Free Traffic Legal Advice

Live cases legal advice => Private parking tickets => Topic started by: 8vaibhav on August 07, 2025, 08:42:55 am

Title: Re: NPC Notice to Hirer: Parked on Pavement
Post by: 8vaibhav on October 02, 2025, 09:55:40 pm
Sharing a good news here, many thanks to the amazing help from here. Kudos!

Parking Charge Number (PCN): xxxxxx
Vehicle Registration: yyyyy
Issued On: 30/07/2025
Issued By: National Parking Control Group Ltd

Appeal Outcome: Accepted

The Adjudicators comments are as follows:

"This PCN was issued on the basis that the Appellant was parked on a pavement which is an area where no parking is permitted. The Appellant appeals the PCN on a number of grounds including that the Notice to Hirer is defective as it doesn't comply with PoFA; specifically paragraphs 13 and 14 of Schedule 4. I have checked the requirements of those sections and read the Notice to Hirer that is provided. The Appellant states that the documents referred to in paragraph 13(2) which the Operator is required to serve on the Hirer together with the Notice to Hirer have not been served on him. The Notice to Hirer makes no mention of these documents and no copy is provided by the Operator (only a copy of the transfer of liability from the registered keeper). As such, I cannot be satisfied that the required documents were served on the Appellant and I cannot be satisfied that the requirements of PoFA have been complied with. As such I will allow the appeal.

I have considered all the issues raised by both parties in this Appeal and I am not satisfied that the Operator has established that the Parking Charge Notice was properly issued and therefore this Appeal is allowed. "


As your appeal has been accepted, the charge has been cancelled by the operator and you do not need to take any further action.

Yours Sincerely,
The Independent Appeals Service
Title: Re: NPC Notice to Hirer: Parked on Pavement
Post by: b789 on August 21, 2025, 12:18:36 pm
The odds of a claim actually going as far as a hearing are very small. The vast majority of cases that go to a claim are either struck out, discontinued or won.

If it ever went to a hearing, then you can look at this short video that explains the process. It's not Rumpole of the Bailey. https://youtu.be/n93eoaxhzpU?feature=shared

As for how a CCJ could "happen", just read this:

Nothing we advise on here will make anyone get a CCJ.

Quote
A County Court Judgment (CCJ) does not just happen—it follows a clear legal process. If someone gets a Parking Charge Notice (PCN) from a private parking company, here's what happens step by step:

1. Parking Charge Notice (PCN) Issued

• The parking company sends a letter (Notice to Keeper) demanding money.
• This is not a fine—it’s an invoice for an alleged breach of contract.

2. Opportunity to Appeal

• The recipient can appeal to the parking company.
•If rejected, they may be able to appeal to POPLA (if BPA member) or IAS (if IPC member).
• If an appeal is lost or ignored, the parking company demands payment.

3. Debt Collection Letters

• The parking company might send scary letters or pass the case to a debt collector.
• Debt collectors have no power—they just send letters and can be ignored.
No CCJ happens at this stage.

4. Letter Before Claim (LBC)

• If ignored for long enough, the parking company (or their solicitor) sends a Letter Before Claim (LBC).
• This is a warning that they may start a court case.
• The recipient has 30 days to reply before a claim is filed.
No CCJ happens at this stage.

5. County Court Claim Issued

• If ignored or unpaid, the parking company may file a claim with the County Court.
• The court sends a Claim Form with details of the claim and how to respond.
• The recipient has 14 days to respond (or 28 days if they acknowledge it).
No CCJ happens at this stage.

6. Court Process

• If the recipient defends the claim, a judge decides if they owe money.
• If the recipient ignores the claim, the parking company wins by default.
No CCJ happens yet unless the recipient loses and ignores the court.

7. Judgment & Payment

• If the court rules that money is owed, the recipient has 30 days to pay in full.
• If they pay within 30 days, no CCJ goes on their credit file.
• If they don’t pay within 30 days, the CCJ stays on their credit file for 6 years.

Conclusion

CCJs do not appear out of thin air. They only happen if:

• A parking company takes the case to court.
• The person loses or ignores the case.
• The person fails to pay within 30 days.

