1. I am the registered keeper of vehicle [VRM]. I appeal to the IAS against UK Car Park Management Ltd (“the Operator”) in respect of Parking Charge Notice [PCN NUMBER], issued in relation to an alleged contravention on 04/11/2025 at approximately 20:48. Liability is denied in full. This is a dispute of substance about contract formation, evidential sufficiency, landowner authority, and the Operator’s compliance with mandatory requirements of the Private Parking Single Code of Practice (“PPSCoP”) and the law of contract.
2. The Operator bears the burden of proof. It must prove on the balance of probabilities (i) the precise location and circumstances of the alleged contravention; (ii) that the driver was offered clear contractual terms capable of acceptance; (iii) that the driver accepted those terms; (iv) that the charge is recoverable as a contractual charge rather than an unenforceable penalty or damages dressed up as a contractual sum; and (v) that the Operator has proper standing and landowner authority to contract with motorists and to pursue charges in its own name. A bare assertion is not evidence.
3. The Operator’s handling of the initial appeal is relevant background to credibility and fairness. The Operator initially refused to process the appeal unless the driver’s full name and serviceable address were provided. That position was improper. There is no general legal obligation upon a registered keeper to name the driver in a private parking matter. That the Operator sought to impose this as a condition of considering a keeper appeal demonstrates a procedural approach geared to coercion rather than genuine dispute resolution. Whilst the Operator has now issued a template rejection, it still fails to engage with the substance of the issues raised and remains evidentially deficient.
4. Procedural fairness and the asserted legal competence of the IAS assessor. The IAS states that appeals are determined by legally qualified assessors, typically solicitors or barristers. Decisions are anonymous, unsigned, and provide no verifiable indication of the assessor’s qualification, practising status, or independence. Where an ADR scheme relies on claimed legal expertise as a marker of credibility, it is reasonable to expect decisions to demonstrate that expertise through structured legal analysis rather than assertion.
5. I therefore invite the IAS to confirm in its decision, without disclosing personal data, whether the assessor determining this appeal is a practising solicitor of England and Wales, a barrister holding a practising certificate, or another legally qualified person, and to confirm that no conflict of interest exists. If the IAS declines to provide even this minimal confirmation, I request that it explains how that position is compatible with transparency and consumer confidence in ADR.
6. This request is directly relevant. The present dispute involves core legal issues: contract formation, the distinction between prohibition and contractual offer, evidential proof of parking as opposed to momentary presence, locus and landowner authority, and compliance with mandatory Code requirements. A legally trained decision-maker will recognise that these are determinative questions and will address them by reasoned analysis. If the IAS intends to dismiss the appeal, I request that it does so by engaging with those legal elements rather than by conclusory statements such as “signage was present” or that the charge was “issued correctly”.
7. The rejection letter asserts that “there is no parking outside of a marked bay” and that the vehicle was “parked in contravention of the terms and conditions as advertised on the signage displayed on site.” That is an unparticularised conclusion. It does not identify (a) the exact boundary of the land the Operator contends is “the site”; (b) the exact position of the vehicle; (c) the wording of the alleged contractual term; (d) the specific sign relied upon and its location relative to the vehicle; (e) how the sign could have been read, understood and accepted at the material time, at night; or (f) evidence of duration showing “parking” as opposed to a brief stop.
8. Failure to prove “parking” as opposed to a momentary stop. The Operator has not proven that the vehicle was parked at all. The circumstances were consistent with a brief stop for passenger collection, in a turning area or junction environment, after manoeuvring. A short stop while a passenger enters a vehicle is not necessarily “parking” in the ordinary meaning of the word and is materially different from leaving a vehicle parked as contemplated by typical private parking terms. The Operator’s evidence must show a meaningful period of parking. If the Operator relies on timestamped photographs, it is put to strict proof that those timestamps evidence a period of presence that is more than momentary and that they show the vehicle stationary in a manner that meets any alleged definition of “parking”. A single instant in time does not prove a contravention of a “no parking” term.
