Free Traffic Legal Advice

Live cases legal advice => Private parking tickets => Topic started by: mrfence on October 22, 2025, 01:01:15 pm

Title: Re: Penalty Notice from Saba for not paying for parking
Post by: DWMB2 on February 27, 2026, 10:29:43 am
Ha, this is becoming bizarre. You might as well keep having some fun with them...

Dear Sirs,

I note your latest response, claiming the owner of the vehicle is liable for any penalties and that you do not have any cause of action against the driver.

If this is the case, please explain why you contacted me on [DATE] asking me to provide you with the name and address of the driver.

This is becoming tedious. I have submitted a valid appeal, as the person to whom the penalty notice by post was issued. If you disagree with the points raised in my appeal, you should reject it and provide a POPLA code, so that I may submit an appeal to them.

Yours,
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: mrfence on February 27, 2026, 09:37:29 am
Thanks again for the advice so far, I went back and told them that I had already contested the penalty in previous correspondence.

However they've come back and said.

We received your appeal, however the owner of the vehicle is held liable for all Penalty Notices issued on Railway assets in all circumstances, as such we have no cause of action against the driver or hirer of the vehicle.

And they want paying in the next couple of weeks.

I'd be grateful for advice on the next response...
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: DWMB2 on February 05, 2026, 09:09:07 am
Should I just say that I have already contested the validity of the charge in my previous correspondence?
I would do what I suggested in reply #38 if it were me. Ideally you want a POPLA code - when you get one, it is valid for a month, which is another month wasted. Then POPLA usually take at least 2 months to make a decision. By that point, you're likely to be past the 6 month cut off for prosecuting a byelaws breach (not that they ever would). Game over for Saba.
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: mrfence on February 05, 2026, 12:29:30 am
The original appeal was through an online portal, so I don't think I have a copy of it.

Should I just say that I have already contested the validity of the charge in my previous correspondence?
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: InterCity125 on February 04, 2026, 05:19:11 pm
Reading between the lines here - I think what they are saying is that it is too late (based on the dates) for them to accept a Keeper Appeal but they can accept an appeal from a freshly revealed driver.

Once again they are applying private parking rules to an alleged statutory offence - nonsense!
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: DWMB2 on February 04, 2026, 04:29:26 pm
Just keep playing the game - if they want to continue putting the matter on hold, let them. Contact them at the end of said hold period pointing out your previous appeal, and enclosing another copy of it.

They'll time it out themselves at this rate.
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: mrfence on February 04, 2026, 11:35:38 am
Yes, in their first email acknowledged the appeal as the registered keeper and said that the driver needed to identify themselves and appeal.
The driver has not been identified in subsequent correspondence and the rest of our correspondence has been based on advice in this thread.

Quote
We have received your appeal as the Registered Keeper.

Please be advised, the contravention was on 9/10/25 and we had sent the Parking Charge on 16/10/25 therefore, the Parking Charge does comply with the Protection of Freedoms Act (PoFA) 2012 as the initial notification of the Parking Charge was sent within 14 days of the contravention. Whilst we do not dispute what you have or have not received and in what timeframe, the progression of the matter begins from the day the Parking Charge is sent. Due to this, we would require the driver to appeal the issuing of the Parking Charge, in the absence of an appeal within the twenty-eight (28) day timeframe the registered keeper will remain liable for this matter.

As you have marked you were not the driver, please provide their full name and serviceable address within seven (7) days of the date of this email. Alternatively, please request the driver appeals directly to appeals@paymyparkingcharge.com. Within this email they will need to confirm their full name, serviceable address and confirmation that they were the driver on the day.

This account will be placed on a seven (7) day hold to allow the driver time to contact our company or for the requested details to be provided.
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: InterCity125 on February 04, 2026, 10:51:53 am
Have they actually acknowledged the appeal that you have already sent?

I would just email and say that you have already submitted what you regard to be 'an appeal' which, as yet, has not been answered.
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: mrfence on February 04, 2026, 10:23:55 am
Thanks to everyone for their help so far.

I've received another email from the paymyparkingcharge people saying that if I want to submit an appeal, to do it in the next seven days.

Is this a trap? As in an appeal rather than a challenge is some kind of acceptance?

I've obviously had a load of correspondence with them over the past few months based on the help I've had here, so I'm not clear what exactly I need to put in the appeal.

Any help would be really appreciated.
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: InterCity125 on January 27, 2026, 06:30:40 pm
No - just see what they come back with.

The original notice was from Saba but they are all probably part of the same network of companies which deal with different aspects of the process.
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: mrfence on January 27, 2026, 05:17:49 pm
Thanks, I've sent it across to them in response to their last email.

The email correspondence since my initial online appeal has been with people with paymyparkingcharge.com email addresses, not Saba ones.

Do I need to send the note you composed to someone else too?

Thanks again.
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: InterCity125 on January 26, 2026, 03:48:39 pm
Okay - have slightly modified the appeal based on some extra evidence from the back of the form.
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: InterCity125 on January 26, 2026, 03:47:41 pm
One appeal has already been suggested and it is obviously up to the OP to choose what they wish to do.

In the alterative I am happy to offer the appeal set out below.

Having done a significant amount of reading, I am pretty sure that the notice which has been issued is in fact a Parking Charge Notice which is dressed up as a Penalty Notice - this is fraud.

I would advise submitting this appeal pure to confront Saba but also to access the POPLA code.

Appeal below....




Saba Appeal.


Charge Notice No - xxxxxxxxxxxx





Appeal made as Registered Keeper.




I am the Registered Keeper of vehicle registration xxxx xxx and I completely refute the Parking Charge Notice which Saba issued against that vehicle on 9th October 2025.

The issuing of a Parking Charge Notice dressed up as some kind of statutory Penalty Notice is a massive contravention of the parking operators Code of Practice - the code expressly prohibits specific wording in that respect - your notice contains many of the expressly prohibited words and terms - the notice also projects an entirely false narrative - this is demonstrably fraud by misrepresentation.

