You can also ignore the next set of letters you will probably receive from GCTT, which is just another knuckle dragging moron sitting at the desk next to the anal orifice who sent you that letter.
You can safely ignore all the useless debt recovery letters you are now going to receive. Debt collectors are powerless to do anything except to try and intimidate the low-hanging fruit on the gullible tree into paying up out of ignorance and fear.
Come back when you receive a Letter of Claim (LoC). All debt recovery letters can be shredded and used as Hamster bedding for anyone cares. We don't need to know about them.
1. Signage: A Masterclass in Concealment
UKPC’s signage is a textbook breach of the "Red Hand Rule", articulated by Lord Denning in Spurling v Bradshaw [1956]. He stated:
- “Some clauses which I have seen would need to be printed in red ink on the face of the document with a red hand pointing to it before the notice could be held to be sufficient.”
The £100 charge—arguably the most onerous term—is buried in small print, indistinguishable from the surrounding clutter. It is not highlighted, not bolded, not enlarged, and certainly not “adequately brought to the attention of the driver” as required by:
- Paragraph 2(2) of PoFA which states that the parking charge must be a sum “of which ADEQUATE NOTICE was given to drivers.” - Paragraph 2(3) defines “ADEQUATE NOTICE” as signage that MUST:
- Specifiy the sum as the charge for unauthorised parking, and
- Is ADEQUATE to bring the charge to the notice of drivers who park vehicles on the relevant land.
UKPC’s signs fail both tests. The signage is a visual fog of generic prohibitions, privacy disclaimers, and irrelevant data protection blather. The £100 charge is not prominent—it’s camouflaged. This is not contract formation; it’s entrapment by obfuscation. The signage does not meet the statutory definition of “adequate notice,” and therefore UKPC cannot rely on PoFA to establish keeper liability.
2. PoFA Contradictions: Paragraph 9 vs Paragraph 8
UKPC’s own submission is a self-defeating contradiction. They claim compliance with Paragraph 9 of Schedule 4 (which applies when no Notice to Driver is served), then immediately cite Paragraph 8(6)—which only applies when a Notice to Driver has been served.
This is not a minor technicality. It’s a fundamental procedural error. You cannot invoke both paragraphs simultaneously. Either:
- A Notice to Driver was served -> Paragraph 8 applies.
- No Notice to Driver was served -> Paragraph 9 applies.
UKPC’s attempt to cherry-pick provisions from both paragraphs is legally incoherent. It’s akin to quoting two different statutes to justify one act—without regard for context or applicability. If POPLA accepts this contradiction, it undermines the statutory framework of PoFA entirely.
3. Jopson v Homeguard: Binding Authority on Delivery Stops
UKPC’s assertion that “any stationary vehicle is deemed parked” is not only absurd—it’s judicially discredited. In Jopson v Homeguard Services Ltd [2016] B9GF0A9E, His Honour Judge Harris QC stated:
“Merely to stop a vehicle cannot be to park it; otherwise traffic jams would consist of lines of parked cars. Delivery vans… would not be accommodated on an interpretation which included vehicles stopping for a few moments for these purposes.”
He went further:
“Whether a car is parked, or simply stopped, or left for a moment while unloading... must be a question of fact or degree.”
The vehicle in question was a delivery van, stopped for 20 minutes and 26 seconds to deliver parcels to residents. This is not “parking”—it is loading/unloading, a lawful and necessary activity. UKPC’s refusal to acknowledge this distinction is not just legally flawed—it’s contemptuous of judicial authority.
If POPLA chooses to ignore Jopson, it is not merely overlooking persuasive precedent—it is disregarding binding judicial interpretation of the very concept it purports to enforce.
4. Keeper Liability: Procedural Failure
UKPC claims the Notice to Keeper was issued 4 days after the event and delivered within the statutory timeframe. But they offer no proof of posting—only a claim. Under the PPSCoP, operators MUST retain a record of the date of posting, not just the date of generation. Without this, the presumption of delivery under PoFA 8(6) fails and is rebutted.
