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Live cases legal advice => Private parking tickets => Topic started by: tellyaddicts on August 01, 2025, 11:52:30 am

Title: Re: Minster Baywatch NTK at Grosvenor casino Sheffield despite ticket being bought
Post by: b789 on November 05, 2025, 07:28:05 pm
The POPLA decision is not binding on you and you DO NOT pay. For now, email the following formal complaint about this assessors utter incompetence to POPLA:

Quote
Subject: Formal complaint – material errors, QA failure, and concerns about independence (POPLA ref: [REF], Assessor: Paul Garrity, Site: Sheffield Grosvenor Casino, Decision date: [DATE])

Dear Sirs,

Please register this as a formal complaint about the above decision. I am not asking for a reassessment; I know POPLA does not rehear cases. I am asking for a lead-assessor review of the reasoning, a written explanation addressing each point below, and confirmation of what corrective action will be taken. This complaint will be copied to my MP and used to question POPLA’s independence and competence.

Executive summary – the most obvious flaws

1. Paid session conceded; “not authorised” upheld
The operator admits a paid session existed (their own words: a major keying error) and says the £20 charter outcome would have applied. Upholding a full PCN on a “not authorised” premise in the face of an admitted paid session is irrational and rewards poor operator practice.

2. Landowner status mischaracterised
The decision describes Bransby Wilson as “the landowner”. The exhibit says Bransby Wilson Parking Solutions Ltd is a managing agent and that authority applies where the land is not owned by BWPSL. A redacted, internally inconsistent paper naming an agent does not prove landowner authority. POPLA should have required an unredacted, continuous chain from the actual landholder to the operator, current on the material date and covering this site.

3. PoFA keeper liability reduced to postage dates

The decision looks at timing but ignores pleaded content defects that are dispositive:
• PoFA Sch 4 para 9(2)(e)(i): the NtK text invites payment only if the recipient was the driver, rather than inviting the keeper to pay the unpaid parking charges.
• PoFA Sch 4 para 9(2)(a): no specified period of parking; ANPR entry/exit instants are not a parking period.

Strict compliance is required; none of this was analysed.

4. Consideration and grace periods ignored
Entry around 14:02 and ticket around 14:07 meets the consideration period. A two-hour ticket to ~16:07 with exit at ~16:09 sits within the end-of-stay grace. The operator even asserts a 30-minute site grace. The decision does not engage with this at all.

5. “Authority” document lacks integrity and probative value
The paper is “made” 01/04/2011 but signed 28/10/2012, uses “Bransby Wilson Ltd” in the recital but “Bransby Wilson Parking Solutions Ltd” in clause 4, repeats the “LICENCE AGREEMENT” header mid-document with a second clause 4, and redacts the client identity and most of the site schedule. Clause 1 grants only an initial three-month term with continuation by agreement and terminable on one month’s notice. There is no unredacted evidence of a subsisting, site-specific mandate on the material date. Accepting this collage as proof of standing was unreasonable.

6. Retrofitting the NtK with later photos
The decision leans on larger, later images in the bundle to justify the NtK instead of assessing the NtK as served. A defective or incomplete NtK is not cured by evidence produced later.

7.Reliance on rhetoric
The operator’s “generic template” slur is repeated but never evidenced. It does not rebut any pleaded defect and should not feature in a reasoned decision.

Why this matters
These are not marginal judgement calls. They are basic legal and evidential errors: conflating agent with landowner; ignoring an admitted paid session; substituting PoFA timing for PoFA content; overlooking grace; and treating a spliced, redacted document as authority. This undermines confidence in POPLA’s competence and independence.

Requested actions
1. Lead-assessor review of this decision’s reasoning and a written response addressing points 1–7 above for the record.
2. Confirmation that this decision has been marked as a QA failure and what corrective guidance will be issued to assessors on:
• PoFA content (9(2)(e)(i) and 9(2)(a));
• Distinguishing landowner, managing agent, and operator and requiring an unredacted, continuous chain of authority;
• Handling admitted keying-error cases under the Appeals Charter;
• Correct application of consideration and grace periods;
• Assessing the NtK as served rather than back-filled by later exhibits.
3. Confirmation of what process changes POPLA will implement to prevent recurrence.

Further action and context
I have no confidence in this outcome or in POPLA’s independence. I will send a copy of this complaint to my MP to raise the question of oversight and independence in Parliament, given POPLA operates with ATA permission while routinely accepting redacted, incoherent “authority” papers and overlooking statutory requirements.

When the Private Parking (Code of Practice) Act 2019 is finally enforced, bodies that cannot meet basic standards thanks to incompetence or poor training, should have no role. In the meantime, I expect a full written explanation for the record.

Yours faithfully,

[Your name]
Title: Re: Minster Baywatch NTK at Grosvenor casino Sheffield despite ticket being bought
Post by: tellyaddicts on November 05, 2025, 03:40:26 pm
POPLA appeal results are in - unsuccessful (pasted below). I guess I now sit tight and wait for Minster Baywatch to start chasing?

 

Decision
Unsuccessful

Assessor Name
Paul Garrity

Assessor summary of operator case
The operator has issued the Parking Charge Notice (PCN) due to the vehicle was not authorised to use the car park.