If you engage with the process (appeal, defend, or pay on time), no CCJ happens.
Title: Re: NPC Notice to Hirer: Parked on Pavement
Post by: 8vaibhav on August 21, 2025, 10:39:33 am
It's not going to make any difference to the IAS decision. In the vast majority of IAS decisions, they are going to back their brother parking firms. The IAS is a kangaroo court.
Thanks.
Just saw status updated online at IAS to "appeal decision pending" now. Meaning the operator chose to submit no further evidence or counter to my rebuttal.

However, an IAS decision is not binding. The majority of these cases are won after a county court claim is issued, with the vast majority being discontinued.
How likely would be a county court claim after IAS reject my appeal? Does it involve physically going to the court at any point or is there a chance of CCJ been raised while a challenge is still ongoing?
Title: Re: NPC Notice to Hirer: Parked on Pavement
Post by: b789 on August 21, 2025, 10:29:35 am
It's not going to make any difference to the IAS decision. In the vast majority of IAS decisions, they are going to back their brother parking firms. The IAS is a kangaroo court.

However, an IAS decision is not binding. The majority of these cases are won after a county court claim is issued, with the vast majority being discontinued.
Title: Re: NPC Notice to Hirer: Parked on Pavement
Post by: 8vaibhav on August 21, 2025, 10:01:14 am
As my lease is about to end, I am thinking to not complain as of now. But would note this for future.

That is a bit silly. You are entitled to compensation for any breach of your GDPR.

They have dobbed you in it with the IAS, so that is not going to end successfully for you. You can easily fight this all the way through the eventual county court claim but I suspect, based on your response above, that you are going to try and settle for the mugs discount.

Your message edged me to send the complaint email to Octopus yesterday. They have just sent the following back:

----------
From: <penalties@octopusev.com>
CC: penalties@octopusev.com; Fleetworks Admin <admin@fleetworks.co>; data-protection@octopusev.com

Sub: Re: Complaint & rectification notice –  regarding identification of “driver” re PCN xxxxx, VRM xxxxxx

Thank you for your email.

Just to let you know, we are looking into this for you and we will get back to you as soon as we can. In the meantime if you need anything urgently, please give us a call on 020 3389 5959.

Kind regards,

Fleet Admin Team
Octopus Electric Vehicles

----------

Should I call them and repeat the request to contact operator ASAP? (Something I requested to be acted up within 48 hours in my email to them)
Title: Re: NPC Notice to Hirer: Parked on Pavement
Post by: 8vaibhav on August 20, 2025, 02:42:56 pm
As my lease is about to end, I am thinking to not complain as of now. But would note this for future.

That is a bit silly. You are entitled to compensation for any breach of your GDPR.

They have dobbed you in it with the IAS, so that is not going to end successfully for you. You can easily fight this all the way through the eventual county court claim but I suspect, based on your response above, that you are going to try and settle for the mugs discount.

Thanks, I can complain but surely saying a person with another insurance cover is like saying I could have been breaching the terms of the lease which explicitly disallow this. Also, while the private parking companies are absolute SCUMs and you are doing god's work fighting against them Octopus have merely shown incompetence.

I am now thinking to complain without the line about "temporary cover" or "own cover". This would help people fight future PCNs surely.

Meanwhile I will also respond on IAS using your amazing template with minor edits.

Greatly appreciate all the help.
Title: Re: NPC Notice to Hirer: Parked on Pavement
Post by: b789 on August 20, 2025, 02:29:05 pm
As my lease is about to end, I am thinking to not complain as of now. But would note this for future.

That is a bit silly. You are entitled to compensation for any breach of your GDPR.

They have dobbed you in it with the IAS, so that is not going to end successfully for you. You can easily fight this all the way through the eventual county court claim but I suspect, based on your response above, that you are going to try and settle for the mugs discount.
Title: Re: NPC Notice to Hirer: Parked on Pavement
Post by: 8vaibhav on August 20, 2025, 02:22:09 pm
Thanks for typing this out.
As my lease is about to end, I am thinking to not complain as of now. But would note this for future.

Quote

Someone else could have been driving under their own cover, under temporary cover, as a garage/valet/breakdown operative, or unlawfully (which you cannot assume to be the case).