Moreover, as already established, UKPC cannot rely on both Paragraph 8 and Paragraph 9 of PoFA. Their submission is internally contradictory and legally incoherent. Keeper liability cannot be enforced on a foundation of procedural confusion.
5. The So-Called Landowner "Witness Statement”
UKPC’s so-called witness statement is a mockery of evidential standards and a textbook example of how template-based fiction is being passed off as legal authority. It is a generic, boilerplate document that fails to meet even the most basic requirements of Section 14.1 of the PPSCoP. It contains no proof that the signatory has any authority whatsoever to bind the landowner. It is not dated in relation to the alleged contravention, and it offers no site-specific detail beyond the name of the location.
A witness statement is not a contract. It is not enforceable. It is not compliant. It is a piece of paper with vague assertions and a redacted signature offering no verifiable link to the landowner, no duration of authority, and no supporting documentation. If this is the standard of evidence POPLA accepts, then the entire concept of “landowner authority” becomes meaningless. Section 14.1 of the Code of Practice explicitly requires a valid, contemporaneous agreement showing the operator’s authority to issue PCNs and pursue legal action. UKPC has failed to provide this.
To illustrate the absurdity of accepting such a document as proof of contractual authority, anyone could parody that "witness statement" and could fabricate “evidence” of landowner authority using nothing more than imagination and a keyboard.
If POPLA accepts UKPC’s version as proof of a valid contract flowing from the landowner, despite its lack of compliance with Section 14.1 of the Code of Practice, including the redaction of signatories and absence of supporting documentation, then it will be further evidence of the inherent failures in the system.
The PPSCoP section 14.1 requires written confirmation from the landowner covering:
a) the identity of the landowner(s)
b) a boundary map of the land to be managed
c) any applicable byelaws
d) the permission granted and its duration
e) the parking terms and conditions, including exemptions
f) the method of issuing parking charges
g) responsibility for obtaining relevant consents
h) obligations under the Code and ATA membership
i) documentation to be supplied to authorised bodies
j) the operator’s approach to handling appeals
None of the information listed above is commercially sensitive, nor has UKPC provided any of it. Their submission fails entirely to meet the evidentiary requirements set out in Section 14.1 of the Private Parking Code of Practice. It does not contain a signed, dated, and site-specific agreement between the landowner and the operator, nor does it establish the scope, duration, or enforceability of any purported authority. In legal terms, it is inadmissible.
A redacted, illegibly signed witness statement—unsupported by contemporaneous documentation and devoid of contractual substance—cannot be construed as proof of landowner authority under any reasonable interpretation of the statutory framework. Acceptance of such material would constitute a breach of POPLA’s duty to apply the Code of Practice with rigour and impartiality.
It would also undermine the statutory safeguards enshrined in Schedule 4 of PoFA, which require demonstrable authority to pursue keeper liability. If POPLA accepts this submission as sufficient, it will confirm the systemic failure of the current appeals process and reinforce the urgent need for reform.
The Private Parking (Code of Practice) Act 2019 was enacted precisely to eliminate this kind of evidential theatre and replace it with a transparent, accountable, and legally compliant framework—one that cannot be manipulated by operators relying on template fiction and procedural sleight of hand.
6. The Driver Has Not Been Identified
The driver remains unidentified. In the absence of full compliance with the Protection of Freedoms Act (PoFA) 2012—as detailed in the appeal—there can be no transfer of liability to the Keeper. The Keeper is under no legal obligation to name the driver, and without such identification, the operator has no lawful basis to pursue the Keeper.
The persuasive authority of VCS v Edward (2023) confirms that operators cannot rely on assumption or inference to establish that the Keeper was the driver. Liability cannot be imposed without clear, unequivocal evidence. No such evidence has been presented, and therefore, the charge must fail.
Summary
UKPC’s signage fails the Red Hand Rule and breaches PoFA 2(2) and 2(3). Their reliance on both Paragraphs 8 and 9 of PoFA is legally contradictory. Their definition of “parking” is judicially discredited by Jopson v Homeguard. Their evidence is riddled with procedural errors, unsupported assertions, and irrelevant boilerplate. Their landowner witness statement is a joke.
