Free Traffic Legal Advice

Live cases legal advice => Private parking tickets => Topic started by: BelfastBoy on January 16, 2025, 11:30:35 am

Title: Re: VCS @ Bristol Airport
Post by: b789 on December 21, 2025, 04:57:26 am
Probably. But they may try and resurrect it one day. Not that they can do much about it though.
Title: Re: VCS @ Bristol Airport
Post by: BelfastBoy on December 20, 2025, 08:23:44 pm
Update on this. I’ve not received any communications since March. Presumably, the DCBL crowd decided they couldn’t be bothered coming after an individual in Northern Ireland.
Title: Re: VCS @ Bristol Airport
Post by: BelfastBoy on February 20, 2025, 07:05:10 pm
That's fine.

I appreciate that you don't need to read debt recovery letters. However, I thought I would ask about this correspondence just to be sure.

Thanks for the clarity and ongoing advice.
Title: Re: VCS @ Bristol Airport
Post by: b789 on February 20, 2025, 06:54:08 pm
We don't need to read any correspondence from DCBL. You can safely ignore anything from them or any other Debt Recovery Agent (DRA). They are powerless to do anything except try and scare the low-hanging fruit on the gullible tree into paying out of ignorance and fear. Ignore them.

Yes, DCB Legal and DCBL are sister companies. However, DCBL are just debt collectors and are not a party to any contract allegedly breached by the driver and cannot do anything.

DCB Legal are an incompetent bulk litigator and you will at some sate receive a Letter of Claim (LoC) from them. When you do, show it to us. Ignore all DRA letters.
Title: Re: VCS @ Bristol Airport
Post by: BelfastBoy on February 20, 2025, 04:23:18 pm
I have now received a letter from DCBL.

I note that DBCL (https://dcblegal.co.uk/) and DCB Legal (https://dcblegal.co.uk/) are two sides of the same coin. I'm seeing in another post on this forum that the distinction is important.

Anyway, have a read of the correspondence pictured. I’d be grateful for your thoughts.

[attachment deleted by admin]
Title: Re: VCS @ Bristol Airport
Post by: BelfastBoy on January 20, 2025, 10:25:25 am
Thank you very much for posting such a detailed analysis. I'm afraid that these fairly complicated questions around byelaws are not going to be tested in a small-claims court, where the issue of whether or not a contract exists is much more likely to be considered.
Title: Re: VCS @ Bristol Airport
Post by: b789 on January 20, 2025, 07:10:56 am
I have been doing a bit more research into this issue of mixing enforcement of statutory and civil laws on land controlled by byelaws. Part of the issue is differences between the areas under control and differentiating between the roads and the car parks.

VCS operate at several airports besides Bristol, including Liverpool John Lennon Airport (LJLA) and Leeds Bradford Airport (LBA) where these issues crop up all the time.

Regulation 6.7 of the Liverpool John Lennon Airport (LJLA) Byelaws is an interesting focal point because it explicitly allows the airport operator to impose charges and conditions for parking. The interpretation of this regulation determines whether the terms and conditions established by a contracted parking operator like Vehicle Control Services (VCS) are statutory (under the byelaws) or civil (under contract law).

Key Considerations for Regulation 6.7

1. Statutory Nature of Regulation 6.7

Scope of the Byelaws: Regulation 6.7 forms part of the statutory byelaws approved under the Airports Act 1986. This means that any charges or conditions imposed by the airport operator under this regulation derive their authority from statutory law. 

Statutory Enforcement Mechanism: Breaches of Regulation 6.7 are enforceable through the byelaws’ statutory framework, typically involving prosecution in a magistrates’ court. This would classify such terms and conditions as statutory in nature, not civil.

2. Private Contracts and Delegated Authority

Role of the Contracted Operator: If the airport operator contracts VCS to manage car parks and authorises them to install signs with terms and conditions, the operator is effectively delegating their authority under Regulation 6.7 to VCS.
 
Civil Contracts: Despite the delegation, the relationship between the driver and VCS is still governed by the terms on the signage, which constitute a civil contract. This is because the authority to impose terms and conditions has been transferred to VCS through a private contract, and the enforcement mechanism is the civil court system, not the statutory byelaws. 

3. Statutory vs. Civil Enforcement

The distinction lies in how breaches are enforced:

Statutory Enforcement: If a driver breaches a condition that flows directly from the byelaws (e.g., parking outside designated areas or obstructing traffic), enforcement would typically occur through prosecution in a magistrates’ court under the byelaws. 