I did previously try to get a separate insurance cover for my spouse who Octopus wouldn't allow to add to the contract on a "learners' license". Basically Octopus had said another person getting a separate insurance to drive the leased car isn't allowed. I eventually couldn't get my spouse added as they didn't have a full UK license.
Title: Re: NPC Notice to Hirer: Parked on Pavement
Post by: b789 on August 20, 2025, 01:57:06 pm
I also advise you to send the following complaint to Octopus EV at penalties@octopusev.com and that you CC customerservice@octopusev.com and data-protection@octopusev.com as well as yourself:

Quote
Subject: Complaint & rectification notice – inaccurate identification of “driver” re PCN [PCN ref], VRM [VRM]

To: penalties@octopusev.com
Cc: customerservice@octopusev.com; data-protection@octopusev.com

From: [Hirer’s full name], Hirer of vehicle [VRM]

Date: [insert]

Dear Penalties Team / Data Protection Officer,

Re: National Parking Control Ltd – PCN [ref]; vehicle [VRM]; event date [dd/mm/yyyy]

I am the hirer. Your letter dated [date] (headed “Notice of Representation”) appears in the operator’s evidence. It contains serious errors that prejudice my appeal:

• You misdescribe a private parking charge as a “fine/offence.”
• You state that I was the driver despite having no first-hand knowledge.
• You purport to transfer liability while ignoring the hire-vehicle regime in PoFA Sch 4 paras 13–14.

Why your “driver” assertion is inaccurate and unreasonable
The vehicle is insured under the lease and, as you know, only the hirer is named by default unless a nominated driver is added. That administrative fact does not evidence who was driving at the material time. Someone else could have been driving under their own cover, under temporary cover, as a garage/valet/breakdown operative, or unlawfully (which you cannot assume to be the case). In short, you had no evidential basis to assert I was the driver.

This is a breach of UK GDPR:

Accuracy (Art 5(1)(d)) – you disclosed inaccurate personal data by asserting I was the driver.
Data minimisation (Art 5(1)(c)) – naming a “driver” was unnecessary to the stated purpose.
Fairness/lawfulness (Art 5(1)(a)) – the “fine/offence” language is misleading.

What I require

Please action the following:

1. Rectification (within 48 hours): confirm you do not know who the driver was; correct your records; and notify the operator that any suggestion I was the driver, and any references to “fine/offence,” are withdrawn as inaccurate. Please copy me.

2. Explanation (within 7 days): tell me exactly what you relied upon to label me the “driver” (templates, policies, staff guidance, or an inference from insurance), and the lawful basis for each disclosure made about me in this matter. Provide copies of all communications you sent to the operator.

3. Assurance (within 7 days): confirm your templates and staff guidance will be corrected so that future correspondence (a) refers to “hirer,” not “driver,” unless evidenced, and (b) does not describe private charges as “fines/offences.”

I reserve all rights, including seeking compensation under Article 82 UK GDPR / s.168 DPA 2018 and escalating to the ICO, should your error cause loss or further prejudice. Nothing in this complaint admits the identity of the driver.

Yours faithfully,

[Name]
Title: Re: NPC Notice to Hirer: Parked on Pavement
Post by: 8vaibhav on August 20, 2025, 01:49:16 pm
Many thanks for the detailed response. You are a STAR.


Quote
. Saying “timestamped photos advise how long the vehicle was observed” is not proof of a continuous period outside any consideration/grace allowance or proof of parking rather than a brief stop. The operator should produce the observation log and a continuous sequence; they have not.


I have a doubt about just one of the points in what you wrote. The photos they have shared are indeed in a "continuous sequence", even as the time between first and last picture of the vehicle is less than 2 minutes.
Also, I think they are working on the principle that "20 minute" loading is allowed while on pavements NO parking is allowed. I am happy to copy paste the entire text you shared as my appeal but would like to understand what this point meant. Many thanks.
Title: Re: NPC Notice to Hirer: Parked on Pavement
Post by: b789 on August 20, 2025, 01:36:17 pm
For the IAS appeal, you can use the following as your rebuttal to the operators prima facie case:

Quote
PCN [ref] – VRM [VRM] – Comments on Operator Evidence (rebuttal)

1. Status. I am the hirer, not the “keeper”. For a hire vehicle the operator must comply strictly with PoFA Sch 4 paras 13–14. Their evidence contains no para 13(2) enclosures.