Having issued what you purport to be a 'statutory notice', you then imply that the fine is a civil debt - you jump between criminal law and civil law and back again - your notice demonstrates this on many occasions.

For example, your notice states that, "The creditor is Saba Park Services Ltd" - If the 'Penalty Notice' were genuine then there would be no 'creditor' - the terms 'creditor' and 'debtor' refer to civil / contract law and not to a 'fine' or 'penalty' issued due to an alleged statutory offence.

The nature of this misrepresentation is further evidenced by the email chain between myself and a Saba staff member - I would ask the assessor to read this entire email chain - once again the staff member jumps between criminal and civil law as it suits them. Further to that point, the staff member projects the entirely false ability of the parking operator to move liability between 'driver', 'keeper' and 'owner'. Having stated that the owner is liable, the staff member then states that they can simply move liability onto the keeper despite there being no legislation to support that assertion. PoFA exists to transfer liability to the keeper when specific criteria is met - the Saba staff member is simply inventing a method of transferring liability because the requirements of PoFA cannot be met on this occasion - this is clearly an attempt to circumvent the requirements of PoFA rather than follow those requirements.

Your stated appeals method also demonstrates that the notice is nothing more than a Parking Charge Notice and not the statutory notice which you dress this up as.

This is basically fraud by misrepresentation and I am happy to take this matter further if this unlawful Parking Charge Notice is not cancelled promptly.




Best wishes,


xxxx xxxxxxx.

Title: Re: Penalty Notice from Saba for not paying for parking
Post by: mrfence on January 26, 2026, 02:27:43 pm
Can you also post the back please?

Sure, here you go...

(https://i.postimg.cc/kM8PYsHM/Back-Of-Saba-Penalty-Notice.jpg)
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: InterCity125 on January 23, 2026, 10:10:44 am
One appeal has already been suggested and it is obviously up to the OP to choose what they wish to do.

In the alterative I am happy to offer the appeal set out below.

Having done a significant amount of reading, I am pretty sure that the notice which has been issued is in fact a Parking Charge Notice which is dressed up as a Penalty Notice - this is fraud.

I would advise submitting this appeal pure to confront Saba but also to access the POPLA code.

Appeal below....




Saba Appeal.


Charge Notice No - xxxxxxxxxxxx





Appeal made as Registered Keeper.




I am the Registered Keeper of vehicle registration xxxx xxx and I completely refute the Parking Charge Notice which Saba issued against that vehicle on 9th October 2025.

The issuing of a Parking Charge Notice dressed up as some kind of statutory Penalty Notice is a massive contravention of the parking operators Code of Practice - the code expressly prohibits specific wording in that respect - your notice contains many of the expressly prohibited words and terms - the notice also projects an entirely false narrative - this is demonstrably fraud by misrepresentation.

Having issued what you purport to be a 'statutory notice', you then imply that the fine is a civil debt - you jump between criminal law and civil law and back again - your notice demonstrates this on many occasions.

For example, your notice states that, "The creditor is Saba Park Services Ltd" - If the 'Penalty Notice' were genuine then there would be no 'creditor' - the terms 'creditor' and 'debtor' refer to civil / contract law and not to a 'fine' or 'penalty' issued due to an alleged statutory offence.

The nature of this misrepresentation is further evidenced by the email chain between myself and a Saba staff member - I would ask the assessor to read this entire email chain - once again the staff member jumps between criminal and civil law as it suits them. Further to that point, the staff member projects the entirely false ability of the parking operator to move liability between 'driver', 'keeper' and 'owner'. Having stated that the owner is liable, the staff member then states that they can simply move liability onto the keeper despite there being no legislation to support that assertion. PoFA exists to transfer liability to the keeper when specific criteria is met - the Saba staff member is simply inventing a method of transferring liability because the requirements of PoFA cannot be met on this occasion - this is clearly an attempt to circumvent the requirements of PoFA rather than follow those requirement.

This is basically fraud by misrepresentation and I am happy to take this matter further if this unlawful Parking Charge Notice is not cancelled promptly.




Best wishes,


xxxx xxxxxxx.
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: InterCity125 on January 22, 2026, 12:53:13 pm
Can you also post the back please?
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: mrfence on January 22, 2026, 12:37:03 pm
Received a 'penalty notice by post notice to owner' from Saba this morning (22/10), though dated (16/10), for not paying for parking in a station car park on 9/10.

The driver parks there once or twice a week and is in the habit of paying on the app as they walk to the platform. There is no auto-pay feature.

Looking at the app, there is no record of the driver paying for parking on that day. This is baffling as paying is part of their routine and they do have a train ticket which is something they also buy at the same time.

The driver doesn't recall getting an error on the app, so can only assume that for some reason they forgot to pay.

My question is whether there is any merit in requesting some discretion due to human error?
If so, are there any key phrases to include or avoid?

When they changed their app, they had issues on the first day so the driver was charged three times due to it giving an error when it was actually processing the payment. Saba gave a refund, but the driver didn't charge them £60 for their mistake!

(https://i.postimg.cc/NFjDB4vy/Saba-Parking-Fine-Oct25.jpg)

This is the original letter as requested.
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: DWMB2 on January 22, 2026, 09:29:25 am
The more I read on this matter, the more I question the validity of the original 'Penalty Charge Notice'.
They've never had strong legal footing. There's a reason they've never taken one of these to court, and a reason the DfT have now amended PoFA to bring railway land in scope for PoFA, whilst instructing train operating companies to switch to parking charge notices rather than penalties.
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: InterCity125 on January 22, 2026, 09:23:41 am
SABA notes.



The original Penalty Notice (PN) specifies that "Our Client (the Creditor) is Saba Park Services UK Ltd" - How can an alleged 'statutory offence' result in a situation where Saba have suddenly become 'the creditor' - Saba are alleging a 'statutory offence' but then, at a stroke, seemingly attempt to turn 'the fine' into 'a civil debt' where they appear to make themselves the legal recipient of said fine.