Civil Enforcement: If the driver breaches a term set out on VCS’s signage (e.g., overstaying a time limit or failing to pay a parking fee), enforcement occurs through the private operator’s civil contract claim, using the civil court system. 

This dual framework creates a situation where certain aspects of parking may overlap:

The byelaws may set general rules for parking (e.g., designated areas, time limits).

VCS’s terms and conditions (authorised by the airport operator under Regulation 6.7) create additional rules, such as charges for overstaying or failing to display a ticket, enforced through civil claims.

Legal and Practical Implications

Flowing Authority: Terms and conditions established by VCS ultimately derive their authority from the airport operator under Regulation 6.7. However, their enforcement mechanism (civil vs. statutory) determines whether they are statutory or civil. 

Blurring Lines: While the terms are indirectly linked to the byelaws, they remain civil in nature because the airport operator has chosen to enforce them through private contracts rather than the byelaws’ statutory framework. 

Potential Challenges: Drivers might argue that since the conditions flow from Regulation 6.7, breaches should be enforced through statutory mechanisms rather than civil claims. This could undermine the operator's ability to rely on private enforcement.

Conclusion

The terms and conditions on VCS’s signs are civil, not statutory, despite originating from the airport operator’s authority under Regulation 6.7. This is because the enforcement mechanism for these terms is through the civil court system as private contractual claims, rather than prosecution under the byelaws. The airport operator’s decision to delegate authority to a private company effectively shifts enforcement into the realm of contract law, even though the underlying authority comes from statutory byelaws.

This distinction between statutory and civil enforcement is crucial in understanding the legitimacy of private parking operators' actions and the legal framework governing parking on byelaw-regulated land.

However, you may be thinking that section 3 above contradicts the argument. You are absolutely right to note the tension in Section 3 regarding enforcement mechanisms. For example, not parking in a marked bay within a car park presents a situation where the conduct breaches both the statutory byelaws (e.g., "parking outside of a designated area") and the contractual terms displayed on the VCS signage. This overlap creates ambiguity as to whether the breach should be enforced statutorily or civilly.

The enforcement of parking outside a designated area within car parks is handled civilly through VCS’s contractual terms, even though the same behaviour could constitute a statutory breach of byelaws. This practice is facilitated by the airport operator’s delegation of enforcement authority under Regulation 6.7 and reflects a preference for civil enforcement over statutory prosecution due to its practicality and efficiency.

However, this dual regulatory framework raises legitimate questions about the boundaries between statutory and civil enforcement. While the current approach is widely used, it remains vulnerable to legal challenges that question the compatibility of contractual enforcement with statutory byelaws. For drivers, this ambiguity underscores the importance of understanding their rights and the legal basis for any enforcement action.

Food for thought on how to handle the breaches of byelaws on the roads.

Title: Re: VCS @ Bristol Airport
Post by: b789 on January 17, 2025, 04:21:55 pm
We could have predicted that for you. Personally, I never recommend wasting time with an IAS appeal. Less than 4% of IAS appeals are upheld which is a dismal record. Their assessors are anonymous and they simply spew out rubbish. They are definitely not "independent" and are funded by the very organisations they are supposed to be adjudicating on.

The IAS decision is not binding on you. You are now in a sort of limbo where nothing of significance will happen except you will be bombarded with useless debt collector letters. The debt collectors are powerless to do anything as they are not a party to the supposed contract that the driver allegedly breached. You can safely ignore them. Our advice is to never, ever, ever, enter into any communication with a useless, powerless debt collector/Debt Recovery Agent (DRA). Use their letters as kindling or to line the bottom of a litter tray.

The next step n the process will be a Letter of Claim (LoC). It will either be issued through Elms Legal or DCB Legal. When it arrives, please come back and we will advise on your next step.
Title: Re: VCS @ Bristol Airport
Post by: BelfastBoy on January 17, 2025, 04:14:09 pm
Many thanks. My appeal to the IAS has just been dismissed.
Title: Re: VCS @ Bristol Airport
Post by: b789 on January 17, 2025, 04:08:30 pm
Obviously you intend to challenge the PCNs. As I mentioned, despite throwing away a perfectly good defence, you still have other arguments, as discussed.

Please remind me where you are at as I simply do not have enough time to go back and re-read everything from the beginning. Once I know where you are at in the process I am more than happy to assist and advise on the next steps, based on your desired outcome.

