner which includes:
the identity of the landowner,
a boundary map of the land to be managed,
applicable byelaws,
the duration and scope of authority granted,
detailed parking terms and conditions including any specific permissions or exemptions,
the means of issuing PCNs
. responsibility for obtaining planning and advertising consents,
. and the operator's obligations and appeal procedure under the Code.
These requirements are not optional. They are a condition precedent to issuing a PCN and bringing any associated action. Accordingly, I put the operator to strict proof of compliance with the entirety of Section 14 of the PPSCoP. Any document that contains redactions must not obscure the above conditions. The document must also be dated and signed by identifiable persons, with evidence of their authority to act on behalf of the parties to the agreement. The operator must provide an agreement showing clear authorisation from the landowner for this specific site.
3. Strict proof that the enforcement mechanism (e.g. ANPR or manual patrol) is reliable, synchronised, maintained, and calibrated regularly. The operator must prove the vehicle was present for the full duration alleged and not simply momentarily on site, potentially within a permitted consideration or grace period as defined by the PPSCoP.
4. Strict proof that the Notice to Keeper complies with the Protection of Freedoms Act 2012 (PoFA), if the operator is attempting to rely on keeper liability. Any failure to
comply with the mandatory wording or timelines in Schedule 4 of PoFA renders keeper liability unenforceable
5. Strict proof that the NtK was posted in time for it to have been given within the relevant period. The PPSCoP section 8.1.2(d) Note 2 requires that the operator must retain a record of the date of posting of a notice, not simply of that notice having been generated (e.g. the date that any third-party Mail Consolidator actually put it in the postal system.)
6. The IAS claims that its assessors are "qualified solicitors or barristers." Yet there is no way to verify this. Decisions are unsigned, anonymised, and unpublished. There is no transparency, no register of assessors, and no way for a motorist to assess the legal credibility of the individual supposedly adjudicating their appeal. If the person reading this really is legally qualified, they will know that without strict proof of landowner authority (VCS v HMRC [2013] EWCA Civ 186), no claim can succeed. They will also know that clear and prominent signage is a prerequisite for contract formation (ParkingEye v Beavis [2015] UKSC 67), and that keeper liability under PoFA is only available where strict statutory conditions are met.
If the assessor chooses to overlook these legal requirements and accept vague assertions or redacted documents from the operator, that will speak for itself-and lend further weight to the growing concern that this appeals service is neither independent nor genuinely legally qualified.
In short, I dispute this charge in its entirety and require full evidence of compliance with the law, industry codes of practice, and basic contractual principles.
However I didn't realise that this didn't go through to an Adjudicator and that EURO PARKING SERVICE were allowed to respond to this.
Their response was as follows
The operator made their Prima Facie Case on 21/05/2026 09:41:22.
The operator reported that...
The appellant was the driver.
The appellant was the keeper.
The operator is seeking keeper liability in accordance with PoFA..
ANPR/CCTV was used.
The Notice to Keeper was sent on 24/03/2026.
A response was received from the Notice to Keeper.
The ticket was issued on 21/03/2026.
The Notice to Keeper (ANPR) was sent in accordance with PoFA.
The charge is based in Contract.
The operator made the following comments...
There are multiple signages displayed on the site for the motorists to view and acknowledged the site regulations. (see evidence attached).As per the signages it is clearly mentioned that the motorist needs to enter the VRM into the kiosk while being in the car premises. (see evidence attached).The Landowner authority is not public information and this does not have to be disclosed.however, please be advised that all correspondence was issued in a timely manner. The IAS has access to this should the appeal go to this stage.The motorist has failed to comply with the site regulations during their stay in the car park. It is the sole responsibility of motorist to get their vehicle whitelisted so that it complies with the site regulations and which shall make it not liable for the Parking Charge notice. (see evidence attached)
Do I appeal to the Arbitration and do I use my initial appeal or something different. Sorry I'm panicking now
Any advice for be greatly appreciated. Thank you
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Also adding that the office blocks are closed at the time of the alleged contravention so no where to enter VRN.
I wouldn't add this point as it doesn't particularly support your case - the counterpoint to it is that if a driver is unable to comply with the terms on offer then he should leave.
Have a look at some other IAS appeals but they will essentially be more thorough versions of your initial appeal.
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https://ibb.co/v4yz6DXp
Hi,
I received a response from Euro Parking Service that my appeal has been unsuccessful and that I should pay in full or submit an appeal to the independent Appeals Service (IAS).
Do I raise the same points as my original appeal? Also adding that the office blocks are closed at the time of the alleged contravention so no where to enter VRN.
Any advice on the approach to this would be greatly appreciated.
Thank you
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hmmm sign say enter details in "Kiosk inside"
what "kiosk" and "inside" where??
33 Darkes lane covers the whole building with multiple businesses with separate entrances. all of which are closed at night.
Appreciate you response mickR, I have already submitted the appeal but that is a very good point everything is shut along there after midnight so no 'kiosk' Maybe I can use that further down the line if they don't cancel the PCN.