The wording on the original PN makes it clear that the notice is being served on 'the vehicle owner' - It appears clear that Saba think they have some kind of judicial power which allows them to move liability from the owner to the registered keeper (RK) - there is no legislation which allows this - furthermore, the existence of PoFA clearly demonstrates that the law regards the moving of liability (from unknown parties to the keeper) as being a serious matter which needs strict criteria to be met - Saba are claiming that they can simply re-allocate liability on the basis of 'reasonable assumption' - if this assertion were true then the statute of PoFA would never need to exist since parking operators could simple apply 'reasonable assumption' to any situation which suited them - clearly PoFA does exist and it's existence combats the claims which Saba make in that respect - Saba are simply seeking to circumvent the clear requirements of PoFA because they cannot meet it's requirement in this particular situation.

Saba say that the RK should notify them of who the owner actually is - but there appears to be no legislation which sets out any such requirement.

Saba say that in the absence of confirmed ownership information, "liability correctly remains with the registered keeper" - this is legally illiterate since liability has NEVER been with the RK at any stage - liability is determined by EXACTLY what is set out in legislation - if the legislation wanted the RK to be liable then it would state as such - in this instance liability actually remains with the unknown owner because that is EXACTLY what the legislation states.

Saba's email comments on 'reasonable assumption' (that the RK is the likely owner) are made out of NECESSITY, they are not made because the law specifies it - (already covered above) but, Saba have to make the argument of 'reasonable assumption' because they have no other way of pursuing any other individual - if they had no one to pursue then their business model would collapse in a heap - it therefore follows that the claim of 'reasonable assumption' is simply a smoke screen which they throw up in order to give themselves a reason to pursue RKs with bulling letters etc.

The alleged offence is the responsibility of the vehicle owner and is a statutory offence - Saba's claim of 'reasonable assumption' (in holding the keeper liable) is contrary to codes of law which protect a defendant - in particular, when accused of a statutory offence, the defendant is 'innocent until PROVEN guilty' - the admission by Saba that they are using 'reasonable assumption' demonstrates that they are unable to separate the concepts of contract law from the laws which surround a statutory offence.

Saba's email comments on "the debt resolution stage" throw into doubt the genuine validity of the original Penalty Charge Notice - is the original PN, in real terms, simply a disguised debt collectors letter?






The more I read on this matter, the more I question the validity of the original 'Penalty Charge Notice'.

I am now wondering if this is a carefully worked fraud - I'm starting to suspect that the original notice was in fact a Parking Charge Notice illegally dressed up as a penalty notice.
With no PoFA on railway land, has the parking operator simply come up with a new method to try and circumvent the ability of drivers to avoid paying for contraventions which occur on railway land?

The wording used is harder hitting than a normal PCN - the mention of penalties and byelaws etc is clearly meant to intimidate the recipient into paying the charge.

The fact that the money goes to Saba and the fact that Saba say that they are 'the creditor' indicates contract law, not statutory law.

Also, the fact that they say POPLA can handle appeals indicates a contractual matter - POPLA have little expertise in statute offences.

The BIGGEST clue with regard to POPLA; that it is implied that POPLA would have the ability to cancel 'the fine' if the defendant's appeal were successful - legally, this is complete nonsense as POPLA would have absolutely NO LEGAL STANDING when trying to cancel a real Penalty Charge Notice - which leads to the obvious question; why appeal to POPLA then? The fact that POPLA can apparently cancel these notices would appear to indicate that they are in fact Parking Charge Notices and NOT Penalty Notices.





Further to these points is the clearly haphazard way which Saba are operating their business.

Your recent email exchanges have tied them in knots.

Saba appear to revise their legal position with each email - in that time, liability has seemingly bounced from owner to driver to keeper to owner and back to the keeper again - this is not the signs of an organisation who are conducting a legitimate business.
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: InterCity125 on January 21, 2026, 01:07:22 pm
This is an interesting one.

I can scribble some notes later.

Their latest response is haphazard at best and their comments on 'debt resolution' suggest that their so called Penalty notice to the owner was more of a debt collecting letter than a real penalty charge notice.


Any chance you could post the back of the original PCN?
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: mrfence on January 21, 2026, 12:52:04 pm
Based on all the correspondence we've had (this is the third or forth interaction), what would you suggest I put in the appeal?

I've referenced the byelaws, relevant and their right/authority to issue a penalty before and they don't seem to want to back down.

When I first posted there seemed a sense that I could challenge the penalty, so would be keen to do so as effectively as possible.

Cheers!
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: InterCity125 on January 21, 2026, 08:44:00 am
As others have said, drag this process out as much as possible.


Is there any chance that the vehicle is subject to a finance agreement? I ask because if that were true, the 'owner' would be a finance company - that would mess them up!


I'd defiantly appeal as this will give you further access to the POPLA appeal process which will further consume a period of time.

Also, personal experience tells me that POPLA are unlikely to agree with the operators statement regarding 'reasonable assumption' with regard to keeper liability - the fact is, there is no legal mechanism which can move liability from the owner to the keeper. If liability could be shifted from party to party so easily then there would be no need for the processes set out in PoFA. The fact that PoFA exists clearly demonstrates that the law requires something greater than 'reasonable assumption' when moving liability to the keeper. The operator's claim of reasonable assumption is being made out of necessity rather than any proven legal process. VCS v Edward also confirms the legal position of reasonable assumption with regard to keeper liability.
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: mrfence on January 20, 2026, 05:08:48 pm
Can you show us the letter/email received, including the bit where they've "given [you] a week to appeal"?

Sorry here it is, for some reason it got clipped from my last post.

regarding the refusal to accept liability for the Penalty Notice issued for a breach of Railway Byelaws “Byelaws”.

Railway Byelaw 14 expressly provides that the owner of the vehicle is liable for a Penalty Notice. Whilst the Driver and Vehicle Licensing Agency (DVLA) has provided registered keeper details and not details on the owner of the vehicle, it is reasonable to rely on registered keeper details as prima facie indication of ownership.