If POPLA upholds this charge, it will be doing so in defiance of statute, precedent, and basic contractual principles. That outcome would speak volumes—not about the merits of the case, but about the credibility of the appeals process itself.
WITNESS STATEMENT
On behalf of the Sovereign Estate of Buckingham Palace, I confirm that:1. The site is Buckingham Palace, London SW1A 1AA.
2. The Operator is B789, acting in a personal capacity with full self-certification.
3. The Operator is authorised by the landowner (pending identification) to undertake parking management and enforcement at the site.
4. The Operator is authorised in an agreement dated 01/04/1066, running in perpetuity unless revoked by Act of Parliament or divine intervention.
5. The Operator is authorised by the Landowner in the agreement to issue Parking Charge Notices for breaches of the parking terms and conditions, including but not limited to carriage misalignment and improper corgi tethering.
6. The Operator is authorised to erect signage at the site, including laminated notices affixed to ceremonial railings.
7. The Operator is authorised to install and operate an Automatic Number Plate Recognition system, comprising a pair of opera glasses and a clipboard.
8. The Operator is authorised to pursue unpaid parking charges through debt recovery, court action, or dramatic readings in the House of Lords.
9. The Operator is authorised to retain the income from Parking Charge Notices issued at the site, to be stored in a velvet pouch under the throne.
10. The Operator is authorised to share data with the DVLA, MI6, and the Yeoman Warders as required.
11. The Operator is a member of the British Parking Association Approved Operator Scheme, subject to retrospective approval.
12. The Operator is responsible under the contract for putting up and maintaining the signage, unless it interferes with the Changing of the Guard.
I confirm that I am authorised to make this statement on behalf of the Landowner, the Crown, and any other entity whose name may be invoked for convenience, and that the above information is true to the best of my imagination and belief.
Agreed and signed: **REDACTED**
Date: 24 August 2025
Print name: **REDACTED**
Position: Royal Parking Enforcement Delegate (Self-Appointed)
For and on behalf of: **REDACTED**
I am the registered keeper of the vehicle. I deny any liability for this parking charge and appeal in full.
The vehicle in question was a large delivery van, engaged in active delivery duties at Marlin Apartments, Windmill Lane, E15 1PE. The stop lasted 20 minutes and 26 seconds. This was not parking. It was a necessary and temporary stop for the purpose of delivering parcels to residents. The distinction between parking and stopping for delivery is not semantic—it is legally recognised.
This point was addressed directly and persuasively in the County Court appeal case of Jopson v Homeguard Services Ltd (2016) [B9GF0A9E], heard by His Honour Judge Harris QC at Oxford County Court. While POPLA is not a court and cannot bind itself to legal precedent, it must not ignore persuasive authority that would be determinative in any legal proceedings.
In Jopson, the appellant was penalised for stopping briefly outside her residential block to unload furniture. The parking operator claimed this was a breach of terms. Judge Harris disagreed, stating:“The concept of parking, as opposed to stopping, is that of leaving a car for some duration of time beyond that needed for getting in or out of it, loading or unloading it, and perhaps coping with some vicissitude of short duration, such as changing a wheel in the event of a puncture.”
He went further:“Merely to stop a vehicle cannot be to park it; otherwise traffic jams would consist of lines of parked cars. Delivery vans, whether for post, newspapers, groceries, or anything else, would not be accommodated on an interpretation which included vehicles stopping for a few moments for these purposes.”
This is not a fringe interpretation. It is a clear judicial finding that distinguishes parking from delivery, and it reflects the reality of how residential and commercial premises operate. If delivery vehicles were treated as parked every time they stopped to unload, the entire logistics sector would be paralysed.
Judge Harris also stated:“Whether a car is parked, or simply stopped, or left for a moment while unloading... must be a question of fact or degree.”
