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General discussion => The Flame Pit => Topic started by: b789 on December 22, 2024, 04:45:55 pm

Title: Re: Can a private company initiate a criminal prosecution under the SJP?
Post by: roythebus on December 29, 2024, 11:22:34 am
To quote above,  "Under railway bylaw 14, only the TOC prosecutor or an authorised agent can initiate criminal enforcement. If a breach of bylaw 14 occurs, the TOC decides whether to prosecute. If prosecution proceeds, it must be under the Single Justice Procedure (SJP) in the Magistrates’ Court."  Do we know if the parking company is an "authorised agent" like a firm of solicitors might be or as they are for local authorities?
Title: Re: Can a private company initiate a criminal prosecution under the SJP?
Post by: Southpaw82 on December 24, 2024, 09:35:51 pm
Does that person have to have any formal or legal training to be able to act as a prosecutor?

Not unless they’re acting for someone else.

Quote
Does the prosecutor lay the information to the court that they are intending to prosecute the defendant for beaching railway bylaw 14.2 under bylaw 24(1) even though they are not an "authorised prosecutor"?

Yes.

Quote
I'm assuming that APCOA would need authorisation from the TOC to initiate the prosecution. How would the court view the fact that the TOC are not taking the lead?

No. Unless there are restrictions on who can prosecute, anyone can prosecute without the need for any permission.

Quote
Would the contract APCOA have with the TOC to manage the car park have to specify exactly what authorisation it has to issue a PN under railway bylaws and specify how prosecution of those PNs takes place?

No, for the same reason given above. I could prosecute if I wanted to and I have no contract with the TOC.
Title: Re: Can a private company initiate a criminal prosecution under the SJP?
Post by: b789 on December 24, 2024, 08:48:27 pm
OK. So, assuming if APCOA wanted to actually prosecute their PN themselves rather than handing it to the TOC to prosecute, someone from the private company has to act as the prosecutor. Does that person have to have any formal or legal training to be able to act as a prosecutor?

Does the prosecutor lay the information to the court that they are intending to prosecute the defendant for beaching railway bylaw 14.2 under bylaw 24(1) even though they are not an "authorised prosecutor"?

I'm assuming that APCOA would need authorisation from the TOC to initiate the prosecution. How would the court view the fact that the TOC are not taking the lead?

Would the contract APCOA have with the TOC to manage the car park have to specify exactly what authorisation it has to issue a PN under railway bylaws and specify how prosecution of those PNs takes place? As I mentioned earlier, I have not yet seen any contract that APCOA has with a TOC that mentions PNs, only Parking Charge Notices and that was due to them mistakenly not submitting their usual "letter of authority confirmation" that POPLA take as sufficient evidence of authorisation.
Title: Re: Can a private company initiate a criminal prosecution under the SJP?
Post by: Southpaw82 on December 24, 2024, 06:52:05 pm
If I now understand correctly, if a "private" prosecutor lays an information to the court, no SJPN is issued. Is a summons then issued by the court instead?

Bingo.
Title: Re: Can a private company initiate a criminal prosecution under the SJP?
Post by: b789 on December 24, 2024, 06:34:31 pm
I am trying to understand what has been written but the waters keep getting muddied by some terminology. For example you mention "authorised prosecutor" and "private prosecutor". Is a "private prosecutor" not the same?

So far we have "private", "public" and now "authorised" prosecutors.

If I now understand correctly, if a "private" prosecutor lays an information to the court, no SJPN is issued. Is a summons then issued by the court instead?

I am simply trying to understand the exact process the private parking company would have to follow in order to obtain a private prosecution in the magistrates court for a minor parking offence which is in breach of the railway bylaws.
Title: Re: Can a private company initiate a criminal prosecution under the SJP?
Post by: Southpaw82 on December 24, 2024, 06:22:34 pm
So let me get this straight... the prosecutor, public or private, submits the "written charge" to the court and serves an SJPN to the defendant. The defendant responds (guilty plea, not guilty plea, or no response). If no plea is entered, the magistrate may decide the case on the papers. If the defendant pleads not guilty, the case is transferred to a full Magistrates’ Court hearing.

Could a private prosecutor issue a "postal requisition"? Isn't this basically a court "summons" and requires the defendant to attend a court hearing in person? Does this require the courts permission before it can be issued?

No. You really need to read what has been written. Only an authorised prosecutor can issue a written charge. A written charge is a prerequisite for a requisition or SJPN. Ergo, no SJPN can follow where an information has been laid, i.e. by a private prosecutor.

Equally, a court issuing a summons will not generally attempt to apply the Code Test for Crown Prosecutors, because that usurps the function of the prosecutor. There is no different standard between a private prosecutor and a “proper” prosecutor (at least as far as the law is concerned).
Title: Re: Can a private company initiate a criminal prosecution under the SJP?
Post by: andy_foster on December 24, 2024, 05:14:29 pm
Drugs are bad, m'kay?
Title: Re: Can a private company initiate a criminal prosecution under the SJP?
Post by: b789 on December 24, 2024, 04:52:48 pm
So let me get this straight... the prosecutor, public or private, submits the "written charge" to the court and serves an SJPN to the defendant. The defendant responds (guilty plea, not guilty plea, or no response). If no plea is entered, the magistrate may decide the case on the papers. If the defendant pleads not guilty, the case is transferred to a full Magistrates’ Court hearing.