If the registered keeper is not the owner, the appropriate course is for the registered keeper to identify the actual owner. In absence of such ownership, liability correctly remains with the registered keeper.

Your assertion that an offence under Byelaws can only be enforced through immediate prosecution is incorrect. The debt resolution stage is lawful and provides an opportunity to resolve the matter prior. If the Penalty Notice remains outstanding, the file will continue to progress accordingly where more fees may be applied.

If you would like to appeal the issuing of this Penalty Notice, please confirm within seven (7) days. If appealed, we will provide you with an official appeal response. Please note, if an appeal is not received within this timeframe, and the points raised are not in relation to the issuing of this Penalty Notice, your account will progress accordingly.
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: DWMB2 on January 20, 2026, 03:10:21 pm
I would, on the last possible day of the 7 day deadline, appeal. I'd be minded to just submit something simple like:

Dear Sirs

I am appealing this penalty notice in my capacity as the registered keeper, on the basis that I have no liability. You have not demonstrated that I am the owner of the vehicle (being the registered keeper is not proof of ownership), nor that I am the driver. It is further disputed that the alleged contravention took place, and that the requirement to pay for parking was adequately communicated to the driver by signage at the site - Saba are put to strict proof of both.

If you do not uphold this appeal, you must provide a POPLA code.

Yours
[/i]

It's not a particularly strong appeal nor will it succeed, but the goal here is just to get a POPLA code and drag the matter out closer to the 6 month period. You could just ignore, but by challenging them you at least get the satisfaction that they have to pay for POPLA.
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: mrfence on January 20, 2026, 03:00:58 pm
Can you show us the letter/email received, including the bit where they've "given [you] a week to appeal"?

It was an email so don't have a hard copy.

Title: Re: Penalty Notice from Saba for not paying for parking
Post by: DWMB2 on January 20, 2026, 02:20:27 pm
Can you show us the letter/email received, including the bit where they've "given [you] a week to appeal"?
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: mrfence on January 20, 2026, 02:10:29 pm
I had hoped that this had gone away, but over three weeks after I responded they've come back and given me a week to appeal, which in itself feels a bit cheeky.

Anyway, addressing the points in my previous email to them taken from the forum, they thank me for getting back to them and say

regarding the refusal to accept liability for the Penalty Notice issued for a breach of Railway Byelaws “Byelaws”.

Railway Byelaw 14 expressly provides that the owner of the vehicle is liable for a Penalty Notice. Whilst the Driver and Vehicle Licensing Agency (DVLA) has provided registered keeper details and not details on the owner of the vehicle, it is reasonable to rely on registered keeper details as prima facie indication of ownership.

If the registered keeper is not the owner, the appropriate course is for the registered keeper to identify the actual owner. In absence of such ownership, liability correctly remains with the registered keeper.

Your assertion that an offence under Byelaws can only be enforced through immediate prosecution is incorrect. The debt resolution stage is lawful and provides an opportunity to resolve the matter prior. If the Penalty Notice remains outstanding, the file will continue to progress accordingly where more fees may be applied.

If you would like to appeal the issuing of this Penalty Notice, please confirm within seven (7) days. If appealed, we will provide you with an official appeal response. Please note, if an appeal is not received within this timeframe, and the points raised are not in relation to the issuing of this Penalty Notice, your account will progress accordingly.


I'd be grateful for any advise on the best way to respond to them on this matter.
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: b789 on December 26, 2025, 05:15:02 pm
I also suggest you send this formal complaint to Saba in anticipation of escalation to the BPA and a DVLA and ICO compliant. Send it by email to dpo.uk@sabagroup.com and CC customersupport.uk@sabagroup.com and yourself:

Quote
Dear Sir or Madam,

This email constitutes a formal complaint concerning your handling of the above-referenced Penalty Notice and your repeated, demonstrably false representations of the legal position relating to Railway Byelaws, the Protection of Freedoms Act 2012 (PoFA), DVLA keeper data, and alleged “owner liability”.

Please ensure this complaint is logged and handled under your formal complaints procedure. I require a substantive, point-by-point written response addressing each issue raised below.

As this complaint concerns the misuse of DVLA keeper data, unlawful processing, and misrepresentation of legal liability, it is properly addressed to the Data Protection Officer. If you consider another department to be responsible for complaints handling, this email constitutes formal service of the complaint and must be redirected internally. I do not consent to being forced through web portals or processes requiring unnecessary personal data or mischaracterising this correspondence.

Complaint summary

Your correspondence does not reflect a single error, but a pattern of serious and sustained legal misstatements, escalating from false claims of PoFA keeper liability to an invented concept of “owner liability”. These misstatements materially misrepresent the recipient’s legal position and are plainly capable of coercing payment under false pretences.

This is not a minor disagreement. It is a serious compliance failure.

Specific grounds of complaint

1. False assertion of PoFA keeper liability on railway byelaw land

In your correspondence you stated:

“the Parking Charge does comply with the Protection of Freedoms Act (PoFA) 2012 as the initial notification … was sent within 14 days… the registered keeper will remain liable”.

This statement is unequivocally false.

PoFA Schedule 4 can only apply to “relevant land”. Land subject to statutory control by Railway Byelaws is expressly excluded from the definition of relevant land. Where Railway Byelaws apply, PoFA is legally incapable of transferring liability to a registered keeper, regardless of timing, wording, or internal process.

The date of sending is irrelevant. The 14-day provision you cited does not override the statutory exclusion of byelaw land from PoFA. Your assertion reduces PoFA compliance to a crude tick-box exercise (“sent within 14 days = keeper liable”) while ignoring the foundational requirement that PoFA must be capable of applying in law.

It was not.
It cannot.
And at the material time it did not.

Your subsequent demand that I “must” identify the driver within seven days, coupled with the threat that the keeper would “remain liable” if I did not, compounds this misrepresentation. PoFA imposes no obligation on a keeper to name a driver in any circumstances, and on railway byelaw land there is no keeper liability to “remain”.

This conduct materially misstates the law and the recipient’s legal obligations.