You won't be paying a penny to VCS and, if processed correctly, you could inflict some financial damage on them. I'd suggest that dome Schadenfreude is always a welcome tidbit.
Title: Re: VCS @ Bristol Airport
Post by: BelfastBoy on January 17, 2025, 03:00:29 pm


Are you looking for meaningful advice on your situation? or just expressing your opinion as you seem to be fixated on the argument you've gained from the Gary Rycroft article.

as I said before b789 has given you excellent advice. up to you if you don't want to use it.

I know what you said before. I'm clearly looking for meaningful advice on my situation. b789 has now provided me with extra information around the bylaws question, which very much looks like the information contained in the article I'm 'fixated on'.
Title: Re: VCS @ Bristol Airport
Post by: mickR on January 17, 2025, 02:55:17 pm


Are you looking for meaningful advice on your situation? or just expressing your opinion as you seem to be fixated on the argument you've gained from the Gary Rycroft article.

as I said before b789 has given you excellent advice. up to you if you don't want to use it.
Title: Re: VCS @ Bristol Airport
Post by: BelfastBoy on January 17, 2025, 02:26:41 pm
Thank you very much. This is what I'm getting at.

Bristol Airport cannot have bylaws in place governing things like stopping and parking but choose not to enforce them through the criminal courts, allowing instead a private contractor to issue demands for payment in the wake of alleged contractual breaches relating to the very behaviour that the bylaws cover. There cannot be two parallel regimes, one statutory and the other contractual, covering the same acts on the same land. 

To be clear again, VCS has made no comment whatsoever about the bylaws. They said nothing to me (in spite of the fact that I challenged them on this very issue) and clearly wanted to contribute nothing to The Guardian on the topic. If the land was not covered by the bylaws, why would VCS be shy about saying so? The same goes for Bristol Airport itself. If the bylaws don't apply, then roads directly adjacent to the airport, which it clearly owns, do not fall within the scope of the 'the Airport', as referenced on page 4 of those bylaws (https://www.bristolairport.co.uk/media/4vqbdkcf/bristol-airport-byelaws-11062018.pdf). No plan is attached to that document; however, page 11 of this document (https://www.bristolairport.co.uk/media/2g3l4hjb/bristol-airport-master-plan-2006.pdf) shows the boundaries of the airport in 2006. The area at issue in my case is very much inside this boundary, even if the footprint has changed slightly in the years since.
Title: Re: VCS @ Bristol Airport
Post by: b789 on January 17, 2025, 12:34:00 pm
You are absolutely correct to raise the question of whether Vehicle Control Services (VCS) can lawfully issue a Parking Charge Notice (PCN) or similar demand based on an assumed contract when the land is explicitly subject to statutory byelaws. This is a fundamental issue when dealing with land governed by specific public law instruments, such as airport byelaws.

Land explicitly covered by byelaws, such as Bristol Airport, operates under public law. This means any conduct regulated under the byelaws (e.g., stopping restrictions, driving offences, or parking) is enforceable only through the mechanisms provided within the byelaws. Since stopping restrictions are governed by the byelaws (e.g., sections 6.13, 6.5), such acts would fall under public law and would need to be prosecuted through a magistrates' court as a byelaw breach. A private company such as VCS cannot bypass this by framing the same conduct as a contractual issue.

When byelaws regulate specific behavior, such as driving or stopping, these regulations displace any implied contractual framework. This principle arises from the fact that byelaws are statutory instruments intended to regulate the land, overriding private arrangements. If VCS attempts to enforce stopping restrictions using a contractual framework, they are effectively circumventing the byelaws, which is unlawful.

For VCS to enforce a contractual claim, they must demonstrate the formation of a valid contract with the driver. However, most airport signage for stopping restrictions is prohibitive (e.g., "No Stopping at Any Time"). Courts have consistently ruled that prohibitive signage cannot create a contractual relationship because it does not offer any terms for a driver to accept. Instead, it communicates a prohibition. If the signage specifies penalties for breaching byelaws, this would further reinforce that the matter is a statutory issue, not a contractual one.

VCS may argue that by entering the airport's private roads, the driver agreed to a set of terms and conditions displayed on signage, forming a contract. They might then issue a PCN under contract law for breaching those terms (e.g., stopping in a restricted area).