Could a private prosecutor issue a "postal requisition"? Isn't this basically a court "summons" and requires the defendant to attend a court hearing in person? Does this require the courts permission before it can be issued?
Title: Re: Can a private company initiate a criminal prosecution under the SJP?
Post by: andy_foster on December 24, 2024, 04:25:10 pm
Public prosecutors cannot lay an information. They can only issue a Written Charge and SJPN or Postal Requisition. Others can only lay an information. AFAIK the SJP is exclusive to cases instigated by way of SJPN.
Title: Re: Can a private company initiate a criminal prosecution under the SJP?
Post by: 666 on December 24, 2024, 04:22:56 pm

They would have to "lay an information" to the court and only if the court is satisfied that the case is suitable for the SJP process or requires a full hearing would it proceed. From what I can understand, cases brought by Public Prosecutors for minor offences are commonly handled under the SJP. However, are Private prosecutions different? Should courts be more cautious about using the SJP for private prosecutions because the process is less transparent and private prosecutors should be subject to stricter scrutiny to ensure fairness?

Under the SJP, all cases where a NOT guilty plea is entered are automatically referred to a full court hearing, so there should be no concerns over transparency or fairness.
Title: Re: Can a private company initiate a criminal prosecution under the SJP?
Post by: b789 on December 24, 2024, 04:09:26 pm
So the parking company or even a private individual could "lay an information" (I live and learn) but surely it would rely on whether the court believed it serves the public interest and that there is a realistic prospect of conviction? Surely a minor parking violation is unlikely to be seen as a serious offence unless it causes significant disruption, danger, or financial loss.

Do magistrates not take into consideration the waste of time and resources, especially f the alleged parking contravention posed no real harm or inconvenience to others? Don't they have to consider whether cases are  worthy of court time? Using criminal prosecution for a trivial matter surely must be viewed as disproportionate, or are we dealing with the "judge bingo" we occasionally see in the county court?

Could it backfire on the "private prosecutor" if the case is considered to be deemed frivolous, vexatious, or without merit? A minor and isolated parking issue with no significant consequences should be seen as an inappropriate use of the court’s time. Prosecuting minor parking infractions in criminal court risks being perceived as overzealous or petty, especially if it imposes unnecessary burdens on the legal system.

Finally, as there would be no financial benefit for the private company, can anyone ever see a firm like APCOA or SABA actually spending time and resources on an action with no guaranteed outcome and, even if successful, would not earn them a penny and most likely would cost them substantially?

So, the answer to my initial question is "yes, they can". However, in the three or four years I've been dealing with Parking Charge Notices from unregulated private parking companies, only APCOA and SABA have issued Penalty Notices for alleged breaches of railway bylaws and I have not come across a single one that has ever been prosecuted in the magistrates court.

They would have to "lay an information" to the court and only if the court is satisfied that the case is suitable for the SJP process or requires a full hearing would it proceed. From what I can understand, cases brought by Public Prosecutors for minor offences are commonly handled under the SJP. However, are Private prosecutions different? Should courts be more cautious about using the SJP for private prosecutions because the process is less transparent and private prosecutors should be subject to stricter scrutiny to ensure fairness?

Even if the case were "approved", would a standard summons rather than an SJP notice be used? From what I can see, the SJP is typically reserved for public prosecutions or routine minor offences handled by government bodies.

Whilst they may be able to initiate a private prosecution, they have never (as far as I am aware and able to research) handed a case to the TOC to prosecute nor have they prosecuted one themselves. Their greed far outweighs any public interest or concern for the law for them to have an ounce of altruism. They are not used to having to provide evidence that has to prove beyond a reasonable doubt that the recipient of their fake PN has broken any law, civil or criminal.
Title: Re: Can a private company initiate a criminal prosecution under the SJP?
Post by: cp8759 on December 24, 2024, 12:39:58 pm
The point of my question was how can the unregulated private parking company (UPPC) "initiate" a private prosecution in the magistrates court (under the SJP or otherwise) and that has been answered, thank you. They can't.
Not sure that's correct, as far as I'm aware they can lay an information and obtain a summons, just as you could.
Title: Re: Can a private company initiate a criminal prosecution under the SJP?
Post by: roythebus on December 23, 2024, 11:45:48 pm
Yes. Councils are not railway land covered by railway byelaws.
Title: Re: Can a private company initiate a criminal prosecution under the SJP?
Post by: NewJudge on December 23, 2024, 08:24:34 pm
Then the best thing that TOCs can do is to simply cease the nonsense with their "Penalty Charges" (or whatever they call them), employ somebody to patrol their car parks to tell them when somebody has broken their rules and simply move straight to prosecution with all the people who break their parking bylaws. Because if they'd done that with the "live" case, we would not be having this discussion.