2. Misrepresentation of Railway Byelaws enforcement

You assert that a breach of Railway Byelaw 14 has occurred. A byelaws breach is a statutory matter. It is enforceable, if at all, only by prosecution in the magistrates’ court by an entity with standing to prosecute.

It is not enforceable by private invoice, payment “invitation”, or administrative declaration of liability. You are not entitled to replace the statutory enforcement framework with a private demand for payment.

Your repeated demands for payment therefore misrepresent the true legal position.

3. False and unsustainable claims of “owner liability”

Having wrongly asserted keeper liability under PoFA, you later claimed that “the owner of the vehicle is held liable in all circumstances”.

This assertion is legally baseless and evidentially indefensible.

There is no register of vehicle owners available to you. DVLA data identifies only the registered keeper. The V5C explicitly states, in bold print, that it is not proof of ownership. You therefore have no lawful or factual basis to assert that the person you are writing to is the owner of the vehicle.

In many routine scenarios — lease vehicles, hire vehicles, financed vehicles, company cars, fleet arrangements — the owner, registered keeper, and driver are all different parties. Your position ignores this reality entirely.

You cannot impose liability on a person whose alleged status (owner) you cannot even identify, let alone evidence.

4. Conflation of owner, keeper, driver, and hirer

Your correspondence moves interchangeably between “owner”, “keeper”, and “driver/hirer” as if these were interchangeable legal concepts. They are not.

This conflation is misleading and appears calculated to ensure that someone — anyone — feels pressured to pay, regardless of whether you can identify the correct party under the correct legal framework.

5. Misuse of DVLA keeper data/absence of reasonable cause

You obtained my DVLA keeper data and used it to pursue payment based on false assertions of PoFA compliance, keeper liability, and later “owner liability”.

Given that:
• PoFA does not apply,
• no keeper liability exists,
• no civil owner liability exists, and
• you are not pursuing a prosecution,

your continued processing of my keeper data raises serious questions as to whether you ever had, or continue to have, reasonable cause to obtain or use it.

What I require from you

A. Written confirmation that this Penalty Notice is cancelled and that no further enforcement action will be taken.
B. Written confirmation that my personal data will cease to be processed for this matter and will be erased where required by data protection law.
C. A clear, reasoned explanation of how and why your staff were instructed to assert PoFA compliance, keeper liability, and “owner liability”, including the legal basis relied upon.
D. Confirmation of the complaint reference number and a copy of your internal complaints procedure.

Next steps

If this complaint is not resolved in full, I will escalate the matter without further notice to:
• the British Parking Association,
• the DVLA (for misuse of keeper data and lack of reasonable cause), and
• the Information Commissioner’s Office (for unlawful processing and misleading representations tied to that processing).

Your correspondence to date is being retained as evidence. Any failure to address each issue substantively will itself form part of the escalation.

I expect a full and reasoned response, not boilerplate.

Yours faithfully,

[Full name]
[Address]
[Vehicle registration]
[Penalty Notice reference]
[Email]
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: b789 on December 26, 2025, 04:20:28 pm
Not sure why Saba are referring to the "Hirer". Are you the Keeper or the Hirer? Which station was this alleged contravention at as I need to now which TOC to submit a formal complaint to about Saba's unlawful activity.

Saba are trying to blur three different ideas (“owner”, “keeper” and “driver/hirer”) because it helps them pressure the recipient into paying. In a railway byelaws matter, that conflation is exactly what breaks their position.

Start with what a “byelaws penalty” actually is. Railway Byelaws are a statutory scheme. If Saba are alleging a breach of Byelaw 14, they are alleging a statutory offence. Statutory offences are not enforced by sending a payment demand and then treating non-payment as a civil debt. The only lawful enforcement route is prosecution in the magistrates’ court within the applicable time limit, brought by an entity with standing to prosecute (in practice the Train Operating Company or another properly authorised prosecutor). A private parking contractor like Saba does not get to convert an alleged offence into a pay-us invoice enforceable against whoever they choose.

That leads to the key point: “liability” in criminal/byelaws land is not the same thing as “liability” for a civil parking charge. In a civil parking charge model, an operator tries to show a contract with the driver, and then (only where PoFA applies on relevant land) sometimes transfers liability to the registered keeper. None of that applies to a railway byelaws allegation. There is no PoFA transfer. There is no county court “debt” claim for a byelaws offence. There is only prosecution, and prosecution requires a specific defendant.

Now look at “owner”. Even if the byelaws mention the owner in some contexts, that does not hand Saba a magic power to invoice “the owner” and demand payment to Saba. If the allegation is genuinely a byelaw offence, any sanction is imposed by a court on conviction, not by Saba by email. Saba cannot simply declare “the owner is liable” and then treat that declaration as a standalone cause of action. The court would still need a named defendant, and the prosecutor would need to prove the necessary elements to the criminal standard. An email assertion that “you remain liable” proves nothing.

This is compounded by a basic evidential problem that Saba never address. There is no register of vehicle owners that they can consult. The only data source available to them is DVLA registered keeper data. That data identifies a registered keeper for vehicle administration purposes only; it does not identify ownership. The V5C itself states, in bold terms, that it is not proof of ownership. Accordingly, even if Saba are writing to the person named on the V5C, that provides no evidence at all that the recipient is the legal owner of the vehicle.

Crucially, “owner” is not the same as “registered keeper”. In a hire or lease situation the “owner” is commonly the finance or lease company, the “keeper” might be the hirer or fleet manager, and the “driver” is the person using it that day. Those can be three completely different parties. Saba’s statement that they have “no cause of action against the driver or hirer” but that “the owner is held liable in all circumstances” is therefore internally incoherent. If they genuinely mean “owner”, they are often writing to the wrong party. And even if they were writing to the actual owner, they still cannot enforce a byelaws allegation by private invoice, nor can they compel a keeper to provide proof of purchase or ownership to assist them.