2. Warden ticket + same-day notice. The operator says a warden ticket was issued 30/07/2025 and a “Notice to Keeper (Non-ANPR)” was sent the same day. That sequence is incompatible with PoFA for a warden (NtD) case. In any event, with a hire vehicle, the operative notice is a Notice to Hirer that also satisfies paras 13–14. It doesn’t.

3. Hire-vehicle documents missing (fatal). To transfer liability to a hirer the operator must serve a Notice to Hirer enclosing (i) a copy of the hire agreement and (ii) a statement of liability signed by the hirer (para 13(2)), within the para 14 timeframe. These documents are absent. Therefore no hirer liability arises.

4. Burden of proof. The operator’s line “we have not received anything to state [the hirer] was not driving” is irrelevant. There is no obligation to identify the driver. The operator must either prove the driver or comply with PoFA. It has done neither.

5. Octopus EV letter. The operator relies on a third-party letter that mislabels the charge as a “fine/offence” and asserts I was the “driver”. Octopus was not present; this is inaccurate hearsay and is not proof of driver identity. It cannot remedy PoFA defects.

6. Signage – ambiguity and inconsistency. The sign provided states:

“You must park wholly within a marked bay. No parking on roadways / yellow lines / paved / hatched or landscaped areas.”

(a) The entire car park surface is paved, including marked bays. The phrase “no parking on … paved … areas” renders the terms ambiguous/contradictory.
(b) The ticket alleges parking on a “pavement”, yet the sign never uses that word and gives no clear boundary between a permitted marked bay and any allegedly prohibited paved area. Ambiguous terms are construed against the drafter; they cannot found a charge.

7. Contract vs prohibition. The operator pleads a contractual charge, but its wording is essentially prohibitive with no clear offer for the area complained of. If the area is prohibited, it cannot create a contract by “breach”. If it is contractual, the terms are unclear and not capable of acceptance with informed consent.

. Saying “timestamped photos advise how long the vehicle was observed” is not proof of a continuous period outside any consideration/grace allowance or proof of parking rather than a brief stop. The operator should produce the observation log and a continuous sequence; they have not.

9. Authority. The operator asserts the charge is “based in Contract”. They must show contemporaneous landowner authority permitting enforcement and proceedings in their own name. None has been exhibited.

Conclusion: Driver identity is unproven; PoFA hire-vehicle requirements are not met (paras 13–14 and timing/sequence); the signage is ambiguous/internally inconsistent for the alleged location; standing is unproven; and the third-party letter is not evidence of the driver. The appeal must be allowed.
Title: Re: NPC Notice to Hirer: Parked on Pavement
Post by: 8vaibhav on August 20, 2025, 01:00:24 pm
Please confirm that as the lessee, you can insure the vehicle for other drivers? For example, you spouse or partner or other family members? Octopus have no idea who the driver is unless, under the terms of the lease agreement, you are the sole permitted driver of the vehicle.

Insurance for the vehicle is included as part of the lease. There is an 'option' to add additional driver which would increase monthly costs but as it stands there is NO other driver insured to drive the vehicle.

I recall in the past, Octopus passed my details as "Hirer" to another private parking operator but for reasons unknown this time they chose to use "Driver" instead of "Hirer" in their communication to NPC.

We are still within the 14 days period of the "discount" fwiw, thinking about options here. Many thanks in advance.

**EDIT: Even though when NPC rejected my appeal on 18th Aug, it said that the "Discounted" £60 is due for two weeks, now on their website the amount due has already jumped to £100. I think they updated it when they responded to my IAS appeal.**
Title: Re: NPC Notice to Hirer: Parked on Pavement
Post by: b789 on August 20, 2025, 12:34:24 pm
Please confirm that as the lessee, you can insure the vehicle for other drivers? For example, you spouse or partner or other family members? Octopus have no idea who the driver is unless, under the terms of the lease agreement, you are the sole permitted driver of the vehicle.
Title: Re: NPC Notice to Hirer: Parked on Pavement
Post by: 8vaibhav on August 20, 2025, 11:48:08 am
NPC have responded on the IAS website

Most of the evidence is a repeat of what I had already shared here in my initial post.