Assessor summary of your case
Assessor summary of appellant case The appellant has raised the following points from their grounds of appeal. For the purposes of my decision, I have summarised these below. • A valid ticket was purchased from Bransby Wilson Parking Solutions and displayed in the vehicle window. • Minster Baywatch has not demonstrated it is authorised to enforce parking at a site operated by Bransby Wilson. • The Notice to Keeper does not fully comply with the Protection of Freedoms Act (POFA) 2012. On reviewing the operator’s evidence, the appellant expands on their initial grounds of appeal. In support of their appeal, the appellant has provided an image of the parking ticket a bank statement photo of signage a copy of the notice to hire company and the operator’s response to their appeal. The above evidence has been considered in making my determination.

Assessor supporting rational for decision
When assessing an appeal POPLA considers if the operator has issued the parking charge notice correctly and if the driver has complied with the terms and conditions for the use of the car park displayed on the signs located within the car park. Therefore, the driver is responsible for seeking out these signs, reviewing the displayed terms and conditions and complying with these. The Minster Baywatch signs on this site confirm all vehicles must either have a valid pay and stay session valid pay by phone session or be included on the authorised suer list and failure to comply will result in the issue of a £100 PCN. I note the Bransby Wilson signage on this site provided by the appellant confirms a parking charge will be issued by the designated enforcement company to any unauthorised vehicles remaining on the car park and failing to comply with the terms and conditions. The operator has provided photographic evidence the vehicle remained on site for two hours and eight minutes. The operator has also provided evidence from its online payment report which confirms no payment was made against the full and correct vehicle registration number. POPLA is an evidence-based service, and I can only base my decision on the evidence presented at the time of the appeal. The appellant has not admitted to being the driver. I will therefore be considering their responsibility as keeper of the vehicle. In order for the keeper to be liable for the parking charge, the operator has to follow the strict requirements of Schedule 4 of the Protection of Freedoms Act 2012 (POFA). Having reviewed the evidence, I consider that there looks to be a contract between the driver and the parking operator, and the appellant has not provided a current name and address for service for the driver. Further, the notice sent complies with the relevant provisions. I am satisfied that the operator has met POFA to transfer liability. I now turn to the appellant’s grounds of appeal to determine if they make a material difference to the validity of the parking charge notice. The appellant has provided an image of the parking ticket and a bank statement confirming when making payment, only one character of the vehicle registration was entered, E. The Private Parking Sector Single Code of Practice (The Code) sets the standards its parking operators need to comply with. The Appeals Charter is a statement within the code on how certain circumstances should be handled by the parking operator. This details when a parking charge should be cancelled, and when a parking charge should be reduced when an appeal is based on an error or mitigating circumstances. Section F.3 of the Code lists specific circumstances where a parking operator must reduce a PCN to £20, subject to appropriate evidence being provided. Such as if a driver has paid the tariff or registered their vehicle but they have swapped characters, have digits missing or have entered the wrong registration completely. On reviewing the appellants initial appeal to the operator, the appellant did not advise the driver was a legitimate user of the car park or that a payment was made nor did they provide evidence of the parking ticket. Therefore, as no appropriate evidence was provided at the first appeal stage, the operator was not required to meet the requirement of F.3 of the code. While it is not disputed that a payment was made, by failing to enter the full correct vehicle registration, this ticket is not valid for the vehicle to remain on site. The operator has provided a copy of the contract with the landowner, Bransby Wilson. This contract confirms that Minster Baywatch has been appointed by Bransby Wilson to enforce paring on this site on its behalf. This is confirmed on the Bransby Wilson signage that enforcement is carried out by the designated enforcement company. Section 14.1 of the Code states that where controlled land is being managed on behalf of a landowner, written confirmation must be obtained before a parking charge can be issued On reviewing this contract and as the appellant has not provided any evidence to demonstrate otherwise, I am satisfied that Minster Baywatch has been appointed by Bransby Wilson to enforce parking on this site. A valid ticket was purchased from Bransby Wilson Paring Solutions and displayed in the vehicle window. The Notice to Keeper was issued within the relevant period and clearly advises if the keeper was not the driver, they should provide the operator the full name of the driver and full address where a notice can be service and to pass the notice onto them. The notice also advises that if the charge has not been paid and the operator does not know the name and current address of the driver, it has the right to recover any unpaid charge from the registered keeper. Within its case file, the operator also provided clear and larger copies of the images of the vehicle entering and exiting the car park. These images clearly show the time and date stamped are included directly on these images. Therefore, while it is noted the actual images on the notice are smaller, the times provided match the time stamps on the larger images. As such, I am satisfied that the notice fully meets the requirements of POFA. On reviewing the operator’s evidence, the appellant expands on their initial grounds of appeal. As I have considered these above, I will not comment further. The appellant has also provided the operators response to their appeal. As I have reviewed this within the case file, I will not comment further. POPLA’s role is to assess if the operator has issued the PCN in accordance with the conditions of the contract. As the terms and conditions of the car park have not been met, I conclude that the operator has issued the PCN correctly, and the appeal is refused
Title: Re: Minster Baywatch NTK at Grosvenor casino Sheffield despite ticket being bought
Post by: tellyaddicts on September 12, 2025, 05:43:35 pm
Thanks so much for such a full response - fantastic of you.
Title: Re: Minster Baywatch NTK at Grosvenor casino Sheffield despite ticket being bought
Post by: b789 on September 11, 2025, 08:55:39 pm
You can just copy and paste the following into he response webform, It is well within the 10,000 character limit:

Quote
This response to the operator’s evidence pack refers to my three pleaded grounds and shows what has not been rebutted.