Finally, when Saba say they are “not updating to the driver/hirer” and that the recipient must seek redress from the hirer under a contract, they are effectively admitting what they are doing: treating this as a private billing dispute, not a prosecution. That is exactly the problem for them. If they stick with “byelaws offence”, they must prosecute, and they cannot use PoFA keeper liability or an invented concept of “owner liability” to make it into a civil debt. If they switch to “civil contract charge”, then it is not a byelaws penalty at all, and the only potentially liable party is the driver (subject to the usual contractual and signage issues), not some rotating cast of “owner/keeper/hirer” chosen for convenience.

So, in plain terms: the “owner” cannot be made liable by Saba’s say-so. Keeper and hirer are irrelevant to a byelaws offence unless a properly authorised prosecutor brings a magistrates’ case against a specific person and proves what the law requires. Saba are not the prosecutor, and they cannot enforce an alleged byelaws offence as a private debt. The only party who could ever be directly responsible for the alleged parking conduct itself is the person who parked or was in charge of the vehicle at the time (the driver/operator), and even then liability only arises in the way the law permits: through prosecution, not through a contractor’s payment demand.

I advise you to respond to that legally embarrassing statement from the morons at Saba with the following:

Quote
Dear Sir or Madam,

Thank you for your latest email. It is, if nothing else, a fascinating demonstration of how confidently a legal position can be asserted while being entirely untethered from reality.

You now claim that “the owner of the vehicle is held liable in all circumstances” for a Railway Byelaws Penalty Notice, while also assuring me that you have “no cause of action” against the driver or hirer. This is not some subtle or technical error. It is a wholesale failure to understand the very framework you are invoking.

If this matter truly concerns an alleged breach of Railway Byelaw 14, then it concerns a statutory offence. Statutory offences are not enforced by emails, payment invitations, or your internal declarations of who you have decided is “liable this week”. They are enforced, if at all, by prosecution in the magistrates’ court, brought by a party with standing to prosecute. You are not such a party, and you do not acquire enforcement powers simply by repeating the word “liable” often enough.

Your attempt to rescue this position by invoking “the owner” is particularly inept.

There is no register of vehicle owners available to you. The only data you ever obtain is DVLA registered keeper data. That data does not establish ownership. The V5C itself spells this out for the benefit of anyone who bothers to read it, stating in bold print that it is not proof of ownership. One would have hoped this was familiar territory for a company claiming expertise in parking enforcement, but apparently not.

So even before we get to law, you face a basic factual problem: you have no idea who the owner is. In the real world, the owner, the registered keeper, and the driver are very often three different parties — lease vehicles, hire vehicles, financed vehicles, company cars, fleet arrangements, and family registrations being entirely routine examples. Your assertion that “the owner is liable in all circumstances” therefore manages to be legally wrong, evidentially unsupported, and practically nonsensical all at once.

It becomes more farcical when you suggest that I should “seek redress from the hirer under my contract”. That language is not the language of a prosecutor enforcing a statutory offence. It is the language of a private billing dispute, hastily stitched together in the hope that someone, somewhere, will simply pay to make you go away. That hope is not a legal framework.

To assist you, since you appear to be struggling:

• PoFA does not apply on railway byelaw land.
• There is no keeper liability.
• There is no such thing as freestanding civil “owner liability” that you can invent by email.
• There is no lawful mechanism for you to enforce an alleged byelaws offence as a private debt.

If you genuinely believe an offence occurred, your only lawful option is to pursue a properly authorised prosecution in the magistrates’ court against an identifiable defendant and prove your case to the required evidential standard - beyond. reasonable doubt. Everything else you are doing is noise.

I do not accept liability as keeper, hirer, alleged owner, or any other label you wish to experiment with next. I will not be naming any driver, providing ownership documents, or engaging further with arguments that appear to have been assembled without even a passing acquaintance with the law.

If you continue to repeat these demonstrably false assertions, I will simply retain your correspondence as evidence of your ongoing misrepresentation of the legal position.

Yours faithfully,

[Name]
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: InterCity125 on December 26, 2025, 10:39:58 am
Their response is total nonsense.

They must be pretty dumb and clearly do not understand the difference between the two types of law involved here.

Also note that they have now introduced, "the owner of the vehicle is held liable"

So we now have, "the owner", "the keeper" and, "the driver" who could all be completely different parties.

Ultimately, this will not go anywhere because there is no legal pathway for them to pursue any of the above.


Wait for further advice - you could have some fun with this one.
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: mrfence on December 26, 2025, 09:59:33 am
Merry Christmas everyone.

I didn't get a card from the parking charge people, but did get this following my sending of the previous recommended response above...

Thank you for your recent correspondence received at our offices and noted accordingly.

This matter relates to a Penalty Notice issued under Railway Byelaws. An offence was committed by breaching Railway Byelaw 14 and therefore a Penalty Notice was issued against this vehicle.

The owner of the vehicle is held liable for all Penalty Notices issued on Railway assets in all circumstances, as such we have no cause of action against the driver or hirer of the vehicle.

Subsequently, the driver or hirer details will not be updated to our system, and you remain the liable party on this account and any course for redress will need to be addressed directly with the hirer of your vehicle under the terms of your contract with them.

We, therefore, again invite you to make payment to be received within fourteen (14) days of the date of this email to settle this file. Please refer to the reverse of our original letter for methods of payment.

Alternatively, you can respond to this email with context of the mitigating circumstances that led to non-payment on the day and we can process the appeal accordingly.

We have placed this matter on hold for 7 days.


Seems a bit of discrepancy between the seven days on hold and the fourteen day window in which they've 'invited' me to pay, but I'd appreciate an appropriate response to get them to drop the issue.

Title: Re: Penalty Notice from Saba for not paying for parking
Post by: b789 on November 26, 2025, 11:50:04 am
FYI, I have just reported SABA to the CMA under the DMCC. It takes only a few minutes and this is the content of my report:

Quote
I am reporting Saba Park Services UK Ltd for what appears to be a misleading and aggressive practice in relation to Penalty Notices on railway land, which I believe may breach the Digital Markets, Competition and Consumers Act (DMCC).