There is one added "Transfer of Liability" letter from the leasing company which is below:
(https://i.imgur.com/LM4Lcbv.png)

Leasing company has mentioned my details as the "driver", not sure if this can be take as evidence by NPC to claim as such. Please advise.

The photos of the vehicle have time stamps from 18:34:17 to 18:35:58 (so total less than 2 minutes)

This is the text from NPC as uploaded on the IAS website:
(https://i.imgur.com/8Z7Zmjx.png)

Please advise how I should proceed, I have the option to add text as well as attachments to respond (post which the operator would get a chance to respond again) OR I can submit straight to arbitration.

Many thanks in advance

They have also added sitemap (as below) and pdf files of all the signage online (not sure how relevant)

(https://i.imgur.com/YNWBIc8.png)
Title: Re: NPC Notice to Hirer: Parked on Pavement
Post by: 8vaibhav on August 18, 2025, 05:52:18 pm
You are not saying the driver is "unknown". We are saying that the driver is "unknown" to the operator. All you are saying, as the Hirer, is that you decline to identify the driver and there is no legal obligation on you to do so to an unregulated private parking firm.

Thanks, I have copy pasted your entire appeal text and barely added a line at the top that I am not the "registered" keeper.

Got the following automated response on email:
What happens now?

Your appeal has been sent to the parking operator so that they can provide their account.

The Parking Operator is now provided 5 working days to upload sufficient evidence to show that you are liable for the charge.

Once they have submitted their evidence you will be able to log in and see it. You will then have 5 working days to respond in one of TWO ways:

1) SUBMIT YOUR APPEAL - You can respond to the evidence by making any representations that you consider to be relevant as to the lawfulness of the charge any by uploading any photographs or other evidence that you may have. Once you submit your response it will go back to the operator who may wish to respond or send the appeal straight to arbitration. In the case of the operator responding, you will receive another chance to respond.

- OR -

2) REFER THE CASE STRAIGHT TO ARBITRATION - If you consider that the information provided is not capable of showing that you are, on the face of it, responsible for the parking charge, then you may choose this option. The Adjudicator will assess the evidence provided by the operator and appellant. You will not have the opportunity of making representations and the Adjudicator will decide, on the balance of probabilities, whether you are liable for the parking charge.

You will be notified by email when you are able to proceed further.

Caution: Once the operator has uploaded their evidence, if you do not respond in one of the above two ways within 5 working days, your appeal will be submitted to the Adjudicator WITHOUT your response to the operators evidence that will be available to you.
Title: Re: NPC Notice to Hirer: Parked on Pavement
Post by: b789 on August 18, 2025, 05:24:11 pm
You are not saying the driver is "unknown". We are saying that the driver is "unknown" to the operator. All you are saying, as the Hirer, is that you decline to identify the driver and there is no legal obligation on you to do so to an unregulated private parking firm.
Title: Re: NPC Notice to Hirer: Parked on Pavement
Post by: 8vaibhav on August 18, 2025, 02:07:55 pm
You're not the registered keeper, but you were keeping the vehicle at the relevant time in your capacity as the hirer. As long as your actual appeal makes clear the capacity in which you are appealing that should be fine.

Brilliant thanks, so I will answer "YES" in the dropdown but clarify in my text that I am NOT the "registered" keeper but HIRER at the time of the alleged breach.

Title: Re: NPC Notice to Hirer: Parked on Pavement
Post by: DWMB2 on August 18, 2025, 02:05:06 pm
You're not the registered keeper, but you were keeping the vehicle at the relevant time in your capacity as the hirer. As long as your actual appeal makes clear the capacity in which you are appealing that should be fine.
Title: Re: NPC Notice to Hirer: Parked on Pavement
Post by: 8vaibhav on August 18, 2025, 01:37:13 pm
Many Thanks Both DWMB2 and b789.

I am seeing the following message on the IAS website:
Unless you were either the driver or the keeper at the relevant time you may not continue with this appeal.

Should I proceed selecting "YES" to the "were you the keeper" question below? Even though I am actually the HIRER and not the KEEPER?

