Understood, thanks.
Is there any point in contacting UK Car Park Management to acknowledge this decision or do you think they will contact me before handing over to a debt collection agency?
Have we missed something in our position of 'relevant land' that the adjucator has seen in the contract that was provided to them to make them think they can win in court?
Is there anything else I can obtain to prove this further without any doubt?
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.
This response addresses and rebuts each point in the operator’s prima facie case and shows why the PCN cannot lawfully be enforced.
1.Keeper Liability Cannot Apply
The operator argues that the site is “relevant land” because there is no TRO and the site is managed under a private agreement. That is a misstatement of the law.
Paragraph 3(1)(b) of Schedule 4 excludes “a parking place which is provided or controlled by a traffic authority.” Paragraph 3(2) defines a traffic authority to include a London borough council. Cranbrook Primary School is a community school, not an academy or foundation school. The site is both owned and controlled by the London Borough of Redbridge. The school governing body does not own or control the land independently. Control therefore rests with Redbridge Council, which is a traffic authority. That alone excludes this land from being relevant land.
The operator’s focus on the absence of a TRO under the Road Traffic Regulation Act 1984 is misplaced. PoFA does not say “provided or controlled under RTRA powers.” It says “provided or controlled by a traffic authority.” Parliament could have restricted the scope to RTRA car parks but did not. The statutory test is broader, and it is satisfied here.
Even if paragraph 3(1)(b) were doubted, paragraph 3(1)(c) also applies. It excludes land where parking is “subject to statutory control.” Cranbrook Primary School is subject to statutory governance under the Education Acts and is directly controlled by a London borough exercising statutory powers. Parking on the site is therefore subject to statutory control.
The operator’s claim that a private agreement with the council renders the site relevant land is misconceived. A contract cannot override statute. If the land is excluded under paragraph 3, no private arrangement can change that legal status.
Accordingly, the Cranbrook Primary School car park is not relevant land. Keeper liability under PoFA cannot arise, and the operator’s reliance on Schedule 4 is fundamentally flawed.
2. Failure to engage with IAS appeal points 4 and 5
The operator’s fallback (“the Appellant is the keeper and has not named the driver; PoFA enables recovery”) is nonsensical once the land is shown not to be relevant. Even a perfectly drafted NtK cannot conjure keeper liability where Parliament has excluded it. The operator has not grappled with this point.
Separately, the operator has failed to answer two discrete evidential challenges in my IAS appeal:
Point 4: Reliability and calibration of enforcement mechanism. I required strict proof that the mechanism used (ANPR or manual patrol) is reliable, synchronised, maintained, and calibrated, and that it evidences a period of parking rather than mere site presence within a consideration or grace period as required by the PPSCoP. No maintenance logs, calibration records, clock-sync evidence, or patrol notes have been produced. No evidence of the operator’s consideration/grace-period policy for this site has been disclosed. Assertions are not evidence. In the absence of contemporaneous records, the evidential chain is incomplete and the allegation is not proven.
Point 5: Proof of posting and service timing. I required strict proof that any NtK was posted in time to be “given” within the relevant period. PPSCoP 8.1.2(d) Note 2 requires the operator to retain a record of the date of posting, not merely the date a notice was generated or handed to a mail consolidator. The operator has provided no postal manifest, no proof of handover to Royal Mail, and no evidence of posting dates. A back-office “generated on” timestamp is not proof of posting or delivery. On their own case, they have not discharged the burden of proving service.
Given (i) PoFA is inapplicable because the land is excluded, and (ii) the operator has not rebutted points 4 and 5 with primary evidence, the prima facie case fails on both legal applicability and proof.
3. Landowner authority: proof required, not bare assertions
If the operator genuinely believes that merely asserting the existence of a valid agreement—without evidencing it to the appellant—is sufficient, I would relish watching them try that excuse in an actual courtroom. The IAS’s willingness to entertain such nonsense only reinforces its reputation as a kangaroo court. If this assessor is prepared to accept that a contract exists based solely on secret evidence shown only to the IAS, then congratulations: you’ve just proven why this appeals process is a farce.