I am an individual who provides free, informal advice to motorists who receive private Parking Charge Notices and Penalty Notices. Through this I see patterns of behaviour across operators. Saba is a clear example of a wider issue: private firms issuing Penalty Notices under Railway Byelaws, but then trying to recover them as if they were civil parking debts enforceable against the registered keeper under Schedule 4 of the Protection of Freedoms Act 2012 (PoFA), even though PoFA does not apply on railway byelaw land.

In the case I am reporting, Saba issued a Penalty Notice for an alleged breach of Railway Byelaw 14 at a railway station car park on 9 October 2025. The land is subject to railway byelaws and is therefore not “relevant land” for PoFA. There is no statutory mechanism to transfer liability from an unknown driver to the keeper.

The registered keeper appealed on that basis. In a written response dated 26 November 2025, Saba:

- claimed that the “Parking Charge does comply with PoFA 2012” because it was sent within 14 days;
- stated that “the registered keeper will remain liable for this matter” if no appeal is received from the driver within 28 days; and
- demanded that, because the keeper had allegedly “marked” they were not the driver, they must provide “the driver’s full name and serviceable address within seven (7) days”, or make the driver write in and “confirm that they were the driver on the day”.

In my experience this is not a one-off mistake but standard boilerplate wording that Saba is applying to byelaw cases.

This conduct misrepresents the legal position and, in my view, meets the tests for a misleading and aggressive commercial practice:

1. It asserts PoFA compliance and automatic keeper liability in a situation where PoFA cannot apply.
2. It tells the keeper that they “will remain liable” when in law no such keeper liability exists on this type of land.
3. It strongly implies that the keeper has a legal obligation to identify the driver within seven days, which is untrue.
4. The overall impression is that there is an inevitable civil debt enforceable against the keeper, without explaining that an alleged Byelaw 14 offence can only properly be pursued in the magistrates’ court, within a six-month time limit, and that there is no separate PoFA keeper-liability route.

A typical motorist, unfamiliar with the distinction between PoFA “relevant land” and railway byelaw land, would be very likely to be misled into paying or disclosing third-party personal data on the basis of these false legal claims.

I am concerned that Saba, and another railway parking contractor, APCOA, are systematically converting alleged criminal byelaw offences into quasi-civil debts backed by misleading statements about PoFA and keeper liability. I am able to supply copies of the Penalty Notice and correspondence to support this report.
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: b789 on November 26, 2025, 10:40:18 am
You respond to that email with the following:

Quote
Subject: Your misuse of PoFA on railway land and impending CMA complaint

Dear Sir/Madam,

Your email perfectly illustrates why I made it crystal clear in my original appeal that this is railway byelaw land and therefore not “relevant land” for the purposes of Schedule 4 of the Protection of Freedoms Act 2012. Yet you have blithely asserted that your Penalty/“Parking Charge” Notice “does comply with PoFA” and that the registered keeper “will remain liable”. That is simply wrong in law. PoFA cannot create keeper liability on land subject to statutory control by railway byelaws, however many times you type the words “PoFA 2012”.

The fact you have a 'sent date' within 14 days is irrelevant. On byelaw land, your only lawful route is a byelaw prosecution in the magistrates’ court under the Single Justice Procedure within six months of the alleged offence. There is no parallel civil keeper-liability regime you can conjure into existence by misquoting PoFA and hoping the keeper does not know any better.

Equally absurd is your attempt to manufacture an obligation for me to identify the driver or to get the driver to appeal. PoFA imposes no such duty on a keeper in any circumstances, and the Railway Byelaws certainly don’t. Your demand that I “must” hand over the driver’s name and address within seven days, coupled with the threat that the keeper will remain liable if I do not, is a textbook misleading statement about my legal position and alleged obligations.

You then compound this by claiming that I have “marked” that I was not the driver. My appeal did no such thing. It simply identified me as the keeper and correctly pointed out your lack of any lawful keeper-liability route. If your “appeals” staff or in-house “legal” team are incapable of understanding the difference, you may wish to consider investing in competent legal counsel, or at the very least some basic training on PoFA, railway byelaws, and the concept of relevant land. At present, your grasp of the law appears to begin and end with copying boilerplate PoFA wording into emails where it plainly cannot apply.

Your mendacious assertions about keeper liability, my supposed obligation to identify the driver, and the inevitability of the keeper “remaining liable” are not just embarrassing; they are likely to amount to unfair and misleading commercial practices. I will therefore be reporting this matter to the Competition and Markets Authority for suspected breaches of the Digital Markets, Competition and Consumers Act in relation to:

* misrepresenting the legal position on liability and consumer obligations;
* implying a statutory or contractual liability that does not exist; and
* using misleading, aggressive wording to pressure a consumer into making payment or disclosing third-party data.

I will also be bringing your conduct and this correspondence to the attention of the DVLA, your Accredited Trade Association, and the relevant Train Operating Company, as I do not consent to my keeper data being used to underpin a fictitious “PoFA liability” that is legally impossible on this site.

For the avoidance of doubt, I will not be naming the driver, I do not accept any keeper liability, and I am fully aware of the legal framework you are attempting – unsuccessfully – to misapply. Any further repetition of these false assertions about PoFA and keeper liability will simply be added to my evidence bundle for the regulators.

Yours faithfully,

[Name]
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: mrfence on November 26, 2025, 10:08:39 am
I sent the recommended text in my appeal and have received an update from them...

We have received your appeal as the Registered Keeper. Please be advised, the contravention was on 9/10/25 and we had sent the Parking Charge on 16/10/25 therefore, the  Parking Charge does comply with the Protection of Freedoms Act (PoFA) 2012 as the initial notification of the Parking Charge was sent within 14 days of the contravention.

Whilst we do not dispute what you have or have not received and in what timeframe, the progression of the matter begins from the day the Parking Charge is sent. Due to this, we would require the driver to appeal the issuing of the Parking Charge, in the absence of an appeal within the twenty-eight (28) day timeframe the registered keeper will remain liable for this matter.