I of course want to stick to "I am not prepared to say" option for the Driver question.

Other option would be to not appeal at all. Please advise.

(https://i.imgur.com/wR84RBc.png)
Title: Re: NPC Notice to Hirer: Parked on Pavement
Post by: DWMB2 on August 18, 2025, 01:11:57 pm
Wouldn't the "unknown driver" aspect be enough to challenge instead of including all these other points?
There's a famous saying about this - "Don't put all your eggs in one basket".
Title: Re: NPC Notice to Hirer: Parked on Pavement
Post by: 8vaibhav on August 18, 2025, 01:08:23 pm
So you appeal to the IAS with the following:

Quote
I am the hirer of the vehicle referenced in PCN [number]. I deny any liability for this parking charge and appeal in full.

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. Crucially, if the operator wishes to hold the hirer liable under Schedule 4 of the Protection of Freedoms Act 2012 (PoFA), it must comply with the strict conditions set out in Paragraphs 13 and 14. It has not done so.
I therefore require the operator to provide the following:

1. Strict proof of compliance with Paragraph 14(5) of PoFA. The Notice to Hirer must contain all the prescribed information. The operator’s notice fails to do so.

2. Strict proof of compliance with Paragraph 13(2) of PoFA. The operator must have included:

• A copy of the hire agreement.
• A statement of liability signed by the hirer.

These documents were not provided. Without them, the operator cannot transfer liability to the hirer. I am under no legal obligation to identify the driver and I decline to do so. Unless the operator can establish the identity of the driver, it has no lawful basis to pursue this charge.

3. 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.

4. 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 IAS assessor to Section 14 of the PPSCoP (Relationship with Landowner), which clearly sets out mandatory minimum requirements.

5. 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.

6. The IAS claims that its assessors are “qualified solicitors or barristers.” Yet there is no way to verify this. Decisions are unsigned, anonymised, and unpublished. There is no transparency, no register of assessors, and no way for a motorist to assess the legal credibility of the individual supposedly adjudicating their appeal. If the person 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 hirer 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. The operator has failed to establish liability, and unless they can identify the driver, they—and the IAS—have no jurisdiction to pursue this matter further.

Thanks Much, is it okay to address the IAS as a third person in an appeal to themselves?

I think you are already confident IAS will reject this so this is ammo to use at next step?

Wouldn't the "unknown driver" aspect be enough to challenge instead of including all these other points?
Title: Re: NPC Notice to Hirer: Parked on Pavement
Post by: b789 on August 18, 2025, 12:58:43 pm
So you appeal to the IAS with the following:

Quote
I am the hirer of the vehicle referenced in PCN [number]. I deny any liability for this parking charge and appeal in full.

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. Crucially, if the operator wishes to hold the hirer liable under Schedule 4 of the Protection of Freedoms Act 2012 (PoFA), it must comply with the strict conditions set out in Paragraphs 13 and 14. It has not done so.
I therefore require the operator to provide the following:

1. Strict proof of compliance with Paragraph 14(5) of PoFA. The Notice to Hirer must contain all the prescribed information. The operator’s notice fails to do so.

2. Strict proof of compliance with Paragraph 13(2) of PoFA. The operator must have included:

• A copy of the hire agreement.
• A statement of liability signed by the hirer.

These documents were not provided. Without them, the operator cannot transfer liability to the hirer. I am under no legal obligation to identify the driver and I decline to do so. Unless the operator can establish the identity of the driver, it has no lawful basis to pursue this charge.

3. 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.

4. 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 IAS assessor to Section 14 of the PPSCoP (Relationship with Landowner), which clearly sets out mandatory minimum requirements.

5. 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.

6. The IAS claims that its assessors are “qualified solicitors or barristers.” Yet there is no way to verify this. Decisions are unsigned, anonymised, and unpublished. There is no transparency, no register of assessors, and no way for a motorist to assess the legal credibility of the individual supposedly adjudicating their appeal. If the person 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 hirer 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. The operator has failed to establish liability, and unless they can identify the driver, they—and the IAS—have no jurisdiction to pursue this matter further.
Title: Re: NPC Notice to Hirer: Parked on Pavement
Post by: 8vaibhav on August 18, 2025, 12:19:21 pm
Received rejection as expected
Please advise

Screenshot here:
(https://i.imgur.com/5dihu65.jpeg)
Title: Re: NPC Notice to Hirer: Parked on Pavement
Post by: 8vaibhav on August 07, 2025, 11:11:33 pm
I will select "I was not aware that I had incurred a charge" option and use the text you kindly shared above.