The PPSCoP §14 requires evidence, not secrecy. Section 14.1(a)–(j) mandates written confirmation from the landowner covering: the landowner’s identity and a boundary plan; any applicable byelaws; the permission granted and its duration; the parking terms and conditions applied; the method of issuing charges; responsibility for necessary consents; the operator’s obligations under the Code; the documentation the operator must be able to supply on request to authorised bodies detailing the relationship with the landowner; and the operator’s approach to appeals. Note 2 confirms that where byelaws prohibit private charges they take precedence; Note 3 warns that pre-existing rights cannot be overridden by signage. These are core standing documents, not optional extras.
Commercially sensitive pricing can be redacted where justified; however, the authority clauses, boundary plan, byelaw status, scope and duration of permission, operative terms, and method of charge issuance must be disclosed in full. A private “we have authority, trust us” is not compliance with §14 and is not evidence of standing.
If the IAS is content to uphold charges on the basis of undisclosed contracts shown only to the assessor, it merely underlines that this process is not transparent and not credibly independent. The upcoming implementation of the Parking (Code of Practice) Act 2019 cannot come soon enough. When it does, incestuous outfits like the IAS—masquerading as independent while rubber-stamping operator fiction—will finally be consigned to the procedural dustbin where they belong.
Conclusion
For the reasons above—(i) the site is not “relevant land” so PoFA cannot transfer liability, (ii) the operator failed to evidence Points 4 and 5 (reliability/calibration and proof of posting/service), and (iii) standing has not been proven as required by PPSCoP §14—the PCN must be cancelled.
Dear FOI Team,
Under the Freedom of Information Act 2000, I request the following information regarding parking enforcement at Cranbrook Primary School, The Drive, Ilford, IG1 3PS:
Has the London Borough of Redbridge, or any delegated authority thereof, contracted UK Car Park Management (CPM) to operate parking enforcement services at the above site?
If so, please provide:• The name of the contracting party or authority.
• The date the contract was initiated.
• The scope and duration of the contract.
• A copy of the contract or agreement (with any necessary redactions).
If CPM was contracted by the school directly, please confirm whether the school had delegated authority from the borough to enter into such an agreement concerning land use and enforcement.
This request concerns the legitimacy of private enforcement activity on land that appears to fall under local authority control. Please treat this as a matter of public interest and procedural accountability.
I look forward to your response within the statutory 20 working days.
Yours faithfully,
B789
Dear B789
Freedom of Information Act 2000
Thank you for your request for information received on 31 July 2025
This request is being handled under the Freedom of Information Act 2000
Section 1 of the Freedom of Information Act 2000 provides two distinct but related rights of access to information which impose corresponding duties on public authorities. These are:• The duty to inform the applicant whether or not information is held by the authority
and, if so,
• The duty to communicate that information to the applicant.
Request
Under the Freedom of Information Act 2000, I request the following information regarding parking enforcement at Cranbrook Primary School, The Drive, Ilford, IG1 3PS:• Has the London Borough of Redbridge, or any delegated authority thereof, contracted UK Car Park Management (CPM) to operate parking enforcement services at the above site?
If so, please provide:• The name of the contracting party or authority.
• The date the contract was initiated.
• The scope and duration of the contract.
• A copy of the contract or agreement (with any necessary redactions).
If CPM was contracted by the school directly, please confirm whether the school had delegated authority from the borough to enter into such an agreement concerning land use and enforcement. This request concerns the legitimacy of private enforcement activity on land that appears to fall under local authority control. Please treat this as a matter of public interest and procedural accountability.
I am writing to advise you that, following a search of our paper and electronic records, I have established that the information you requested is not held by London Borough of Redbridge. Please contact Private Parking firm directly for the requested information.