As you have marked you were not the driver, please provide their full name and serviceable address within seven (7) days of the date of this email. Alternatively, please request the driver appeals directly to appeals@paymyparkingcharge.com. Within this email they will need to confirm their full name, serviceable address and confirmation that they were the driver on the day.

This account will be placed on a seven (7) day hold to allow the driver time to contact our company or for the requested details to be provided.


What would be the next course of action?
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: b789 on October 24, 2025, 07:16:01 pm
Ah, yes. My bad. I was under the assumption this was a windscreen PN. Never mind.

You should still appeal just before the deadline with the following:

Quote
I am the Keeper. This location is subject to Railway Byelaws and is not “relevant land” for PoFA 2012; you cannot transfer liability to the keeper. POPLA is not competent for Byelaws matters and is not a TOC approved Independent Appeals Body (IAB).

If you believe an offence occurred, lay an information before the magistrates under the Single Justice Procedure within six months. Otherwise, erase my data when no longer necessary for this purpose.

As to any further demands, I refer you to the response given in Arkell v Pressdram (1971).

This will not be prosecuted, no matter what they threaten.
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: InterCity125 on October 24, 2025, 11:57:18 am
The original notice was a notice by post so keeper details have already been obtained from the DVLA.
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: jfollows on October 24, 2025, 10:10:12 am
The last post says
Quote
You appeal on day 27 after the date of the alleged contravention
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: mrfence on October 24, 2025, 10:04:52 am
Thanks for the advice.

I'll send that over on day 27.

Just to be clear, is it 27 days after the alleged offence or 27 days after the date on the penalty notice?
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: b789 on October 22, 2025, 03:35:04 pm
You appeal on day 27 after the date of the alleged contravention with the following, but ONLY as the Keeper of the vehicle:

Quote
I am the Registered Keeper. My details are:
Full name: [ ]
Postal address: [ ]

This location is subject to Railway Byelaws and is not “relevant land” for PoFA 2012; you cannot transfer liability to the keeper. POPLA is not competent for Byelaws matters and is not a TOC approved Independent Appeals Body (IAB).

You now have the keeper’s details. You therefore have no “reasonable cause” to obtain them from DVLA. Any DVLA request would be unnecessary and unlawful, contrary to UK GDPR Article 5(1)(c) (data minimisation) and without a valid Article 6 basis. If you believe an offence occurred, lay an information before the magistrates under the Single Justice Procedure within six months. Otherwise, erase my data when no longer necessary for this purpose.

As to any further demands, I refer you to the response given in Arkell v Pressdram (1971).

That is all you need. Nothing will ever come of this but you have to go through the motions. Come back when they reject the appeal and show us the wording.

From November, SABA and APCOA will not be allowed to issue Penalty Notices for railway bylaw breaches as criminal offences. They are going to be required to only issue Parking Charge Notices (PCNs) for civil breach of contract by the driver.
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: jfollows on October 22, 2025, 02:36:13 pm
Discretion won’t work, these people only want your money and can only be challenged on technicalities.

In this case, the only sanction is a prosecution for an offence covered by byelaws. Saba can’t do this, and even if they could they wouldn’t get any money.

Whatever you do, don’t hurry because the original offence can’t be prosecuted after six months anyway.
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: jfollows on October 22, 2025, 02:09:25 pm
See https://www.ftla.uk/private-parking-tickets/800-parking-tickets-completely-unjust-where-do-i-stand-england/msg89074/#msg89074
Quote
Do nothing. SABA have 6 months in which to lay information before a magistrate. They won’t, because there is no money in it for them as any “fine” would go to the public purse, not SABA.

However, they will tell you that if you don’t pay it, they will issue a county court claim for the alleged debt. They can’t, because you cannot prosecute a statutory offence in the county court.

It is all part of a giant scam that should be reported to the police (not Action Fraud) as the Penalty Notices are instruments of fraud and an illegal attempt to extort money from you under the false pretence that you are criminally liable.

If they were ever so stupid as to try this on, either in the magistrates court or the county court, they would be spit to strict proof of their standing to issue Penalty Notices.

You cannot prosecute a safely ignore all debt recovery letters. Debt collectors, just like SABA, are powerless to actually do anything in this case beyond making unlawful threats in the hope that you are low-hanging fruit on the gullible tree and are likely to pay up out of ignorance and fear.

Keep us updated on their responses. We don’t need to see any debt recovery letters but any correspondence from SABA themselves must be kept as evidence of their illegal activity, especially if they threaten debt recovery through the county court for a Penalty Notices are.
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: mrfence on October 22, 2025, 02:00:45 pm
Thanks, have updated the original post and put in an image of the notice.
Title: Re: Penalty Notice from Saba for not paying for parking
Post by: DWMB2 on October 22, 2025, 01:03:27 pm
Welcome to FTLA.

To help us provide the best advice, please read the following thread carefully and provide as much of the information it asks for as you are able to: READ THIS FIRST - Private Parking Charges Forum guide (https://www.ftla.uk/private-parking-tickets/read-this-first-private-parking-charges-forum-guide/)
Title: Penalty Notice from Saba for not paying for parking
Post by: mrfence on October 22, 2025, 01:01:15 pm
Received a 'penalty notice by post notice to owner' from Saba this morning (22/10), though dated (16/10), for not paying for parking in a station car park on 9/10.

The driver parks there once or twice a week and is in the habit of paying on the app as they walk to the platform. There is no auto-pay feature.

Looking at the app, there is no record of the driver paying for parking on that day. This is baffling as paying is part of their routine and they do have a train ticket which is something they also buy at the same time.

The driver doesn't recall getting an error on the app, so can only assume that for some reason they forgot to pay.

My question is whether there is any merit in requesting some discretion due to human error?
If so, are there any key phrases to include or avoid?

When they changed their app, they had issues on the first day so the driver was charged three times due to it giving an error when it was actually processing the payment. Saba gave a refund, but the driver didn't charge them £60 for their mistake!

(https://i.postimg.cc/NFjDB4vy/Saba-Parking-Fine-Oct25.jpg)