However, on land governed by byelaws, VCS cannot establish a contractual framework for conduct already regulated by statutory law. If stopping restrictions are enforceable only as byelaw breaches, VCS cannot claim a financial penalty as damages under contract law because the statutory framework preempts such claims. Any signage referencing "fines" or penalties under byelaws may misrepresent the nature of the charge, further invalidating their claim.

VCS’s claim based on an assumed contract is certainly invalid on land covered by statutory byelaws. The regulation of stopping restrictions is exclusively within the scope of the byelaws, which can only be enforced via the mechanisms provided—typically through magistrates' court for criminal proceedings.

If VCS attempts to enforce their claim through contract law, you should challenge:

• Their authority to issue contractual demands on byelaw-governed land.
• The validity of the alleged contract, especially if the signage is prohibitive.
• Any misrepresentation of their role or authority in enforcing byelaws.

However, just so you are aware, VCS will claim that the airport bylaws are obsolete, proving their mendacious behaviour. Their argument that the byelaws are obsolete is an attempt to justify their reliance on assumed contracts to issue PCNs.

The byelaws governing Bristol Airport were made under the Airports Act 1986 and approved by the Secretary of State for Transport. This gives them statutory authority. Byelaws cannot simply become obsolete; they remain enforceable until formally revoked, replaced, or invalidated by a court ruling or updated legislation.

VCSs claim the byelaws are obsolete to justify enforcement under contract law, amounts to misrepresentation and an unfair business practice, as it falsely implies that byelaw restrictions do not apply. Such a claim should be challenged under the Consumer Protection from Unfair Trading Regulations 2008 (CPUTRs), especially as VCS misleads drivers about the legal framework governing the land.

I have not even covered how VCS can or cannot issue and prosecute a Penalty Notice even they had statutory authority to do so. They do not!
Title: Re: VCS @ Bristol Airport
Post by: BelfastBoy on January 17, 2025, 11:55:38 am
They are almost certainly making their claim according to an assumed contract. The issue, however, is whether that's allowed on land covered by bylaws. Contraventions of stopping restrictions are surely a bylaw issue not a contractual one on land so explicitly covered by pretty clear legislation.

I would repeat that VCS has simply not engaged with the point relating to bylaws. It hasn't even said that bylaws don't apply in this situation. The Guardian article features a very vague statement from the airport and nothing from VCS.
Title: Re: VCS @ Bristol Airport
Post by: mickR on January 17, 2025, 11:29:02 am
that is one element of the available defences.
for that to be successful you would have to check the area of the alleged contravention is indeed within the airport land boundary for bylaws to be applicable.

then you need to consider if the scammers parking Co are claiming under bylaw contravention or private parking contract.

the response will be different for each.

as b789 has detailed for you there also is the issue of signage and whether or not a contract has even been offered.
Title: Re: VCS @ Bristol Airport
Post by: BelfastBoy on January 17, 2025, 10:53:39 am
The article references the Airports Act 1986. Is the fact that motorists are being pursued for alleged contractual breaches on lands falling under the authority of airport bylaws not an issue? Stopping where you've been told not to stop in an airport is, theoretically, a contravention of a clearly identifiable bylaw, not some legally dubious contract, surely?
Title: Re: VCS @ Bristol Airport
Post by: b789 on January 17, 2025, 10:38:56 am
All that article reiterates is that as long as the Keeper or Hirer does not blab the drivers identity, VCS cannot transfer liability from the unknown driver to the known Keeper.

Unfortunately for you, you mistakenly assumed that the hire company named you, the known Hirer as the unknown driver. They didn’t. All they did was name you as the known Hirer and it was you who then appealed incorrectly and revealed yourself, the known Hirer to also be the, up until then, the unknown driver.

That was you mistake because you assumed that you had been revealed as the driver of the hire vehicle. The hire company does not know who the driver is and all they can do is tell VCS that you are the Hirer

There is a legal distinction between the driver and the Hirer/Keeper. There can be no inference that the Hirer/Keeper must also be the driver. They may be, but the burden of proof is on the parking operator. There is no legal obligation on the Hirer/Keeper to do their job for them. It is not for the Hirer/Keeper to disprove anything.

However, having blown away the “golden ticket” element of any appeal/defence, you still have another point you can rely on. However, it will come down to persuading a District Judge that, as the driver, you did not enter into any contractual agreement with VCS. Why? Have a read of the PCN and see what it is alleged the driver has done and what the PCN actually is.

The PCN is nothing more than a speculative invoice for an alleged breach of contract by the driver. What are the main elements of a contractual agreement?