Before you proverbially blow both feet off... what do you mean by the above?
I had attached the screenshot of the options available, this was one of them, none of the others made sense to me. Think you couldn't/didn't see the screenshot to ask this perhaps. I am attaching it here again.
(https://i.imgur.com/TBHaygS.jpeg)
I have already appealed selecting this option, hopefully it isn't negative for me.

Quote
You only appeal as the "Hirer" or "Other". You are denying any liability as the Hirer.
Indeed, above the "reason" drop-down there was another dropdown where I could choose keeper, Hirer or driver. I chose Hirer.

Quote
Is the notice you have shown us a Notice to Hirer (NtH) addressed to you or is it a copy of the Notice to Keeper (NtK) that was sent to the lease company? Unless it is an NtH addressed and issued to to you, you cannot do anything.
The NtH I attached was indeed addressed to me. The NtK must have been sent to the leasing company earlier, they must have responded by providing my details and they also informed me about this as well but the original NtK was never sent to me by anyone.
Title: Re: NPC Notice to Hirer: Parked on Pavement
Post by: jfollows on August 07, 2025, 07:32:55 pm
First post - definitely a Notice to Hirer
Title: Re: NPC Notice to Hirer: Parked on Pavement
Post by: b789 on August 07, 2025, 06:44:08 pm
I will select "I was not aware that I had incurred a charge" option and use the text you kindly shared above.

Before you proverbially blow both feet off... what do you mean by the above?

You only appeal as the "Hirer" or "Other". You are denying any liability as the Hirer.

Is the notice you have shown us a Notice to Hirer (NtH) addressed to you or is it a copy of the Notice to Keeper (NtK) that was sent to the lease company? Unless it is an NtH addressed and issued to to you, you cannot do anything.
Title: Re: NPC Notice to Hirer: Parked on Pavement
Post by: jfollows on August 07, 2025, 10:00:09 am
Also note for later defence if necessary, an “observation time” of under two minutes is too short. You need enough time to read the signs and comply with them.
Title: Re: NPC Notice to Hirer: Parked on Pavement
Post by: 8vaibhav on August 07, 2025, 09:37:11 am
You can appeal along the lines of
Quote
Dear Sirs,

I have received you Notice to Hirer [(PCN number)] for Vehicle Registration Mark [VRM]. I am the hirer of the vehicle. There is no obligation for me to name the driver at the time and I will not be doing so.

To hold me liable for the charge as the hirer of the vehicle, you must meet the conditions specified in Paragraph 14 of Schedule 4 of the Protection of Freedoms Act 2012 (“the Act”). I note from your correspondence that you have failed to meet these conditions. These failures include (but are not limited to):

A failure to serve a Notice to Hirer containing all the information required by 14(5) of the Act.
A failure to include the additional documents mentioned by 13(2) of the Act.

As a result of this, you are unable to recover the specified charge from me, the hirer. As I do not have liability for this charge, I am unable to help you further with this matter. I therefore look forward to your confirmation that the charge has been cancelled.
They only have one shot at getting the Notice to Hirer right. They didn’t. They never do. Lots of people fall for it and pay up.

Very kind, I will select "I was not aware that I had incurred a charge" option and use the text you kindly shared above. Will update here if this is rejected as you suspect. Many thanks
Title: Re: NPC Notice to Hirer: Parked on Pavement
Post by: jfollows on August 07, 2025, 09:32:35 am
You can appeal along the lines of
Quote
Dear Sirs,

I have received you Notice to Hirer [(PCN number)] for Vehicle Registration Mark [VRM]. I am the hirer of the vehicle. There is no obligation for me to name the driver at the time and I will not be doing so.