The complication arises because they kindly give the miscreants the chance to pay a bribe so as to avoid prosecution. They have no need to do this but all the alleged miscreants have to do if they don't like the look of it is to simply ignore it.

Quite why some of them complicate it even further by introducing a civil arbitration process to resolve an allegation of a criminal offence is a complete mystery.

Of course the simplest way to resolve this is to remove from the TOCs their recourse to criminal proceedings for something which, virtually everywhere else, is a civil matter.

As for bribery and corruption, as Andy often tells us, the police in England & Wales operate a very profitable scheme offering those accused of some minor traffic offences the chance to avoid prosecution by paying for an educational course from which they receive a very generous cut.
Title: Re: Can a private company initiate a criminal prosecution under the SJP?
Post by: b789 on December 23, 2024, 07:43:15 pm
Yes, but it's -15 outside and snowing so I have time to kill.

I still want to give APCOA/SABA the BPA and POPLA their comeuppance for their unlawful actions and extortion though.
Title: Re: Can a private company initiate a criminal prosecution under the SJP?
Post by: andy_foster on December 23, 2024, 07:19:11 pm
So, in a nutshell, LAs can delegate issuing of penalty notices to PPCs because DPE operates under civil law and there is an appeals process, but TOCs can't delegate issuing of penalty notices to PPCs because the bylaws operate under criminal law? But using a lot more words.
Title: Re: Can a private company initiate a criminal prosecution under the SJP?
Post by: b789 on December 23, 2024, 06:56:32 pm
Playing Devil's Advocate - PPCs often issue Penalty Charge Notices on behalf of LAs. Is this any different?

Yes, there is a significant difference between Penalty Charge Notices (PCNs) issued by private parking companies (PPCs) on behalf of Local Authorities (LAs) and purported Penalty Notices issued by PPCs under other circumstances, such as for railway byelaw breaches or private land parking enforcement.

When PPCs issue Penalty Charge Notices on behalf of Local Authorities, they are acting under the statutory powers delegated to the LA, typically under the Traffic Management Act 2004 (TMA 2004) in England and Wales or Road Traffic Regulation Act 1984 or other legislation applicable to the relevant area.

These notices are lawful because they are issued under the authority of public law and relate to enforceable statutory regulations (e.g., parking restrictions, controlled zones).

PCNs issued by or on behalf of LAs are part of the civil enforcement system, but they carry statutory backing. Recipients who wish to contest the notice can appeal to the Traffic Penalty Tribunal (TPT) in England and Wales or the Parking and Bus Lane Tribunal for Scotland in Scotland.

If the notice is upheld and the charge remains unpaid, it can be enforced through the Traffic Enforcement Centre (TEC) or equivalent, leading to debt recovery action. Any penalty collected from a PCN issued under LA authority goes to the Local Authority and is reinvested in public infrastructure, transportation improvements, or other community benefits. PPCs issuing these notices do not retain the fines as profit but are paid a fee by the LA for their management services.

The process for handling Penalty Charge Notices (PCNs) issued by Local Authorities (LAs) is firmly rooted in civil law, not criminal law, and any disputes or enforcement related to PCNs are managed through the County Court system rather than the Magistrates' Court.

If the recipient neither pays the penalty nor appeals successfully, the enforcement process moves forward as a civil matter:

a. Charge Certificate

If no payment is made after the PCN becomes enforceable, the LA issues a Charge Certificate, increasing the penalty amount (typically by 50%).

b. Registration as a Civil Debt

If payment is still not made, the LA can register the debt at the Traffic Enforcement Centre (TEC), which operates as part of the County Court system (not the Magistrates' Court).

Once registered, the PCN is treated as a civil debt, similar to any unpaid invoice or financial liability.

c. Enforcement via County Court

The LA can apply for a warrant of control to enforce the debt through civil means, such as instructing bailiffs (enforcement agents) to recover the outstanding amount.

Importantly, this is a civil enforcement action. No criminal record or criminal penalties are involved.
Title: Re: Can a private company initiate a criminal prosecution under the SJP?
Post by: andy_foster on December 23, 2024, 06:45:17 pm
Playing Devil's Advocate - PPCs often issue Penalty Charge Notices on behalf of LAs. Is this any different?
Title: Re: Can a private company initiate a criminal prosecution under the SJP?
Post by: b789 on December 23, 2024, 06:36:50 pm
The point of my question was how can the unregulated private parking company (UPPC) "initiate" a private prosecution in the magistrates court (under the SJP or otherwise) and that has been answered, thank you. They can't.

If the UPPC wants to enforce the PN, they can only do so by referring it to the TOC prosecutor who would then be able to prosecute it through the SJP, should they decide to do so and they are within the 6 month statute of limitation.