1. An Offer
2. Acceptance
3. Consideration

For a contract to be formed there must first be an ‘offer’ of something. Whatever is being ‘offered’ then has to be ‘accepted’ by the other party. ‘Consideration’ is a form of payment or other benefit, and both parties must give consideration to form a legally binding contract.

For example, if a VCS sign said “Parking available for £2 per hour. By parking, you agree to our terms.”, that is an ‘offer’. If the driver parks their car in the car park, they are indicating their agreement to the terms displayed, and that is the ‘acceptance’. The driver pays £2 for one hour of parking, and VCS provides the space and associated services, which is the ‘consideration.

So, a ‘contractual agreement’ was formed between the driver and VCS. Now, if one of the terms was that the vehicle must be parked in a marked bay but the driver parked on the line dividing two bays, that is a breach of the terms of the contract and so VCS can invoice the the driver by way of a PCN for the breach of contract.

Now consider what contract was formed by the signage for the alleged contravention you have been accused of. If a sign says “No stopping or picking up or dropping off”, what is being ‘offered’?

A prohibitive sign cannot form a contractual agreement. VCS cannot simply put up a sign that says “Stopping Prohibited. Breaching this term will incur a charge of £100” and expect that it forms a contractual agreement with the driver if they do stop.

That would be one of your remaining defence arguments. That and the fact that no one has seen an up to date, valid contract between Bristol Airport and VCS that permits them to issue PCNs in their own name or that they even have any right to do so outside of the car parks.
Title: Re: VCS @ Bristol Airport
Post by: BelfastBoy on January 17, 2025, 09:32:59 am
So, the argument posited by Gary Rycroft is moot?
Title: Re: VCS @ Bristol Airport
Post by: b789 on January 16, 2025, 11:22:25 pm
There is no legal obligation on the Hirer to identify the driver. This is not a criminal matter that is subject to forensic examination.

Have a read of this persuasive appeal court decision that is often used to explain why the defendant is not under any obligation and the burden of proof is on the claimant:

VCS v Edward (2023) (https://www.dropbox.com/scl/fi/zra61px7l3if53o3bp9c4/VCS-v-EDWARD-Transcript.pdf?rlkey=bv4bba389nau5qpfglqkpjq5l&st=wpnxrkyx&dl=0)

The only relationship to bylaws is that because of them, the location is under statutory control and therefore, not relevant land for the purposes of PoFA.
Title: Re: VCS @ Bristol Airport
Post by: BelfastBoy on January 16, 2025, 10:05:50 pm
Thank you for this very extensive reply. I’m concerned to note that VCS would not be required to try and actually recover the debt. They could leave it unenforced, collecting no money themselves but impacting my credit score.

Does any part of your response relate to bylaws?

Also, would the identity of the driver not be examined during a court hearing? Or are you saying that my refusal to answer that question in a court setting would be a sufficient defence?
Title: Re: VCS @ Bristol Airport
Post by: b789 on January 16, 2025, 03:56:50 pm
I repeated an argument advanced by an experienced consumer-rights lawyer in a national newspaper. Having examined the legislation cited, I thought this position had merit. I still do.

It didn't do you any good though. Not that any other argument would have done any better. You are not dealing with a nice firm with a good customer service ethos. You are dealing with a bunch of ex-clampers who operate on the very edge of lawfulness and often beyond. Their only ethos is how much of your money can they scam you out of.

In addition, as the only person registered and insured to drive the vehicle, VCS would have had little trouble establishing the identity of the driver if, in the absence of any engagement on my end, it continued to press the registered keeper for details, something which may well have cost me more in related admin costs.

I disagree. The burden of proof is on the claimant (VCS) to show, on the balance of probabilities, that the Hirer (or registered keeper) was the driver at the time of the alleged contravention. However, the following factors can complicate this:

If the Hirer permitted another person to drive the vehicle (e.g., a friend or family member), the hire agreement’s restrictions do not matter in this context. Provided that the third party had adequate insurance (e.g., “Driving Other Cars” cover under their own insurance policy), they could lawfully drive the vehicle with the Hirer’s permission. In such cases, the identity of the driver becomes ambiguous, which weakens the claimant’s case.

The hire agreement may be evidence that the Hirer was likely the driver, but it is not conclusive proof. The claimant would still need to provide additional evidence (e.g., witness statements, video footage, or admissions from the Hirer) to support their assertion.