Valid ticket was purchased (operator now concedes “major keying error”)

The operator’s own evidence accepts there was a paid session and says they would have offered the £20 keying-error outcome. That is a concession that payment existed.

Their original allegation “not authorised to use the car park” is therefore incorrect on its face. A paid, mis-keyed VRM is not “no authorisation”. Nothing in their bundle justifies pursuing a full PCN on that false premise.

Their photos confirm mixed branding: the tariff boards and pay machine identify Bransby Wilson; payment on the bank statement is to Bransby Wilson. That is who the consumer reasonably believes they are contracting with.

The redacted, inconsistent “licence agreement” produced after the fact does not cure the ambiguity presented to the motorist at the point of contract and does not show a clear, current mandate for this site on the material date.

Under CRA 2015 s.68–69, any ambiguity about the contracting party is resolved in the consumer’s favour. The operator has not rebutted this; if anything their own material entrenches it.

NtK non-compliance with PoFA and evidence integrity issues remain unaddressed

The operator’s comments about “timescales” do not engage with the pleaded PoFA defects. The NtK failed to include the mandatory invitation to the keeper to pay the unpaid parking charges (PoFA Sch.4 para 9(2)(e)(i)).

That omission is dispositive: keeper liability cannot arise when any one of the para 9(2) requirements is missing.

Additionally, the NtK relied on cropped ANPR stills with times typed beneath rather than embedded. That breaches the PPSCoP v1.1:

- Clause 7.3(b): images used as the basis for a charge must “bear an accurate time and date stamp.”

- Clause 7.4: photographic evidence must not be digitally altered except to blur faces/other VRMs, or to enhance the VRM for clarity (not to change characters). Producing uncropped/stamped images later does not repair the defect in the NtK actually served.

Also, the NtK still does not specify a “period of parking” as required by PoFA para 9(2)(a); ANPR entry/exit instants are not the same as a period parked. None of these PoFA points has been answered by the operator.

Standing not proved; CRA 2015 s.69 applies due to consumer-facing ambiguity

The exhibited “Licence Agreement” is not proof of standing. It is a muddled, redacted collage that fails to show a live, site-specific mandate in Minster Baywatch’s own name on the material date. It invites ridicule rather than confidence for the following plain reasons.

The parties are not even identified coherently. The recital says the agreement is made between “Bransby Wilson Ltd (the Client)” and “Minster Baywatch Ltd (the Company)”, yet clause 4 suddenly switches to “Bransby Wilson Parking Solutions Ltd” as the entity supposedly confirming authority and instructing Minster Baywatch. If the drafter cannot keep the principal’s legal name straight within the same two-page instrument, the document is not reliable evidence of who authorised what.

The dates do not withstand scrutiny. It purports to be “made on 1 April 2011” but the only signatures are dated 28 October 2012. There is no visible clause granting retroactive effect. On its face it is either sloppily back-dated or compiled. In either case, the operator still had to prove subsisting authority for this specific site on 12 July 2025. They have not.

Clause 1 makes the weakness worse, not better. It grants an initial three-month term and says continuation is only if both parties agree, thereafter terminable on one month’s notice. The operator has provided no evidence of any continuing agreement, no proof that no termination was served, and no unredacted correspondence bridging the gap to 2025. The clause that should save them simply highlights what is missing.

Redactions gut the chain of authority. The client’s identity and address are concealed; most of the site schedule is blacked out. POPLA cannot verify who the principal is, what was authorised, or whether “Sheffield, G Casino, S2 4BG” was within scope and remained so on the material date. A contract that hides its principal and scope is unworthy of reliance.

Document integrity is compromised. After clauses 1–4, the header “LICENCE AGREEMENT” bizarrely reappears and a different clause 4 follows. There are no page numbers or initials. That looks like pages from different versions spliced together. POPLA cannot be expected to guess which version, if any, governed this site.

Even on its own wording, Minster Baywatch is only acting “on behalf of” Bransby Wilson. There is no clear, unredacted grant of the right to issue and recover charges in Minster Baywatch’s own name. Meanwhile, the consumer-facing materials and the card merchant descriptor identify Bransby Wilson as the creditor. If Minster Baywatch wishes to contradict the face of the consumer contract, it must produce a crystal-clear, current mandate. This is anything but.

In short: a confusing recital, inconsistent party names, execution long after the stated “made” date, a three-month initial term with no proof of continuation, heavy redactions that conceal the principal and scope, and a spliced clause structure. This is a risible attempt to dress up a lack of standing as a contract. POPLA should give it negligible weight and allow the appeal on standing alone.

Conclusion

On the appellant’s three pleaded grounds, the operator either concedes the point (payment) or fails to answer it (standing; PoFA content). The appeal should be allowed.
Title: Re: Minster Baywatch NTK at Grosvenor casino Sheffield despite ticket being bought
Post by: tellyaddicts on September 11, 2025, 02:14:28 pm
*update*

I have received Minster Baywatch's evidence in response to my POPLA appeal. Redacted version shared here:  Redacted Evidence (https://drive.google.com/file/d/1NXEVHZYtL21Xy_gut_9b8_RvWcYauZDu/view?usp=sharing)

I don't think they have effectively rebutted any of the points of appeal. My reasoning is as follows.