9. Failure to prove the exact location and that it is controlled land within the Operator’s remit. The Operator has not provided a boundary map or a clear site plan showing where the controlled land begins and ends, what parts are said to be roadway, access road, car park or marked bays, or that the alleged location falls within land over which it has authority. This is not a technicality. If the vehicle was on or adjacent to highway land, or on land outside the Operator’s remit, there is no cause of action. The Operator’s rejection ignores this entirely.
10. Failure to prove adequate signage and therefore failure of contract formation. A parking charge can only be recovered as a contractual term if the terms were clearly brought to the driver’s attention before any alleged acceptance. This requires prominent, legible signage positioned so that a driver can read it in time to decide whether to enter or stop. The material time was after 20:48 in early November, in darkness. The Operator has produced no evidence of illumination, reflective material, sign orientation, font size, or readability from a driver’s perspective, nor photographs showing what the driver would have seen on approach or at the stopping position. A generic assertion that “signage is displayed on site” is not evidence of communication of terms.
11. In particular, the Operator must prove the charge term was prominent. The Supreme Court decision in ParkingEye v Beavis turned on unusually prominent signage and a specific commercial justification. It does not permit operators to impose £100 charges on the basis of obscure, unreadable, or unseen terms. Absent strict proof that the charge itself was prominently displayed and legible at the material time, the appeal must be allowed.
12. Forbidding or prohibitory signage and absence of contractual offer. UKCPM commonly uses signage stating “No parking”, “No stopping” or “No parking outside marked bays” on roadways or access roads. Such wording is prohibitory and incapable of forming a contractual offer to park for a fee. A prohibition cannot be accepted; at most it alleges trespass, which only a landholder may pursue and only for nominal damages. The Operator must therefore prove that the signage relied upon constituted a contractual offer capable of acceptance rather than a bare prohibition. If the case is “you must not park here”, no contract exists and the charge is unrecoverable.
13. Failure to evidence landowner authority. The Operator was expressly put to strict proof of landowner authority and compliance with PPSCoP Section 14. The rejection letter does not engage with this point at all. The Operator must produce contemporaneous written authorisation defining the land, the scope of enforcement, any permissions or exemptions, and authority to issue charges and pursue recovery in its own name, together with a boundary map. Without this, the Operator lacks standing and the appeal must be allowed.
14. Failure to engage with the substance of the appeal. The rejection is boilerplate. It does not answer the questions posed about signage adequacy, boundary definition, landowner authority, night-time visibility, the distinction between parking and a brief stop, or the legal nature of the signage. A statement that a PCN was “issued correctly” is not a reasoned determination.
15. Evidence quality and reliability. The Operator is put to strict proof that its evidence is accurate, contemporaneous, correctly timestamped, and contextual. Any photographs must show the vehicle’s position relative to bays or markings, the presence and location of signage, the route of approach, and that signage was readable at night. Close-ups without context do not discharge the burden of proof.
16. Keeper liability under the Protection of Freedoms Act 2012. If the Operator seeks to rely on keeper liability, it must demonstrate strict compliance with Schedule 4 of PoFA. If it does not, then it has no lawful route to pursue the keeper. The Operator’s earlier attempt to compel driver identification strongly indicates it cannot or will not rely on PoFA, a point the IAS is invited to consider.
17. PPSCoP consideration and grace periods. The PPSCoP treats consideration and grace as distinct concepts. Where an alleged contravention involves a very brief presence, the Operator must show it considered whether the event fell within a permitted consideration period. The Operator has produced no evidence of such consideration and has merely asserted a prohibition.
18. Consumer fairness and transparency. The Operator’s references to additional charges and credit impact are noted. Any credit impact can only arise following a court judgment that remains unpaid beyond the statutory period. Template wording implying otherwise is misleading and relevant to credibility.