Based on what has been commented on so far, as I understand it, a private company cannot issue a legitimate Penalty Notice (PN) under railway bylaw 14 because it lacks the statutory authority required to do so. Only the Train Operating Company (TOC) or an authorised prosecutor acting on behalf of the TOC has the legal authority to enforce railway bylaw breaches through the Single Justice Procedure (SJP) or other criminal court proceedings.

If a private parking company issues a notice purporting to be a Penalty Notice under railway byelaws, surely this amounts to misrepresentation. Using terms like "Penalty Notice" or implying criminal liability (e.g., referring to "prosecution" or "Magistrates’ Court") is misleading if the notice is not issued by an authorised prosecutor or TOC.

If the notice implies criminal consequences or statutory enforcement powers that the private company does not possess, it breaches the Consumer Protection from Unfair Trading Regulations 2008. Also, it is making a false representation with intent to cause loss or gain which is a breach of the Fraud Act 2006 (Section 2).

A private company issuing what it claims to be a Penalty Notice under railway bylaw 14 is acting beyond its authority. Such a notice must be legally invalid, as only the TOC or its authorised prosecutor can issue and enforce Penalty Notices under railway byelaws. Any such misuse of the term "Penalty Notice" by a private company can only be considered as misleading or unlawful.

So, it all comes back to my point that the UPPC, by issuing a purported PN, is in fact committing fraud. In other words, it is not a real PN but an "offered contract". An offered contract is a civil contract law matter and has nothing to do with criminal law.

The criminal extortion element is a serious issue with the potential misuse of authority by UPPCs. If a UPPC issues what it purports to be a PN for an alleged breach of railway bylaw 14, this can only amount to fraudulent or unlawful behaviour.

The use of language typically reserved for criminal enforcement in a notice issued by a private company, when the company lacks the authority to prosecute or enforce criminal penalties, surely meets the criteria for fraud under the Fraud Act 2006. Fraud by false representation occurs when someone dishonestly makes a false representation, intending to make a gain for themselves or cause a loss to another.

If the UPPC falsely represents the notice as a legitimate Penalty Notice under byelaw 14, this probably qualifies as fraud. The notice implies authority (e.g., potential criminal prosecution or fines), which the company does not have. The intent is to scare the recipient into paying money they do not legally owe to the UPPC.

By using intimidating language such as "fine," "offence," or "criminal prosecution," the UPPC exploits the recipient’s likely misunderstanding of the legal distinction between civil and criminal liability. This tactic can only be viewed as a form of extortion, as it pressures individuals into paying under the false pretence of avoiding criminal consequences. Such behaviour not only violates consumer protection laws but also constitute criminal misconduct.

Under railway bylaw 14, only the TOC prosecutor or an authorised agent can initiate criminal enforcement. If a breach of bylaw 14 occurs, the TOC decides whether to prosecute. If prosecution proceeds, it must be under the Single Justice Procedure (SJP) in the Magistrates’ Court.

Any fine imposed by the court is paid into the public purse, not retained by the TOC or any private contractor. A UPPC issuing a "Penalty Notice" bypasses this legal framework and improperly seeks to profit directly from the alleged breach, which subverts the intention of the byelaws (to regulate conduct on railway land, not to generate private revenue) and deprives the public purse of funds that should rightfully flow through the judicial process.

The language used in a real Penalty Notice issued under criminal law must reflect the statutory framework, including the nature of the offence and potential court proceedings. A private company issuing a notice for what is, at best, an "offered contract" cannot lawfully use terms such as "Fine" which is reserved for criminal penalties, "Offence" which implies criminal wrongdoing or "Criminal prosecution" which suggests the involvement of criminal courts, which a UPPC cannot initiate. In a civil contract dispute, the private company must use neutral language (e.g., "Parking Charge Notice" or "charge"), clearly explaining the basis of the claim without implying criminal liability.

Another key distinction in railway bylaw enforcement is that any fines resulting from criminal prosecutions go to the public purse. If a UPPC issues a notice and retains the funds, it misrepresents the nature of the enforcement, redirects funds from their intended destination (public coffers) into private profits which clear abuse of the byelaw framework, undermining the public interest and the legal integrity of the railway bylaw enforcement system.

In conclusion, an unregulated private parking company issuing a purported "Penalty Notice" under railway bylaw 14 is acting unlawfully. Such notices are inherently fake, as only a TOC prosecutor has the authority to issue them and initiate proceedings under the SJP. Any language implying criminal liability or penalties is misleading and constitutes fraud or extortion. Furthermore, since fines under the byelaws are intended for the public purse, the UPPC’s actions divert funds improperly for private gain.

This conduct must be legally challengeable, and recipients of such notices would be justified in treating them as invalid and reporting the matter to the relevant authorities.