Your reasoning is flawed for several reasons. Being the sole person "registered and insured" to drive the vehicle does not conclusively prove that the Hirer was driving at the time of the alleged contravention. As stated earlier, another person could have driven the vehicle with the Hirer’s permission, provided they held adequate insurance. This creates sufficient ambiguity to undermine the claimant’s case.

VCS cannot legally force the Hirer (or the registered keeper) to disclose the driver’s identity. The Hirer is under no obligation to respond, and silence does not constitute evidence. Civil law does not allow adverse inferences to be drawn from the Hirer’s refusal to name the driver.

Since the alleged contravention occurred on airport land, which is not considered "relevant land" under PoFA 2012, VCS cannot use the legislation to transfer liability to the Hirer if the driver’s identity is not known. Without this legal mechanism, VCS is wholly reliant on proving who the driver was, a significant burden when the Hirer does not engage or disclose.

If you had not engaged, VCS would have had no direct evidence of driver identity, leaving them to rely solely on circumstantial evidence such as "insurance or registration" details. This is insufficient to meet the burden of proof. In the absence of PoFA applicability, a claim would likely fail unless VCS could provide clear evidence.

Your concern about being liable for ‘additional admin costs’ if VCS pressed the hire company for the driver’s details is misplaced. Under Schedule 4 of the Protection of Freedoms Act 2012 (PoFA), once the hire company has complied with its obligations to transfer liability to the Hirer, VCS cannot pursue the hire company again or demand additional information. The liability is fully and permanently transferred to the Hirer, and the hire company is no longer involved. There is no provision in PoFA that allows VCS to revert to the hire company or ‘press’ them for further action.

Once VCS receives the Hirer’s details from the hire company, any further administrative costs related to this transfer are not the Hirer’s responsibility. Your assumption that VCS would continue pressing the hire company and somehow pass additional costs onto you, the Hirer, is not supported by how liability transfer works under PoFA.

The transfer of liability under PoFA allows VCS to pursue the Hirer only if the land qualifies as “relevant land” under PoFA. Since airport land is not relevant land, the transfer of liability does not enable VCS to hold the Hirer liable unless they can prove the Hirer was the driver. Therefore, even if the hire company transferred liability, VCS would still face the same evidentiary hurdle of proving who was driving the vehicle.

Your belief that engagement was necessary to avoid further admin costs is based on a misunderstanding of how PoFA works. Once liability was transferred, the hire company was entirely out of the process, and VCS could not pursue them again. Your engagement provided VCS with direct evidence of driver identity, strengthening their case. By remaining silent and allowing VCS to rely on their own limited evidence, you would have had a much stronger defence.

Surely the fact that I'm resident in Northern Ireland would have no actual bearing on the points I might make in defending any such claim? Is VCS likely to secure its CCJ and leave it there? They wouldn't try to enforce the judgement (assuming I didn't pay up in the wake of it) but they would damage my credit score.

Your residency in Northern Ireland does not affect the substance of the legal points you can make in your defence—those remain grounded in the facts of the case, the applicable law (e.g., the Protection of Freedoms Act 2012, contract law, signage compliance), and procedural fairness. However, your location could impact procedural aspects of how VCS pursues the claim and enforces any resulting judgment.

The legal arguments you make (e.g., PoFA does not apply on airport land, VCS cannot prove driver identity, unclear signage) are not affected by your residency. These points apply regardless of where you live because the alleged contravention occurred in England. If VCS pursues a claim, they must:

• Issue the claim through the English County Court system.
• Ensure the claim is served correctly to your address in Northern Ireland under UK cross-border service rules.

Residency only complicates matters for VCS logistically, not legally, when they attempt to pursue a claim.

If VCS files a claim and you do not defend or fail to respond, they will obtain a default judgment against you. However, if you defend the claim robustly, VCS would need to:

• Prove the alleged contravention occurred.
• Overcome defences such as the inapplicability of PoFA on airport land or the lack of evidence identifying you as the driver. (moot at this point)
• Address any procedural errors, such as improper service of documents to Northern Ireland.['indent]

So, if you provide a strong defence, VCS is less likely to succeed in obtaining a CCJ.

However, if VCS obtains a judgment, the consequences depend on what they do next:

A. Judgment Left Unenforced

If you do not pay the judgment within 30 days, it will be recorded on your credit file for six years. This will negatively impact your credit score, affecting your ability to secure loans, mortgages, or other financial products.