1. That a valid ticket was purchased for the vehicle from Bransby Wilson Parking Solutions
They have showed that there was a major keying error but confirmed that a ticket was purchased (and said they would have offered the £20 rate had I raised this with them, presumably to cover that grounds of rejection by POPLA).

2. that Minster Baywatch Ltd has not demonstrated that they are authorised to enforce parking at a site operated by Bransby Wilson - Consumer Rights Act (CRA) 2015, Section 69
They have provided lots of pictures of signs and a copy of an agreement between themselves and Bransby Wilson, but in doing so have confirmed that some signs (those near the pay machine) don't say Minster Baywatch. I think this shows ambiguity and, as you have told me, Under CRA 2015 Section 69 any ambiguity must be resolved in favour of the consumer. The agreement between the companies seems irrelevant - how can the driver have contracted with them on the basis of information they are only now supplying?

3. that the Notice to Keeper letter does not fully comply with ALL the requirements of the Protection of Freedoms Act (PoFA) 2012.
They don't seem to have engaged with this at all (and instead make an irrelevant point about timescales). However, the non-cropped pictures they have now supplied confirm that those in the NtK were cropped which demonstrates that the NtK is not POFA compliant. The point that the Ntk doesn't invite the keeper to pay the charge stands uncontested.


I plan to respond along these lines before the 7 day deadline. Any other advice or suggestions anyone can offer are very much appreciated.


Title: Re: Minster Baywatch NTK at Grosvenor casino Sheffield despite ticket being bought
Post by: tellyaddicts on September 09, 2025, 06:40:41 pm
Great, thank you.
Title: Re: Minster Baywatch NTK at Grosvenor casino Sheffield despite ticket being bought
Post by: b789 on September 09, 2025, 06:36:10 pm
It's only POPLA. Just send it and when the operator submits their evidence, you will have an opportunity to see if they've rebutted your appeal points and respond accordingly.
Title: Re: Minster Baywatch NTK at Grosvenor casino Sheffield despite ticket being bought
Post by: tellyaddicts on September 09, 2025, 05:31:48 pm
I have edited the response to take on the comments above - still available at the link above. The revised text (without pictures) is as follows. Still not sure whether to mention the signs that do say Minster Baywatch as part of my second point.

I plan to submit tonight, but any thoughts and suggestions still welcome.

Thanks as ever - I really appreciate all the help. 

=======================================================================================================================================
Parking Charge Reference: [XXXXXXX]
Operator: Minster Baywatch
Alleged Contravention: Vehicle was not authorised to use the car park
Vehicle Registration: [XXXXXXX]

Background
I received a letter from Minster Baywatch Ltd on 26th July 2025 (dated 18th July 2025) titled “Notice to Keeper or Hire Company”. This letter identified me as the keeper of a vehicle that they claimed had breached “stated contractual terms and conditions of use” of a car park and asked me to identify the driver. The letter states if I fail to do so, they have a “right to recover any unpaid part of the parking charge” from me as the registered keeper.  I attach photos of the front and back of this letter as evidence at Annex 1.

I subsequently appealed to Minster Baywatch on the basis that this Notice to Keeper letter does not fully comply with ALL the requirements of the the Protection of Freedoms Act (PoFA) 2012, and therefore they are unable to hold the keeper of the vehicle liable for the charge. This appeal was rejected and I was advised to appeal to POPLA.

Outline of the basis of my appeal
My appeal to you is on three distinct grounds that I would like you to consider individually and in full:

1. That a valid ticket was purchased for the vehicle from Bransby Wilson Parking Solutions; 
2. that Minster Baywatch Ltd has not demonstrated they are authorised to enforce parking at a site operated by Bransby Wilson - Consumer Rights Act (CRA) 2015, Section 69; and
3. that the Notice to Keeper letter does not fully comply with ALL the requirements of the Protection of Freedoms Act (PoFA) 2012.

Evidence supporting my appeal
This section outlines my points of appeal in more detail and provides supporting evidence.

1. A valid ticket was purchased for the vehicle from Bransby Wilson Parking Solutions


The Notice to Keeper states that the “Vehicle was not authorised to use the car park”. In the response to my initial appeal, Minster Baywatch Ltd stated ”After having thoroughly examined the payment records and authorised list for the date and time in question, we can find no payment nor authorised listing having been made for your vehicle or a vehicle with a similar registration”. The full response to my appeal is attached at Annex 2.

In fact, a ticket was bought for the vehicle and displayed in the windscreen. Fig 1 shows a picture of that ticket and Fig 2 a redacted bank statement showing the purchase of the ticket, reflected on the payer’s account the following day as a payment to “Bransby Wilson". The signage around the pay machine for the car park (see fig.3) and the machine itself (see fig. 4) both display the name “Bransby Wilson Parking Solutions". These signs do not contain the name “Minster Baywatch Ltd” or similar. These are distinct companies registered separately at Companies House.  Any contract entered was with Bransby Wilson and not Minster Baywatch Ltd. This may explain why Minster Baywatch Ltd are not able to find a relevant transaction - the car park does not appear to be operated by them and payment was not made to them.

So the basis for the PCN - that a payment for parking was not made - is false and therefore the PCN is invalid. Note that this information does not confirm the identification of the driver and no inference or assumptions can be made.