In this case, the fact is clear: the driver was delivering parcels. The duration was short. The stop was necessary. There was no intent to leave the vehicle unattended for leisure or convenience. It was a functional, time-bound delivery stop.
If UKPC were to pursue this matter to court, they would face the same problem Homeguard did in Jopson. The claim would fail. The judge would distinguish delivery from parking, and the charge would be dismissed. POPLA may not be a court, but it must not pretend that this legal distinction does not exist.
To ignore Jopson is to ignore the law. To treat delivery as parking is to misrepresent the facts. This appeal must be upheld.
The parking operator bears the burden of proof. It must establish that a contravention occurred, that a valid contract was formed between the operator and the driver, and that it has lawful authority to operate and issue Parking Charge Notices (PCNs) in its own name. I therefore require the operator to provide the following:1. Strict proof of clear, prominent, and adequate signage that was in place on the date in question, at the exact location of the alleged contravention. This must include a detailed site plan showing the placement of each sign and legible images of the signs in situ. The operator must demonstrate that signage was visible, legible, and compliant with the IPC Code of Practice that was valid at the time of the alleged contravention, including requirements relating to font size, positioning, and the communication of key terms.
2. Strict proof of a valid, contemporaneous contract or lease flowing from the landowner that authorises the operator to manage parking, issue PCNs, and pursue legal action in its own name. I refer the operator and the POPLA assessor to Section 14 of the PPSCoP (Relationship with Landowner), which clearly sets out mandatory minimum requirements that must be evidenced before any parking charge may be issued on controlled land.
In particular, Section 14.1(a)–(j) requires the operator to have in place written confirmation from the landowner which includes:• the identity of the landowner,
• a boundary map of the land to be managed,
• applicable byelaws,
• the duration and scope of authority granted,
• detailed parking terms and conditions including any specific permissions or exemptions,
• the means of issuing PCNs, • responsibility for obtaining planning and advertising consents,
• and the operator’s obligations and appeal procedure under the Code.
These requirements are not optional. They are a condition precedent to issuing a PCN and bringing any associated action. Accordingly, I put the operator to strict proof of compliance with the entirety of Section 14 of the PPSCoP. Any document that contains redactions must not obscure the above conditions. The document must also be dated and signed by identifiable persons, with evidence of their authority to act on behalf of the parties to the agreement. The operator must provide an agreement showing clear authorisation from the landowner for this specific site.
3. Strict proof that the enforcement mechanism (e.g. ANPR or manual patrol) is reliable, synchronised, maintained, and calibrated regularly. The operator must prove the vehicle was present for the full duration alleged and not simply momentarily on site, potentially within a permitted consideration or grace period as defined by the PPSCoP.
4. Strict proof that the Notice to Keeper complies with the Protection of Freedoms Act 2012 (PoFA), if the operator is attempting to rely on keeper liability. Any failure to comply with the mandatory wording or timelines in Schedule 4 of PoFA renders keeper liability unenforceable.
5. Strict proof that the NtK was posted in time for it to have been given within the relevant period. The PPSCoP section 8.1.2(d) Note 2 requires that the operator must retain a record of the date of posting of a notice, not simply of that notice having been generated (e.g. the date that any third-party Mail Consolidator actually put it in the postal system.)
If the assessor reading this really is legally qualified, they will know that without strict proof of landowner authority (VCS v HMRC [2013] EWCA Civ 186), no claim can succeed. They will also know that clear and prominent signage is a prerequisite for contract formation (ParkingEye v Beavis (2015) UKSC 67), and that keeper liability under PoFA is only available where strict statutory conditions are met.
If the assessor chooses to overlook these legal requirements and accept vague assertions or redacted documents from the operator, that will speak for itself—and lend further weight to the growing concern that this appeals service is neither independent nor genuinely legally qualified.
In short, I dispute this charge in its entirety and require full evidence of compliance with the law, industry codes of practice, and basic contractual principles.
A ticket arrived from a shark,
For stopping my car in the dark.
I won’t just concede,
So kindly proceed
And send me the code for POPLA.