VCS might leave the judgment unenforced if they view the cost of cross-jurisdictional enforcement as uneconomical, especially if it is for less than £600.

B. Judgment Enforced in Northern Ireland

For VCS to enforce the judgment in Northern Ireland, they would need to register the English County Court Judgment with the Enforcement of Judgments Office (EJO) in Northern Ireland. This adds administrative costs for VCS and makes enforcement less likely if the debt is relatively small (e.g., less than £600).

So, in conclusion, your residency in Northern Ireland has no bearing on the legal arguments for your defence but does complicate enforcement for VCS. If you respond and defend a claim, VCS is less likely to succeed, especially given that the alleged contravention occurred on airport land, where PoFA does not apply, and the signage was prohibitive, preventing the formation of a valid contract.

However, since you have already revealed yourself as the driver, VCS no longer needs to prove driver identity, which strengthens their position. If the court ultimately rules against you, as long as you pay the CCJ in full within one calendar month of judgment, the CCJ will be expunged from your credit record and will not affect your credit score.

An English CCJ can negatively affect a Northern Ireland resident’s credit score even without enforcement because it is entered into the UK-wide credit reporting system. However, VCS would need to register the judgment in Northern Ireland to take any legal steps to recover the debt. (unlikely if under £600)

At this stage, you need to decide whether to continue fighting the claim based on the remaining points, particularly the argument that no contract could have been formed because the signage is prohibitive, or to prepare for the possibility of settling promptly if the judgment is not in your favour.
Title: Re: VCS @ Bristol Airport
Post by: mickR on January 16, 2025, 03:24:47 pm
VCS only knew who the hirer was, not the driver. the fact you were the only one insured etc is irrelevant to that fact.

you shoukd also check your hire agreement to see what it says about admin fees. some if these T&Cs are contrary to the CRA 2015 rules.

you should take b789's advice, they and others are very experienced at defending spurious airport pcn's
Title: Re: VCS @ Bristol Airport
Post by: BelfastBoy on January 16, 2025, 01:58:45 pm
Thank you for this comprehensive reply. I repeated an argument advanced by an experienced consumer-rights lawyer in a national newspaper. Having examined the legislation cited, I thought this position had merit. I still do.

In addition, as the only person registered and insured to drive the vehicle, VCS would have had little trouble establishing the identity of the driver if, in the absence of any engagement on my end, it continued to press the registered keeper for details, something which may well have cost me more in related admin costs.

Surely the fact that I'm resident in Northern Ireland would have no actual bearing on the points I might make in defending any such claim? Is VCS likely to secure its CCJ and leave it there? They wouldn't try to enforce the judgement (assuming I didn't pay up in the wake of it) but they would damage my credit score.
Title: Re: VCS @ Bristol Airport
Post by: b789 on January 16, 2025, 12:16:01 pm
You’ve made several basic errors. First was taking note of that article by the Grauniad which steered you in the wrong direction.

You’ve blown both feet off, figuratively speaking, by appealing the way you did. The hire company did not dob you in it. All they did was transfer liability from them, the keeper, to you, the Hirer. No one except you, the Hirer knew the identity of the driver.

Because only you knew the drivers identity, you were under no legal obligation to reveal it to an unregulated private parking company.

Because the location is covered by airport bylaws, it is not relevant land for the purpose of PoFA which means the Hirer cannot be liable for the charge.

The driver was always liable but if they didn’t know the drivers identity, they could do nothing about it. If the Hirer blabbed the drivers identity, inadvertently or otherwise, then that’s a big screw up.

Any appeal to VCS and especially the IAS is an exercise in futility. Having appealed and given away the fact that the Hirer was also the driver, is SNAFU.

You are going to receive a claim from VCS and you’ve blown your best defence away. However, there are other defences and they include the fact that there cannot have been a contractual agreement between VCS and the driver if the signage is prohibitive.

However, if you are an NI resident, you can be sued for a parking charge relating to an alleged contravention in England, but the process differs due to jurisdictional issues between England and Northern Ireland.

Since the alleged parking contravention took place in England, English law typically governs the matter. However, enforcement against a defendant residing in Northern Ireland requires the claimant to adhere to the relevant jurisdictional rules.

VCS must initiate the claim through the English County Court system (CNBC). The court papers will then need to be served in Northern Ireland, as the defendant resides there. This is allowed under the Civil Jurisdiction and Judgments Act 1982, which enables cross-border enforcement of civil debts within the UK.

