Landowner Authority – Horizon’s Claim is Legally Illiterate and Completely Unsupported
Horizon Parking has made no attempt whatsoever to respond to point #3 raised in the appeal. They were specifically challenged to produce a full, signed, and dated contract with the landowner showing they have the legal right to operate and issue parking charges in their own name. They were also told that a properly witnessed landholder statement would suffice if a contract could not be disclosed. They have done neither.
Instead, they offer this infantile claim:
"we have signs and equipment in place, so we must have landowner authority."
This is not a rebuttal. It is a childlike assumption dressed up as legal reasoning. The existence of signs proves only that Horizon has placed signs there. It says nothing about whether they are entitled to do so, whether any contract exists now, or whether any authority was ever granted.
This is not theoretical. Contracts lapse, expire, or are revoked, and signage frequently remains in place regardless. Horizon has provided no evidence that any permission is current, valid, or even exists. They have not produced:
- a contract
- a redacted summary of one
- a witness statement
- or even a letter of confirmation.
They have failed to respond to the central evidential burden. And to then attempt to bypass that obligation with an appeal to the existence of their own signs is not just legally bankrupt—it is insulting to the intelligence of any independent adjudicator.
PPSCoP Section 14 – Clear and Binding
Section 14 of the Private Parking Single Code of Practice (PPSCoP) sets out precisely what operators must obtain and be able to show in relation to landowner authority, including:
- the permission granted and its duration
- what they are authorised to do
- and, at 14.1(i), a requirement to be able to supply documentation to authorised bodies upon request.
They have not supplied it. They haven’t even claimed to have it. Instead, they’ve deployed a non-answer based on an implied truth that isn’t just unsupported—it is patently false.
If the POPLA assessor is inclined to accept Horizon’s “we have signs, therefore we have authority” position, then they must be reminded that this would amount to discarding basic evidential standards in favour of magical thinking. It would require a total abandonment of logic, and the kind of intellectual negligence that brings the entire adjudication process into disrepute.
PCN No: [PCN Number]
Vehicle Registration Mark: [VRM]
I am the keeper of the vehicle and I dispute your ‘parking charge’. I deny any liability or contractual agreement and I will be making a complaint about your predatory conduct to your client landowner.
As your Notice to Keeper (NtK) does not fully comply with ALL the requirements of PoFA 2012, you are unable to hold the keeper of the vehicle liable for the charge. Partial or even substantial compliance is not sufficient. There will be no admission as to who was driving and no inference or assumptions can be drawn. Horizon has relied on contract law allegations of breach against the driver only.
The registered keeper cannot be presumed or inferred to have been the driver, nor pursued under some twisted interpretation of the law of agency. Your NtK can only hold the driver liable. Horizon have no hope at POPLA, so you are urged to save us both a complete waste of time and cancel the PCN.