2. Minster Baywatch Ltd has not demonstrated that they are authorised to enforce parking at a site operated by Bransby Wilson - Consumer Rights Act (CRA) 2015, Section 69

As shown above, Minster Baywatch Ltd are not named on the signs at or near the pay machine. These display the name Bransby Wilson Parking Solutions. In addition, payments made by card at this car park show as being made to “Bransby Wilson Parking” on a bank statement. The RingGo app and website both show Bransby Wilson as the operator of the car park.

Minster Baywatch Ltd and Bransby Wilson Parking Solutions are distinct companies registered separately at Companies House. No clear contractual link is shown to justify enforcement by Minster Baywatch. Ambiguity in contract terms must be interpreted in favor of the consumer. Drivers cannot be expected to contract with a party not clearly identified on the signage.

The signage and payment details would lead any reasonable driver to believe they are contracting with Bransby Wilson Parking Solutions. No reasonable driver would believe they were entering a contract with Minster Baywatch Ltd. Minster Baywatch Ltd has not demonstrated they are authorised to enforce parking at a site operated by Bransby Wilson. Under CRA 2015, Section 69, any ambiguity must be resolved in favour of the consumer. The PCN is therefore legally unenforceable.


3. The Notice to Keeper letter does not fully comply with ALL the requirements of the Protection of Freedoms Act (PoFA) 2012

The photos that Minster Baywatch Ltd have supplied in the Notice to Keeper letter do not have timestamps. The time and date is written-in underneath.  This is a breach of the Private Parking Sector Single Code of Practice (PPSCoP) section 7.3(b) which states:

Photographic evidence must not be used by a parking operator as the basis for issuing a parking charge unless: the images bear an accurate time and date stamp.

The shape of the photographs and lack of a timestamp show that these photos have been digitally altered, and so PPSCoP section 7.4 also applies:

Parking operators must not digitally or by other means alter images used as photographic evidence other than:
a) to blur faces or the VRMs of other vehicles in the image in accordance with their GDPR
obligations; or
b) to enhance the image of the VRM for clarity, but not to alter the letters and numbers displayed.

The Notice to Keeper  also fails to comply with PoFA paragraph 9(2)(e)(i) as there is no invitation for the Keeper to pay the charge.

The Notice to Keeper is, therefore, not compliant with ALL the requirements of PoFA which means that if the unknown driver is not identified, they cannot transfer liability for the charge from the unknown driver to the known keeper.

There is no legal obligation on the known keeper (the recipient of the Notice to Keeper) to reveal the identity of the unknown driver and no inference or assumptions can be made.


Summary
Taken together this evidence shows that the PCN was not valid in the first place - a ticket was in fact purchased and any contract for parking was made with Bransby Wilson and not Minster Baywatch.  Therefore the Notice to Keeper letter from Minster Baywatch is invalid, but that notice also fails on its own terms as it is not compliant with relevant law. Therefore I conclude I am under no obligation to identify the driver and as the keeper of the vehicle not liable for any charge.
Title: Re: Minster Baywatch NTK at Grosvenor casino Sheffield despite ticket being bought
Post by: tellyaddicts on September 09, 2025, 09:50:36 am
Any other comments before I submit tonight gratefully received.
Title: Re: Minster Baywatch NTK at Grosvenor casino Sheffield despite ticket being bought
Post by: tellyaddicts on September 08, 2025, 06:23:02 pm
Got it, keeper. Will edit.
Title: Re: Minster Baywatch NTK at Grosvenor casino Sheffield despite ticket being bought
Post by: b789 on September 08, 2025, 06:12:34 pm
This is bolleaux:

Quote
I received a letter from Minster Baywatch Ltd on 26th July 2025 (dated 18th July 2025) titled “Notice to Keeper or Hire Company”. This letter identified me as the owner of a vehicle

Can you point us in the direction to the official “Register of Owners” where they supposedly identified you as the “owner”?
Title: Re: Minster Baywatch NTK at Grosvenor casino Sheffield despite ticket being bought
Post by: tellyaddicts on September 08, 2025, 03:57:36 pm
Good point, I will rejig for the final version.
Title: Re: Minster Baywatch NTK at Grosvenor casino Sheffield despite ticket being bought
Post by: DWMB2 on September 08, 2025, 03:51:11 pm
I've not read the appeal yet (I will in due course), but if it were me appealing, I'd be tempted to lead with point #3, then move on to the other points.

Your technical appeal points around PoFA and Branby Wilson etc. are all perfectly valid, but the fact that the driver paid for their stay in full (and left within the applicable grace period) rebuts the entire basis of the parking charge, which was issued because they allege the vehicle was not authorised to be there.
Title: Re: Minster Baywatch NTK at Grosvenor casino Sheffield despite ticket being bought
Post by: tellyaddicts on September 08, 2025, 02:46:49 pm
Thanks for everyone's help on this thread. I know I have a few more days, but keen to get this off my plate.

Here is a link to the appeal I plan to submit, based on the advice above, with personal details redacted. I plan to send in an (unredacted) pdf version of this document once it is finalised - I assume that is a valid way to do my appeal?

https://docs.google.com/document/d/1XdLd8prR3E9bAEkTRtT4dPSy2sLvzGJaybWA9rIJ4EM/edit?usp=sharing (https://docs.google.com/document/d/1XdLd8prR3E9bAEkTRtT4dPSy2sLvzGJaybWA9rIJ4EM/edit?usp=sharing)

I also copy the text below without the pictures.