Thank you
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That should do for the initial appeal.
Thank you DWMB2, I have submitted the appeal. I'll will post once I hear back.
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hmmm sign say enter details in "Kiosk inside"
what "kiosk" and "inside" where??
33 Darkes lane covers the whole building with multiple businesses with separate entrances. all of which are closed at night.
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That should do for the initial appeal.
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If you show us a draft appeal we can advise. I'd do so as the keeper, focus on insufficient signage, and mention that is the signage on the site is prohibitive insofar as it does not offer a contract to park to non permit holders.
@DWMB2
H, I was wondering if the draft appeal that I have posted below is ok to send to Euro parking services?
Thank you
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Thank you for your replying to me DWMB2 and appreciate your advice. I did notice EPS have made an error on location so have included that point on the appeal too.
This is the draft appeal
Dear Euro Parking Services,
I am the registered keeper of vehicle [registration] and I am writing to formally appeal the Parking Charge Notice referenced above. You allege “Parking on the premises whilst failing to enter the vehicle registration number at the kiosk”. I dispute this charge in full. My grounds for appeal are as follows:
1. No signage at the entrance and inadequate visibility of on site signs
There is no signage at the entrance to the Service Road indicating that it is a controlled or managed parking area. The only sign present is mounted on a wall and is obstructed by large commercial wheelie bins, making it impossible to see from a low vehicle, particularly when the vehicle is not facing the sign. The area is also poorly lit after midnight, further reducing visibility. Because the signage is neither prominent nor legible, no contract could have been formed.
2. The signage is prohibitive and does not offer a contract to park
The wording on the signage is prohibitive, stating that parking is for permit holders only. Prohibitive signage cannot form a contract with a driver who is not permitted to park. Instead, it amounts to a notice of trespass, which only the landowner—not a parking operator—can pursue. As no contractual offer was made, no parking charge is enforceable.
3. Incorrect location details on the Notice to Keeper
The Notice to Keeper states the location as: “Service Road (33 Darkes Lane) The Service Rd, Buckinghamshire, EN6 1QA.” This is factually incorrect. EN6 1QA is in Hertfordshire, not Buckinghamshire. Issuing a Notice to Keeper with incorrect location details is a material error.
For the reasons above—lack of entrance signage, prohibitive wording, and incorrect location details—the Parking Charge Notice is invalid and must be cancelled. Please confirm cancellation in writing.
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If you show us a draft appeal we can advise. I'd do so as the keeper, focus on insufficient signage, and mention that is the signage on the site is prohibitive insofar as it does not offer a contract to park to non permit holders.
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Hi,
Would anyone be able to give me some much needed advice on this please, I would be very grateful. It is coming up to the 28 days to appeal. Not sure if I should appeal on the basis that there is no clear signage.
Thank you
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Hi,
I was wondering if anyone could assist me with this PCN please?
Thank you
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[quote author=cm6578 link=topic=10434.msg115173#msg115173 date=1775229020
Sorry I know I posted this above but have now read the forum guide.
My Son received a Notice to keeper from Euro Parking services.
The PCN is for parking on a premises whilst failing to enter the VRN at the kiosk.
The driver stopped in a parking space on a service road after midnight whilst waiting for a friend. There were no signs as you entered the service Road. There was a sign on the building wall but the sign isn't clearly visible from the drivers point of view as there are big bins in front of it.
It was gone midnight and any kiosks would have been shut for the driver to enter any VRN. We have until the 7th April to either pay the reduced amount or appeal.
Any advice, help, I would be grateful
This is the entrance to the service road. The driver stopped in one of the bays on the left
https://maps.app.goo.gl/UPdCDFz6D6tQsxKj9
https://ibb.co/cXQQGckt
https://ibb.co/x8LK3N4Z
https://ibb.co/7JyXGX9y
https://ibb.co/8LyCYfk7
https://ibb.co/TDC8bjpT
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https://postimg.cc/8J0vzNxF
https://postimg.cc/B8wbxNpw
https://postimg.cc/qzX7mpQG
https://postimg.cc/7CbYY04X
https://postimg.cc/WdN1CxHL
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https://www.ftla.uk/private-parking-tickets/read-this-first-private-parking-charges-forum-guide/
Airports are not “relevant land” under https://www.legislation.gov.uk/ukpga/2012/9/schedule/4
It’s unlikely, but not impossible, that this applies to your latest PCN. If you follow the advice above we can advise.
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Hi,
Received a PCN from Euro Parking services.
The driver stopped in a parking space on a service road after midnight whilst waiting for a friend. There were no signs as you entered the service Road. There was a sign on the building wall but the sign isn't clearly visible from the drivers point of view as there are big bins in front of it.
Can I appeal and use the Schedule 4 of the Protection of Freedoms Act 2012 which I have used for APCOA Stansted airport in the past and have had the parking charge cancelled
Or should I appeal that no clear signs.
Any advice, help, I would be grateful