What I would like to know, is how could I initiate the necessary action to get the appropriate authorities alerted to this fraudulent and extortionate behaviour? I would like to do so as I have the time and some resources available but short of going out and deliberately getting one of these fake PNs issued to me personally, I am at a loss.
Title: Re: Can a private company initiate a criminal prosecution under the SJP?
Post by: andy_foster on December 23, 2024, 06:18:46 pm
In general, and more apropos the case referred to in the live cases forum, where there is seemingly a strong meritorious defence on the facts of the case, and a seemingly stronger technical defence which would tend to suggest that a provision is a dead letter, I would very much be minded not to disregard the meritorious defence in pursuit of the loophole defence.

Courts of all levels have shown a propensity to inflict as much violence as necessary to the language of a provision to achieve what they consider to be a just outcome. Whilst they often do not do this, it is never safe to assume that they won't, although if the DC or above has already ruled on the matter [with a rational interpretation] such an assumption is somewhat safer.
Title: Re: Can a private company initiate a criminal prosecution under the SJP?
Post by: NewJudge on December 23, 2024, 05:40:46 pm
All of the above is all fine and dandy - if the motorist agrees to arbitration. He has no requirement to do so. Whether or not he should depends upon the circumstances he finds himself in.

If he does and it goes against him (as I believe it might have in the case of our friend in the "Live Cases" forum) all he has to do is to refuse to pay. He will then be prosecuted where the charge will have to be proved to the criminal standard. The court will not be interested in any deficiencies in any penalty notices as there is no requirement to provide any. It will not be able to make assumptions about the owner/registered keeper/person in charge. The status of the person charged will have to be proved as required.

All the information you have provided relates to private parking companies, their responsibilities to issue the correct documentation to levy penalty charges and the arbitration services associated with that. None of it has any bearing on criminal prosecutions and that's where these cases end up if they remain unsettled.

 
Title: Re: Can a private company initiate a criminal prosecution under the SJP?
Post by: b789 on December 23, 2024, 04:14:37 pm
Of course the BPA would like railway land to become "relevant land" for the purposes of PoFA. However, I attach below the response I received from POPLA when I queried their right to adjudicate on Penalty Notices issued by APCOA and SABA.

POPLA claim that they queried this with the DfT in 2018 and the attached a copy of their communication saying (paraphrasing) "The DfT told us we can so we do!"

(https://i.imgur.com/tJEVKYu.jpeg)
(https://imgur.com/D4BZGI0.jpeg)
(https://imgur.com/7ZJZzp4.jpeg)
(https://imgur.com/akBncMM.jpeg)
(https://imgur.com/GlmZPKf.jpeg)

Any highlighting mine. I believe that POPLA have chosen to make their own interpretation of the recommendation by the DfT because of the misuse of the word "penalty" in this sentence in their response:

Quote
Further, it is stated in by byelaw 14(4)(i) that the owner of a vehicle may be liable to pay a penalty if it has been used, placed or left in contravention of byelaws 14(1) to (3).

In the next sentence, the DfT state:

Quote
The ability to render a charge under byelaw 14(4)(i) is distinct from the general enforcement power in byelaw 24(1), under which a person can be prosecuted in the Magistrates Courts.

The DfT use of the term "penalty" in reference to byelaw 14(4)(i) appears to be a misnomer. In context, it seems intended to refer to a "charge" rather than an actual "penalty" as defined under the railway byelaws. This interpretation is supported by their subsequent clarification:

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"The ability to render a charge under byelaw 14(4)(i) is distinct from the general enforcement power in byelaw 24(1), under which a person can be prosecuted in the Magistrates' Court."

This statement indicates that while a private parking company, if contracted, may issue a "charge" (such as a Parking Charge Notice or PCN) for breaches of railway byelaws, this is entirely separate from the enforcement of penalties through criminal proceedings in the Magistrates' Court. Consequently, the use of the term "penalty" in the context of byelaw 14(4)(i) should not be conflated with the formal penalties enforceable under byelaw 24(1). This distinction is critical, as it underscores the limited powers of private parking companies and highlights that any charges they issue are not equivalent to criminal penalties.


The term "penalty" is being used in two distinctly different contexts, which creates confusion as it is not clearly differentiated:

Under Byelaw 14(4)(i):

Here, the word "penalty" is seemingly being used to describe a civil charge (e.g., a Parking Charge Notice) that may be issued by a private parking company. This usage does not imply a criminal sanction but rather an invoice-like demand for payment, enforceable only through civil proceedings (e.g., small claims track of the county court). This form of "penalty" is essentially a contractual mechanism to deter undesirable behaviour, such as parking in breach of terms and conditions.

Under Byelaw 24(1):

In this context, "penalty" refers explicitly to a criminal offence, enforceable through prosecution in a Magistrates' Court. This type of penalty carries potential legal consequences beyond a mere financial charge, such as a criminal record or fines imposed by the court.

The distinction lies in the nature of enforcement and consequences:

• A civil charge is a financial liability imposed privately, for breaching terms and conditions, and does not carry criminal implications.