Grateful for anyone's advice on how I can improve this. In particular

1. I have not made reference to the signs that do mention Minister Baywatch in the car park - as it felt like I was making their case for them - but I could include if I want to emphasise the point that it is confusing rather than (as now) anyone reasonable would think they are contracting with Minister Baywatch.

2. Is there anything I'm missing?

3. Is the format ok - I've just tried to structure as logically as possible?


As ever, thanks in advance for any help anyone can offer.

___________________________________________________________________________________________________________


Parking Charge Reference: [XXXXXXX]
Operator: Minster Baywatch
Alleged Contravention: Vehicle was not authorised to use the car park
Vehicle Registration: [XXXXXXX]

Background
I received a letter from Minster Baywatch Ltd on 26th July 2025 (dated 18th July 2025) titled “Notice to Keeper or Hire Company”. This letter identified me as the owner of a vehicle that they claimed had breached “stated contractual terms and conditions of use” of a car park and asked me to identify the driver. The letter states if I fail to do so, they have a “right to recover any unpaid part of the parking charge” from me as the registered keeper.  I attach photos of the front and back of this letter as evidence at Annex 1.

I subsequently appealed to Minster Baywatch on the basis that this Notice to Keeper letter does not fully comply with ALL the requirements of the the Protection of Freedoms Act (PoFA) 2012, and therefore they are unable to hold the keeper of the vehicle liable for the charge. This appeal was rejected and I was advised to appeal to POPLA.

Outline of the basis of my appeal
My appeal to you is on three distinct grounds that I would like you to consider individually and in full:

1. That Minster Baywatch Ltd has not demonstrated they are authorised to enforce parking at a site operated by Bransby Wilson - Consumer Rights Act (CRA) 2015, Section 69;
2. that the Notice to Keeper letter does not fully comply with ALL the requirements of the Protection of Freedoms Act (PoFA) 2012; and
3. that a valid ticket was purchased for the vehicle. 


Evidence supporting my appeal
This section outlines my points of appeal in more detail and provides supporting evidence.

1. Minster Baywatch Ltd has not demonstrated they are authorised to enforce parking at a site operated by Bransby Wilson - Consumer Rights Act (CRA) 2015, Section 69

Minster Baywatch Ltd are not named on the signs at or near the pay machine.
The signs at the pay machine for the car park (see fig.1) and the machine itself (see fig. 2) display the name “Bransby Wilson Parking Solutions". These signs do not contain the name “Minster Baywatch Ltd” or similar. These are distinct companies registered separately at Companies House.

In addition, payments made by card at this car park show as being made to “Bransby Wilson Parking” on the bank statement. The RingGo app and website both show Bransby Wilson as the operator of the car park.

The signage and payment details would lead any reasonable driver to believe they are contracting with Bransby Wilson Parking Solutions. No reasonable driver would believe they were entering a contract with Minster Baywatch Ltd. Minster Baywatch Ltd has not demonstrated they are authorised to enforce parking at a site operated by Bransby Wilson. Under CRA 2015, Section 69, any ambiguity must be resolved in favour of the consumer. The PCN is therefore legally unenforceable.


2. The Notice to Keeper letter does not fully comply with ALL the requirements of the Protection of Freedoms Act (PoFA) 2012

The photos that Minster Baywatch Ltd have supplied in the Notice to Keeper letter do not have timestamps. The time and date is written-in underneath.  This is a breach of the Private Parking Sector Single Code of Practice (PPSCoP) section 7.3(b) which states:

Photographic evidence must not be used by a parking operator as the basis for issuing a parking charge unless: the images bear an accurate time and date stamp.

The shape of the photographs and lack of a timestamp show that these photos have been digitally altered, and so PPSCoP section 7.4 also applies:

Parking operators must not digitally or by other means alter images used as photographic evidence other than:
a) to blur faces or the VRMs of other vehicles in the image in accordance with their GDPR
obligations; or
b) to enhance the image of the VRM for clarity, but not to alter the letters and numbers displayed.

The Notice to Keeper  also fails to comply with PoFA paragraph 9(2)(e)(i) as there is no invitation for the Keeper to pay the charge.

The Notice to Keeper is, therefore, not compliant with ALL the requirements of PoFA which means that if the unknown driver is not identified, they cannot transfer liability for the charge from the unknown driver to the known keeper.

There is no legal obligation on the known keeper (the recipient of the Notice to Keeper) to reveal the identity of the unknown driver and no inference or assumptions can be made.


3. A valid ticket was purchased for the vehicle
The Notice to Keeper states that the “Vehicle was not authorised to use the car park”. In the response to my initial appeal, Minster Baywatch Ltd stated ”After having thoroughly examined the payment records and authorised list for the date and time in question, we can find no payment nor authorised listing having been made for your vehicle or a vehicle with a similar registration”. The full response to my appeal is attached at Annex 2.

In fact, a ticket was bought for the vehicle and displayed in the windscreen. Fig 3 shows a picture of that ticket and Fig 4 a redacted bank statement showing the purchase of the ticket, reflected on the account the following day as a payment to “Bransby Wilson".  In line with point 1 above, any contract entered was with Bransby Wilson and not Minster Baywatch Ltd.

So the basis for the PCN - that a payment for parking was not made - is false and therefore the PCN is invalid. Note that this information does not confirm the identification of the driver and no inference or assumptions can be made.