Subject: Request for Internal Review
Dear FOI Team,
I am writing to request an internal review of your response to my Freedom of Information request regarding the contracting of UK Car Park Management (UKCPM) at Cranbrook Primary School.
Your reply stated that the information I requested is not held by the London Borough of Redbridge and advised me to contact the private parking firm directly. I believe this response is inadequate for the following reasons:1. Failure to confirm land ownership and delegation
Even if the Council does not hold the UKCPM contract itself, you are still able – and obliged – to confirm whether the land in question is Council-owned or controlled, and if so, whether any delegation has been granted to the school governing body to enter into such arrangements. This is relevant context squarely within the scope of my request.
2. Duty to advise and assist (s16 FOIA)
The Section 45 Code of Practice requires public authorities to advise and assist applicants. Directing me to contact a private company that is not subject to FOIA does not satisfy this duty. You should instead have identified or signposted the correct public body likely to hold the requested information – in this case, the governing body of Cranbrook Primary School – or considered whether a transfer under FOIA was appropriate.
3. Incomplete handling of the request
My request covered not just the specific contract with UKCPM but also any agreements, delegations, or authorisations by the Council concerning parking enforcement at this location. These are matters the Council is in a position to confirm.
I therefore request that the internal review addresses:• Whether the land at Cranbrook Primary School, including the car park, is owned or controlled by the Council.
• Whether the Council has delegated authority to the school governing body to enter into parking enforcement arrangements.
• Whether the Council holds any records, correspondence, or authorisations relating to the introduction of private parking enforcement at this site.
• Proper signposting or transfer to the public body that does hold the requested contract (likely the school/governing body).
Please ensure this review is conducted in line with the FOIA Code of Practice and completed within 20 working days.
Yours sincerely,
B789
Given that >20,000 PCNs are issued every day, the idea that parking companies read this forum just in case one of their PCNs is being discussed does not make sense. They don’t care if one of their PCNs fails because enough people just pay up on receipt of the remaining 19,999.
Just to clarify as I know that UKCPM read these forums and then rely on them later in court and I am unable to edit the post - I am not the registered keeper [fact] therefore there should be no assumption that the original post in this thread is admitting liability for being the registered keeper and driver and also there can be no assumption on probability that these posts are from the registered keeper.
I received a Parking Charge from UK Car Park Management.
I am the keeper of the vehicle and I dispute your 'parking charge'. I deny any liability or contractual agreement and I will be making a complaint about your predatory conduct to your client landowner.
As your Notice to Keeper (NtK) does not fully comply with ALL the requirements of PoFA 2012, you are unable to hold the keeper of the vehicle liable for the charge. Partial or even substantial compliance is not sufficient. There will be no admission as to who was driving and no inference or assumptions can be drawn. Horizon has relied on contract law allegations of breach against the driver only.
The registered keeper cannot be presumed or inferred to have been the driver, nor pursued under some twisted interpretation of the law of agency. Your NtK can only hold the driver liable. Horizon have no hope at POPLA, so you are urged to save us both a complete waste of time and cancel the PCN.
IAS Appeal – Cranbrook Primary School, The Drive, Ilford, IG1 3PS
I am the registered keeper of the vehicle. 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. I therefore require the operator to provide the following:1. Strict proof that the land in question is “relevant land” under Schedule 4 of the Protection of Freedoms Act 2012 (PoFA). Cranbrook Primary School is a community school maintained by the London Borough of Redbridge. As such, the land is under statutory control and excluded from the definition of “relevant land” under PoFA. The operator is therefore barred from pursuing keeper liability. I require strict proof of the land’s legal status, including ownership, statutory designation, and any relevant exclusions under PoFA Schedule 4. If the operator cannot prove that the land is relevant, then any attempt to hold the keeper liable is unlawful.
2. 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.
3. 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 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.
4. 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.
5. Strict proof that the NtK was posted in time for it to have been given within the relevant period if the operator is trying to imply Keeper liability (which it cannot). 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.)
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 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.