• A criminal penalty involves formal legal proceedings, potential prosecution, and the imposition of sanctions by the judicial system.
Title: Re: Can a private company initiate a criminal prosecution under the SJP?
Post by: NewJudge on December 23, 2024, 02:39:29 pm
Quote
The TOC will receive no money whether the motorist is found guilty or not guilty.

Yes good point, nigel. But I do note they ask for £175 costs, which is getting on for double the amount the CPS or police ask for in straightforward prosecutions. So I imagine the TOC gets a few quid somehow or other (provided the court sees fit to award that full amount, of course).

I think this issue is being made unnecessarily complicated and I don’t really know whose fault it is.

The bottom line is that parking transgressions on railway land are criminal offences. As such they can be ultimately enforced only by the criminal  (i.e. magistrates’) court. To do that the TOCs do not need to employ parking companies at all. They can simply employ staff to check their car parks. When an offence is suspected, all they need to do is nothing, except prosecute the suspected offender through the court using the Single Justice Procedure. The TOCs are authorised to do this and they have six months from the date of the alleged offence to do so. No other notice is necessary.

Where it becomes complicated is when the TOCs do engage private parking companies and they, on behalf of the TOC, suggest they will accept a payment to avoid criminal proceedings being taken.

In the case on the “live cases” board, the only notice the motorist received was just that offer – “pay us £60/£30 and we’ll say no more about it”. That was ignored so criminal proceedings began. That, in my view, is how it should be. That said, I do think that the notice could have set out the consequences of ignoring it, though it may have done so (I don’t believe we saw all of it). There should be no mention of recourse to POPLA or any other adjudicator. The only adjudication that should be available is that provided by the Magistrates’ Court.

The case posted on this thread is clearly different to that. ACPOA has taken it upon itself to confuse the legal position. It suggests that an appeal “must” be made firstly via their own appeals procedure and, if the recipient is dissatisfied, to POPLA. If the end result of these processes go against the motorist and the penalty remains unpaid, ACPOA (say) they will take action in the Magistrates’ Court by way of a private prosecution.

What they don’t say is that they not empowered to do this (certainly not under the SJ procedure) and if a prosecution is to be launched it can only come from the TOC.

In my view, this procedure (appeals via adjudicators and then a prosecution) is unfair. If an appeal is to go to adjudicators then enforcement of payment should remain with that process (I’m not sure how that enforcement works, presumably via the County Court). But in any case, I don’t believe the adjudication process has any place in deciding whether or not a criminal offence has been proved. I believe that adjudicators make their decisions on “the balance of probabilities”. They also make assumptions which would not be valid in a criminal court. One of particular concern is (according to POPLA) that the Registered Keeper is assumed to be the owner unless proved otherwise. This leaves the prosecution enjoying this presumption and places the burden on the defendant to disprove one of the elements of the offence which has merely been assumed, not proven. A criminal court cannot make such an assumption.

All in all, it is quite a mess. The TOCs can tidy it up by simply instructing their parking agents to issue the offer of a fixed penalty in lieu of prosecution, accompanied by a simple warning that if it isn’t accepted then the matter will be decided in the Magistrates’ Court

EDIT: I also found his, which dates from 2020:

https://www.britishparking-media.co.uk/news/on-the-right-track-bpa-welcomes-changes-to-managing-parking-on-railway-land

It contains recommendations to clarify the position on these matters. I don't believe any of those recommendations have been implemented.
Title: Re: Can a private company initiate a criminal prosecution under the SJP?
Post by: DWMB2 on December 23, 2024, 10:12:41 am
POPLA refuse to adjudicate on PCNs issue under Railway Bylaws.
POPLA's website (https://www.popla.co.uk/faqs#535CHPaixoD1uJbAFGkV4d) says otherwise:

I have received a penalty charge notice for an alleged breach of parking conditions under bylaws. Can POPLA consider this?

POPLA does have remit to consider penalty charge notices issued for alleged breaches of parking conditions under bylaws. You must appeal to the parking operator first and they will refer you to POPLA and provide a verification code to you if you're eligible to apply. Please check the response to your appeal sent by the operator for more details.
Title: Re: Can a private company initiate a criminal prosecution under the SJP?
Post by: nigelbb on December 23, 2024, 07:39:59 am
Both APCOA and SABA are BPA members and offer a secondary "independent" appeals service through POPLA should the initial appeal to the operator be rejected. However, I do not believe that POPLA have the authority to adjudicate on PNs which are (if they were real ones) criminal matters. As these fake PNs are nothing more than "offered contracts" (under civil law), there is no obligation on anyone to accept an offered contract under any circumstances.

POPLA refuse to adjudicate on PCNs issue under Railway Bylaws.
Title: Re: Can a private company initiate a criminal prosecution under the SJP?
Post by: nigelbb on December 23, 2024, 07:36:38 am
But the principle is the same, whoever operates the first ("give us £100...") part.

If the TOCs undertake both parts they are no different to the police who might firstly offer a course or fixed penalty and then prosecute when they are not taken up.

Quote
In other words, they are asking for a bribe in order not to criminally prosecute them.