Summary
Taken together this evidence shows that the PCN was not valid in the first place - a ticket was in fact purchased - and any contract for parking was made with Bransby Wilson and not Minster Baywatch.  Therefore the Notice to Keeper letter from Minster Baywatch is invalid, but that notice also fails on its own terms as it is not compliant with relevant law. Therefore I conclude I am under no obligation to identify the named driver and as the keeper of the vehicle not liable for any charge.
Title: Re: Minster Baywatch NTK at Grosvenor casino Sheffield despite ticket being bought
Post by: DWMB2 on September 07, 2025, 11:37:41 pm
It was the "E" next to the "3.00" on the ticket that made me ask - I was considering the possibility that for one reason or another, only 1 letter of the VRM had been registered when paying. It's something I've seen happen before.
Title: Re: Minster Baywatch NTK at Grosvenor casino Sheffield despite ticket being bought
Post by: tellyaddicts on September 07, 2025, 10:29:56 pm
No, but the question intrigues me!
Title: Re: Minster Baywatch NTK at Grosvenor casino Sheffield despite ticket being bought
Post by: DWMB2 on September 07, 2025, 10:16:37 pm
Should there not be a 10 minute grace period? That's a major breach of the joint code.
There should be, yes, but Minster Baywatch's claim is that no payment was made at all.

OP - does the vehicle's VRM (reg plate) begin with 'E', by any chance?
Title: Re: Minster Baywatch NTK at Grosvenor casino Sheffield despite ticket being bought
Post by: tellyaddicts on September 07, 2025, 10:16:06 pm
They are saying no record of the payment for the registration rather than overstaying - so could be an error on their part or the registration keyed incorrectly - but I agree any overstaying is very minimal.
Title: Re: Minster Baywatch NTK at Grosvenor casino Sheffield despite ticket being bought
Post by: ixxy on September 07, 2025, 10:11:17 pm
Should there not be a 10 minute grace period? That's a major breach of the joint code.
Title: Re: Minster Baywatch NTK at Grosvenor casino Sheffield despite ticket being bought
Post by: tellyaddicts on September 07, 2025, 09:57:36 pm

Thanks, that's good to know. Should I put together a POPLA appeal based on:

1. Non-compliance of the NtK (with the reasons you posted above - Confusion over who contract is with (CRA 2015, Section 69); No time stamp on photograph (PPSCoP section 7.3(b)); Cropping the image (section 7.4); No invitation for the Keeper to pay the charge. (PoFA paragraph 9(2)(e)(i)).

2. Evidence that a ticket was bought (but mindful not to identify the driver)


Anything else I should include or other things to note when drafting? Should I post that back here for any comments before submitting?

Thanks again for help- It is really appreciated.
Title: Re: Minster Baywatch NTK at Grosvenor casino Sheffield despite ticket being bought
Post by: b789 on September 07, 2025, 08:40:36 pm
Your POPLA appeal code is valid for 33 days from the date of the initial appeal rejection. Count 33 days from that date.

They allow 5mdsysmfor service of the POPLA code plus 28 days.
Title: Re: Minster Baywatch NTK at Grosvenor casino Sheffield despite ticket being bought
Post by: tellyaddicts on September 07, 2025, 02:09:45 pm
My POPLA deadline is Tuesday so I'm going to have to put my appeal together in the next 24 hours. If anyone does have any advice on what to include I would very much appreciate it.

Title: Re: Minster Baywatch NTK at Grosvenor casino Sheffield despite ticket being bought
Post by: tellyaddicts on September 01, 2025, 10:06:03 am
Apologies for the delay in returning to this thread, I have been on holiday.

Whilst away I received the expected rejection of my appeal from Minster Baywatch on the 12th August. The text of that response is below.

Any helpful suggestions for how to draft my appeal to POPLA gratefully received. I need to submit by 9th September at the latest, but hope to get done this week.

Thanks again for your help.
 

Further to your appeal received on 05/08/2025 regarding the above charge, we note your comments; however, when this charge was issued this vehicle was in contravention of the agreed terms and conditions for all users of this site.

Your appeal has been reviewed along with all evidence gathered at the time of the breach of the site rules.
There is a contract to enter this site, as stipulated by signage located around the car park, signage which clearly states that the fee for the duration of parking must be covered or a vehicle driver must record their details at any provisioned vehicle registration system within the Grosvenor Casino on use of the venue as a customer on each visit. Your vehicle was observed to contravene this condition. After having thoroughly examined the payment records and authorised list for the date and time in question, we can find no payment nor authorised listing having been made for your vehicle or a vehicle with a similar registration.
We are therefore unable to cancel the charge as it was issued correctly. You have now reached the end of our internal appeals procedure and must choose to do one of the following: Pay the charge at the prevailing rate of £60.00 within 14 days. Please note that after this time the discounted rate will no longer apply and the Charge will rise to £100.00.

MINSTER BAYWATCH LIMITED 
P.O. Box 731 York YO31 7WP Website: www.minsterbaywatch.co.uk 
Registered Address Minster Baywatch Ltd Popeshead Court Offices, Peter Lane, York YO1 8SU Registered in England and Wales, Company Registration Number 07517434 

You can submit a further appeal to the Independent Appeals Service, POPLA (Parking on Private Land Appeals) using the POPLA code provided above, any appeal to POPLA must be made within 28 days. Please note that where a charge has been issued in Scotland or Northern Ireland, only the driver may appeal to POPLA. If you appeal to POPLA and you withdraw your appeal or your appeal is rejected, the option to pay at the discounted amount of £60.00 will no longer apply and the full amount of £100.00 will be due. Further details on how to appeal to POPLA can be found on their website, www.popla.co.uk.