VCS must ensure the claim form is correctly served to the defendant’s address in Northern Ireland. If the service requirements are not met, the defendant could challenge the validity of the proceedings.

The defendant can respond to the claim in the usual way (admitting, defending, or counterclaiming). If defending, the defendant can argue the case in an English County Court. This may require travel to England for any court hearings unless the hearing is conducted remotely (e.g., via video link).

If VCS were to win the case and obtains a County Court Judgment (CCJ) in England, they can enforce it in Northern Ireland through the Enforcement of Judgments Office (EJO). This requires the CCJ to be registered in Northern Ireland, which involves additional procedural steps and costs for the claimant.

What VCS would need to consider is that the cost of cross-jurisdiction enforcement may deter them from pursuing claims against Northern Ireland residents for minor parking charges, although this is for two charges.

VCS must ensure full compliance with English and Northern Ireland civil procedure rules to avoid the claim being struck out.

As an NI resident, you would defend the claim on its merits (e.g., inadequate signage, no valid contract etc.).
You could also argue inconvenience or jurisdictional challenges, although these may not automatically prevent the claim.

For now, you will have to wait and see how they decide to go. You should also carefully check your hire agreement for the terms relating to private parking charges. It was never a penalty notice, no “offence” occurred and no “fine” has been issued. Your PCNs are merely speculative invoices.
Title: Re: VCS @ Bristol Airport
Post by: mickR on January 16, 2025, 11:43:23 am
READ THIS FIRST - **BEFORE POSTING YOUR CASE!**, 

https://www.ftla.uk/private-parking-tickets/read-this-first-private-parking-charges-forum-guide/
Title: Re: VCS @ Bristol Airport
Post by: John U.K. on January 16, 2025, 11:33:12 am
This will be moved to Private Parking
Title: VCS @ Bristol Airport
Post by: BelfastBoy on January 16, 2025, 11:30:35 am
Hello,

In November, I received a pair of charge notices from VCS, which, as I'm sure you all know, enforces parking and traffic flow at Bristol Airport. These notices were issued on foot of my having stopped, on two separate occasions, in a prohibited area while returning a hire car.

There was no point in ignoring the notices on the assumption that VCS could not establish the identity of the driver. The hire company sold me out at the drop of a hat, providing my details to VCS and charging me £84 for the trouble.

I appealed to VCS initially, pointing out that these charges were not enforceable or properly served. That argument was based on the observations of Gary Rycroft, who was quoted in this article (https://www.theguardian.com/money/2024/sep/14/airport-parking-fines-bristol-unenforceable-bylaw):

'Guardian Money also contacted the consumer lawyer Gary Rycroft, a partner at Lancaster-based Joseph A Jones & Co Solicitors... “The legal rule under common law is that bylaws are only enforceable through fines and prosecution in the magistrates court,” he said. “My view is that private parking invoices issued by VCS on behalf of Bristol airport are at odds with – and indeed in direct conflict with – the prosecution and enforcement regime set out in the Airports Act 1986, and for that reason I do not believe they are enforceable.” VCS, the parking contractor at the centre of dispute, has not responded to repeated requests for comment.'

In rejecting my appeal, VCS completely ignored the reference to airport bylaws (particularly section 64 of the Airports Act (https://www.legislation.gov.uk/ukpga/1986/31/section/64)). Bristol Airport's bylaws are available on it website (https://www.bristolairport.co.uk/media/4vqbdkcf/bristol-airport-byelaws-11062018.pdf). Indeed, there is a specific bylaw (6.3) that restricts stopping in areas described by notices. VCS is issuing these charge notices to people who stop in areas described by notices. In short, VCS is collecting money for breaches of the airport's bylaws, claiming instead that the issue is one of contract.

I appealed the matter to the Independent Appeals Service (IAS). The appeals process allows each party to submit evidence to and fro (the appellant submits representations, the operator responds to those representations, the appellant responds to that response and so on, until neither party has anything else to say and the appeal is then considered by adjudicator). In all the submissions back and forth, VCS simply would not engage with the bylaws issue. In the end, the IAS couldn't be bothered to do so either. My appeals were dismissed and I'm on the hook, in theory, for the original fines.

What are the chances that this is escalated to the county court? I live in Northern Ireland and, as such, VCS would have to take further steps to enforce any judgements in this jurisdiction. Could VCS get a county court judgement against me and simply not attempt to enforce it in Northern Ireland, punitively allowing it to fester on my credit file?