That's certainly one way of putting it.

I know virtually nothing about decriminalised processes and procedures so cannot comment on the deficiencies you mention. But the important thing with these railway offences is that they are not decriminalised. They are not subject to review or adjudication. If he motorist does not pay the bribe, the only way the TOC can get paid is to prosecute him through the magistrates' court.

So the rules and protocols pertinent to the decriminalised offences do not apply.

If the motorist is fined in the magistrates court the fine goes into government coffers. The TOC will receive no money whether the motorist is found guilty or not guilty.
Title: Re: Can a private company initiate a criminal prosecution under the SJP?
Post by: b789 on December 22, 2024, 10:30:04 pm
I understand that should APCOA decide to force prosecution of the alleged breach of the railway bylaw, they could only do so if they hand the case to the TOC and it is then up to the prosecutor for that TOC to initiate the SJP prosecution. However, that is not what is being threatened in the supposed "PN" that I have shown

Please correct me where I am wrong and may be misunderstanding the law but the notice I have shown, refers to itself as a Penalty Notice, suggesting it is issued under statutory authority (such as a penalty issued by a local council or a government body). However, APCOA is a private company. Penalty Notices under Railway Byelaws must be issued by or on behalf of the relevant train operating company (TOC) or station operator. APCOA does not specify that it is acting directly under the authority of the TOC or any other authority, which raises concerns about its legal basis.

The notice states that it is issued for a breach of Railway Byelaws (Byelaw 14) and implies that failure to pay could result in a criminal prosecution and a fine of up to £1,000. However, Railway Byelaw 14 has multiple subsections, each covering different aspects of parking-related offences (e.g., parking without payment, failing to display a ticket, or parking in a prohibited area). Without specifying the exact subsection, the notice fails to adequately inform the recipient of the alleged wrongdoing. This lack of detail makes it impossible for the recipient to fully understand the nature of the alleged offence, formulate a proper defence or appeal or assess whether the alleged breach genuinely applies.

This failure to provide sufficient detail must render the PN as unenforceable, because clarity is essential for both criminal and civil proceedings. Railway Byelaws require the issuing authority to clearly specify the nature of the breach and its legal basis. A vague reference to "Byelaw 14" does not meet this standard.

Only the train operating company or a properly authorised agent can initiate legal proceedings in the magistrates’ court. The notice fails to explicitly state that it is issued under the authority of the train operating company or railway operator responsible for enforcing the byelaws. Without this, the notice lacks credibility as an enforceable penalty under the byelaws.

The demand for payment (£100, reduced to £60 if paid within 14 days) blurs the line between a statutory penalty (under Railway Byelaws) and a private parking charge (a civil claim for breach of contract). If this is treated as a civil charge, APCOA would have to pursue the registered keeper (or driver) in a civil court, where different rules apply. They cannot simultaneously threaten prosecution under Byelaw 14.

Under the Magistrates’ Courts Act 1980, any prosecution under the byelaws must be initiated within six months of the alleged offence. If APCOA does not escalate the matter to the train operating company within this period, no prosecution can take place. However, the notice refers to an appeals process with APCOA and mentions POPLA (Parking on Private Land Appeals), which is irrelevant to statutory byelaws. Appeals related to Railway Byelaws must be directed to the relevant railway operator or magistrates’ court, not a private adjudicator like POPLA.

The notice is questionable as a "Penalty Notice" under Railway Byelaws because it does not clearly establish APCOA's authority to act on behalf of the train operating company. The document blurs the distinction between a statutory penalty (criminal law) and a private parking charge (civil law). This misleads recipients into paying without understanding their rights.
Title: Re: Can a private company initiate a criminal prosecution under the SJP?
Post by: DWMB2 on December 22, 2024, 09:47:40 pm
Quote
But the principle is the same
Agreed - the reason I was making the point is just because the practice doesn't necessarily reflect the principle with some TOCs.
Title: Re: Can a private company initiate a criminal prosecution under the SJP?
Post by: NewJudge on December 22, 2024, 09:36:19 pm
But the principle is the same, whoever operates the first ("give us £100...") part.

If the TOCs undertake both parts they are no different to the police who might firstly offer a course or fixed penalty and then prosecute when they are not taken up.

Quote
In other words, they are asking for a bribe in order not to criminally prosecute them.

That's certainly one way of putting it.

I know virtually nothing about decriminalised processes and procedures so cannot comment on the deficiencies you mention. But the important thing with these railway offences is that they are not decriminalised. They are not subject to review or adjudication. If he motorist does not pay the bribe, the only way the TOC can get paid is to prosecute him through the magistrates' court.

So the rules and protocols pertinent to the decriminalised offences do not apply.
Title: Re: Can a private company initiate a criminal prosecution under the SJP?
Post by: DWMB2 on December 22, 2024, 08:03:35 pm
Quote
but when the motorist does not stump up, the TOCs take over and, as authorised prosecutors, initiate a prosecution.
I'm not sure that they actually do, often if at all.