If you choose to do nothing, after 35 days we will seek to recover the monies owed to us via our debt recovery procedures and may proceed with Court action against you. By law we are also required to inform you that Ombudsman Services (www.ombudsman-services.org/) provide an alternative dispute resolution service that would be competent to deal with your appeal. However, we have not chosen to participate in their alternative dispute resolution service. As such should you wish to appeal then you must do so to POPLA, as explained above.

To support our eligibility to pursue this Parking Charge Notice, we would like to draw your attention to the fact that on 4th November 2015 there was a landmark Court decision that saw a motorist challenge a Parking Charge Notice through the Court system of England and Wales with the final appeal to the Supreme Court. Where, in a final decision made by the Supreme Court Judges, a Judgement was handed down supporting the view that a parking charge should be viewed as an effective deterrent. The judgment confirmed the parking charge was lawful and motorists parking on private land must comply with the advertised terms and conditions. Further information regarding this judgement can be found at www.supremecourt.uk/cases/uksc-2015-0116.html
Payments can be made online 24-hours a day at www.minsterbaywatch.co.uk or via our automated phone payment system on 03330 230973. Alternative payment methods are available - please refer to your original charge for details.

Yours sincerely,

Appeals Department

Minster Baywatch Ltd


Title: Re: Minster Baywatch NTK at Grosvenor casino Sheffield despite ticket being bought
Post by: b789 on August 02, 2025, 12:03:13 pm
Yes, you can use the fact that a ticket was purchased, but to be honest, don't pin too much hope on POPLA either. If it is successful, great. If it isn't, it's not binding and you don't pay.
Title: Re: Minster Baywatch NTK at Grosvenor casino Sheffield despite ticket being bought
Post by: tellyaddicts on August 02, 2025, 10:21:35 am
Thanks so much for such a helfpul reply.

Would i deploy the fact the driver actually bought a ticket if it goes to POPLA?

You are correct, there is no time stamp on the photos provided - the time is written underneath.

Title: Re: Minster Baywatch NTK at Grosvenor casino Sheffield despite ticket being bought
Post by: b789 on August 02, 2025, 08:59:42 am
This situation has been successfully challenged in court in the past. The car park signage prominently displays Bransby Wilson Parking Solutions as the operator, while the PCN is issued by Minster Baywatch.

These are distinct companies registered separately at Companies House. No clear contractual link is shown to justify enforcement by Minster Baywatch. Ambiguity in contract terms must be interpreted in favor of the consumer. Drivers cannot be expected to contract with a party not clearly identified on the signage.

The signage creates confusion about who the contracting party is. No reasonable driver would believe they were entering a contract with Minster Baywatch. Minster Baywatch has not demonstrated they are authorised to enforce parking at a site operated by Bransby Wilson.

Under CRA 2015, Section 69, any ambiguity must be resolved in favour of the consumer. The PCN is therefore legally unenforceable.

Whilst any initial appeal will fail, there is a possibility that POPLA would uphold the argument but even if it doesn't, it would fail if they ever tried to make claim in court.

There is another point that has succeeded at POPLA... Is there a timestamp on those photos on the Notice to Keeper (NtK)? If not, then they have been cropped or altered, which is a breach of the PPSCoP section 7.3(b) which states:

Photographic evidence must not be used by a parking operator as the basis for issuing a
parking charge unless: the images bear an accurate time and date stamp.

Also, section 7.4 applies...

Parking operators must not digitally or by other means alter images used as photographic
evidence other than:
a) to blur faces or the VRMs of other vehicles in the image in accordance with their GDPR
obligations; or
b) to enhance the image of the VRM for clarity, but not to alter the letters and numbers displayed.

The NtK also fails to comply with PoFA paragraph 9(2)(e)(i) as there is no invitation for the Keeper to pay the charge. There is no legal obligation on the known keeper (the recipient of the Notice to Keeper (NtK)) to reveal the identity of the unknown driver and no inference or assumptions can be made.

The NtK is not compliant with all the requirements of PoFA which means that if the unknown driver is not identified, they cannot transfer liability for the charge from the unknown driver to the known keeper.

Use the following as your appeal which will be rejected but will get you the POPLA code. No need to embellish or remove anything from it:

Quote
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. Minster Baywatch (MB)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. MB have no hope at POPLA, so you are urged to save us both a complete waste of time and cancel the PCN.
Title: Minster Baywatch NTK at Grosvenor casino Sheffield despite ticket being bought
Post by: tellyaddicts on August 01, 2025, 11:52:30 am
I received a NTK on 25th July (dated 18 July) claiming that a vehicle for which I am the registered keeper had breached the terms and conditions of parking at the location "Sheffield, Grosvenor Casino, S2 4BG" on 12th July 2025.

Specifically that the "Vehicle was not authorised to use the car park".

Looking at other cases here, I think the most pertinent facts are:


I have yet to take any action. I'd be grateful for any advice on how best to proceed from the fantastic people on this forum.





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