To hold me liable for the charge as the hirer of the vehicle, you must meet the conditions specified in Paragraph 14 of Schedule 4 of the Protection of Freedoms Act 2012 (“the Act”). I note from your correspondence that you have failed to meet these conditions. These failures include (but are not limited to):

A failure to serve a Notice to Hirer containing all the information required by 14(5) of the Act.
A failure to include the additional documents mentioned by 13(2) of the Act.

As a result of this, you are unable to recover the specified charge from me, the hirer. As I do not have liability for this charge, I am unable to help you further with this matter. I therefore look forward to your confirmation that the charge has been cancelled.
They only have one shot at getting the Notice to Hirer right. They didn’t. They never do. Lots of people fall for it and pay up.
Title: Re: NPC Notice to Hirer: Parked on Pavement
Post by: 8vaibhav on August 07, 2025, 09:28:53 am
Did NPC also send you
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(a)a statement signed by or on behalf of the vehicle-hire firm to the effect that at the material time the vehicle was hired to a named person under a hire agreement;

(b)a copy of the hire agreement; and

(c)a copy of a statement of liability signed by the hirer under that hire agreement.
?

No?

Then they are not compliant with the requirements of PoFA 2012 (https://www.legislation.gov.uk/ukpga/2012/9/schedule/4) to hold you, the hirer, responsible for the liabilities of the driver, whom you are under no obligation to identify.

Brilliant! Indeed they didn't send me anything else. Just the attached letter by post and the information/pictures online.
I did get an email from the leasing company when they passed my details to NPC, so they may have shared these copies with NPC. Could NPC send these to me as a response to my challenge/appeal?

When I am trying to appear as a hirer I see the following options on their website, which should I choose?

(https://i.imgur.com/TBHaygS.jpeg)
Title: Re: NPC Notice to Hirer: Parked on Pavement
Post by: jfollows on August 07, 2025, 09:23:26 am
Be aware that
That’s the worst case, you might get lucky. These companies only want your money and don’t care how they get it. But if they can’t be bothered to comply with the law, why should they?
Title: Re: NPC Notice to Hirer: Parked on Pavement
Post by: jfollows on August 07, 2025, 09:07:07 am
Did NPC also send you
Quote
(a)a statement signed by or on behalf of the vehicle-hire firm to the effect that at the material time the vehicle was hired to a named person under a hire agreement;

(b)a copy of the hire agreement; and

(c)a copy of a statement of liability signed by the hirer under that hire agreement.
?

No?

Then they are not compliant with the requirements of PoFA 2012 (https://www.legislation.gov.uk/ukpga/2012/9/schedule/4) to hold you, the hirer, responsible for the liabilities of the driver, whom you are under no obligation to identify.

Specifically, Schedule 4 Paragraph 14 (2)(a)
Quote
(2)The conditions are that—

(a)the creditor has within the relevant period given the hirer a notice in accordance with sub-paragraph (5) (a “notice to hirer”), together with a copy of the documents mentioned in paragraph 13(2) and the notice to keeper;
Title: NPC Notice to Hirer: Parked on Pavement
Post by: 8vaibhav on August 07, 2025, 08:42:55 am
I have received the following £60 (£100 if not paid soon) parking charge in mail as the Hirer of the said vehicle.
The notice was initially sent to the Keeper (the leasing company) who have passed on my details to NPC as I have this vehicle on lease.

Please advise what options I have as the Hirer, in the notice they haven't asked me to share the details of the driver. Can I challenge it as the Hirer and refuse revealing Driver's identity?

Some additional detail, I have been verbally told by a resident that parking for up to 20 minutes is allowed in the area. At the time of the alleged contravention (Parking on the Pavement), hazard lights of the vehicle were blinking (even seen on the pictures they attached online) which confirms that the car wasn't left unattended/parked. The vehicle wasn't there for more than 5 minutes total within which these pictures were taken.


Notice to Hirer Front:

(https://imgur.com/zxr8gdu.jpeg)


Notice to Hirer Back:

(https://imgur.com/L7DU8OZ.jpeg)


Venue Signage:

(https://imgur.com/0x9Gk1w.jpeg)


Online 1:

(https://imgur.com/ARz7hJ6.jpeg)



Online 2:

(https://imgur.com/qxbVlWH.jpeg)


Many thanks in advance.