The TOCs who do prosecute (like Merseyrail, as seen in the live example in the Criminal forum) seem to manage the process themselves from the outset, rather than farming it out to APCOA or SABA.
Title: Re: Can a private company initiate a criminal prosecution under the SJP?
Post by: NewJudge on December 22, 2024, 07:37:16 pm
The answer to your question is that some private companies can initiate prosecutions under the SJP

Quote
I am fairly certain that neither APCOA nor SABA have ever initiated a private prosecution in the magistrates court.

I’m quite certain you are right. This is because those two bodies are not “authorised prosecutors” under the legislation covering the Single Justice Procedure. Railway Companies are. I checked that they were when the original question was raised because I was interested to see how the recent ruling by the Chief Magistrate (which nullified about 75,000 railway fare evasion prosecutions taken under the SJP) came about. I wondered whether these charges were also ineligible to use the SJP, but they are not and the prosecutions seem lawful.

I can understand you conflating the civil procedure and criminal prosecutions. The railway companies are in (so far as I can fathom) a unique position in that they seemingly operate what looks like a private parking enforcement regime. But if the charges from that remain unpaid, they have recourse to criminal prosecutions courtesy of their bylaws. 

As far as I can see, there is no requirement for the railway companies to operate a fixed penalty scheme or to operate out-of-court settlements (in the same way as there is no requirement for the police to offer courses or fixed penalties). They could simply prosecute all those who break their bylaws. But they don't.

Instead their strategy seems essentially to be along the lines of “give us a hundred quid and we won’t prosecute you”. They seem to employ parking companies to do that, but when the motorist does not stump up, the TOCs take over and, as authorised prosecutors, initiate a prosecution.

As a result, I don’t see how the validity of any notices under the “give us a hundred quid…” stage can effect or jeopardise a criminal prosecution. It’s similar to a speeding offence when the police offer a course or fixed penalty and neither are taken up. The police start a prosecution and all that went before in relation to the course or fixed penalty becomes  irrelevant.
Title: Can a private company initiate a criminal prosecution under the SJP?
Post by: b789 on December 22, 2024, 04:45:55 pm
Seeking learned opinion regarding unregulated private parking companies (UPPCs) threatening criminal prosecution under railway bylaws. There are at least two UPPCs, APCOA and SABA, who regularly issue what they purport to be Penalty Notices (PNs) issued under railway bylaws for parking infringements at railway stations where they are contracted to manage the parking.

Having recently been dealing with an actual PN issued by the Train Operating Company (TOC) where they have charged the defendant with a breach of railway bylaw 14.2 which states:

Quote
14.2 No person in charge of any motor vehicle, bicycle or other conveyance shall leave or place it on any part of the railway:

(i) in any manner or place where it may cause an
(ii) obstruction or hindrance to the Operator or any person using the railway; or
(iii) otherwise than in accordance with any instructions issued by or on behalf of the
Operator or an authorised person.

The TOC prosecutor has issued a charge under the SJP and the defendant has to now decide whether to plead guilty or not. The case is being discussed here:
Byelaws offence - Taken to magistrates for private parking ticket (https://www.ftla.uk/speeding-and-other-criminal-offences/sjp-for-private-parking-ticket/)

My question relates to the supposed PNs issued by UPPCs. As far as I can make out, the PN issued is not real. There is no mention in them of which authority they are acting under (no UPPC is an "authority" in any way, shape or form) except to say that the recipient has breached the railway bylaws and is liable to criminal prosecution in the magistrates court if they don't pay £100 into the UPPCs coffers.

In my opinion, the PN is fake and a fraudulent attempt to extort money from the recipient by way of coercion through unlawful terms in what can only be described as an "offered contract". In other words, they are asking for a bribe in order not to criminally prosecute them. I will attach a redacted example of a UPPC issued PN below.

Both APCOA and SABA are BPA members and offer a secondary "independent" appeals service through POPLA should the initial appeal to the operator be rejected. However, I do not believe that POPLA have the authority to adjudicate on PNs which are (if they were real ones) criminal matters. As these fake PNs are nothing more than "offered contracts" (under civil law), there is no obligation on anyone to accept an offered contract under any circumstances.

I am fairly certain that neither APCOA nor SABA have ever initiated a private prosecution in the magistrates court. Also, I have never seen one of these fake PNs sued over in the county court as a civil matter, because they can't. They are relying on the recipient to pay up out of ignorance and fear of criminal prosecution (when there is no chance of it).

So, does anyone have an opinion on how these UPPCs could initiate a criminal prosecution in the magistrates court, assuming they were to try and back up their unlawful threats in the "offered contract" disguised as a PN?

Here is an example of what I believe to be a fake (fraudulent) PN issued by APCOA:

(https://www.ftla.uk/index.php?action=dlattach;topic=4211.0;attach=9420;image)

(https://www.ftla.uk/index.php?action=dlattach;topic=4211.0;attach=9418;image)