19. Remedy sought. The Operator has failed to prove contract formation, failed to prove standing or landowner authority, failed to prove that the vehicle was parked rather than briefly stopped, and failed to rebut the substantive points raised. The IAS is invited to allow the appeal and direct cancellation of the PCN. In the alternative, the IAS is invited to require production of the landowner contract and boundary map, a full site plan with sign locations, contemporaneous legible photographs of the signage relied upon, and contextual photographs showing the vehicle’s position in night-time conditions. In the absence of that evidence, the appeal must be allowed.
I am the registered keeper. Your refusal to process my appeal unless I identify the driver is unacceptable, unlawful, and will be treated as evidence of bad faith in any future proceedings.
You have my full and correct name and address. You obtained these details from the DVLA under the KADOE contract. That contract requires you to comply fully with the Private Parking Single Code of Practice.
Your attempt to make identification of the driver a precondition to considering a keeper appeal is a clear breach of both the PPSCoP and the KADOE contract. You are expressly prohibited from using DVLA data to pressure a keeper into naming the driver, and you are required to offer a fair, transparent, and accessible appeals process to the registered keeper, which you are deliberately obstructing.
Your statement that you “cannot verify the information provided” is false. You have already used the same name and address to send the Notice to Keeper. This demonstrates either dishonesty or systemic incompetence. I will rely on this in any defence as evidence of unreasonable conduct.
You will now do one of two things:1. Cancel the PCN, or
2. Issue a formal rejection that addresses the appeal points properly and provides a valid IAS appeal pathway.
If you continue to block the appeal process, misstate legal obligations, or issue any further misleading or coercive demands, I will escalate the matter without further notice. This includes:• A formal complaint to the DVLA for breach of the KADOE contract.
• A PPSCoP compliance complaint to your ATA.
• A regulatory complaint to the Competition and Markets Authority under the strengthened DMCC Act 2024 powers, on the basis that your conduct amounts to an unfair, misleading, and aggressive commercial practice.
• A complaint to my MP regarding your misuse of DVLA keeper data.
If you are reckless enough to litigate on the back of behaviour like this, I will place all of this correspondence before the court when seeking strike out and costs for unreasonable conduct.
Your next communication must confirm cancellation or provide a proper rejection with the IAS pathway. Any further procedural obstruction will be treated as harassment. I expect your response within 14 days.
Why would you even consider paying a vexatious, bottom-dwelling, unregulated private firm of ex-clampers? You appear to be under the impression that you may be liable as the Keeper for an “offence” and liable to a “penalty” or a “fine”,Quote2) The driver is aware that there could be other offences in play which could be made subject of there own penalty given the area is a red route etc.
No “offence” has been committed and the Notice to Keeper (NtK) is definitely not a “fine”. UKCPM are certainly no “authority” that can issue penalties. The NtK is simply a speculative invoice for an alleged breach of contract by the driver.
Only the low-hanging fruit on the gullible tree pay these out of ignorance and fear. Follow the advice you receive here and you will not pay a penny to this scamming firm of vexatious thugs.
They have no case if they were to try and escalate to a county court claim, even though they will do so. The main point is that once defended, they claim will either be struck out or discontinued just before the £27 trial fee has to be paid.
There can be no Keeper liability if the driver is not identified because their NtK does not comply with all the requirements of PoFA. Also, there is no evidence of a consideration period (at least 5 minutes) for a contract to have been formed with the driver.
Forget the 40% mugs discount. Why would you just pay a speculative invoice because it offers a discount? That is just sucker the gullible into thinking they are getting a bargain.
Whilst the IAS is a kangaroo court, we make the operators jump through the hoops because it costs them to challenge an IAS appeal. Not much, but enough for a bit of schadenfreude unless they concede.
We advise and assist every step of the way. For now, simply send the following as your IAS appeal:QuoteI 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 of clear, prominent, and adequate signage that was in place on the date in question, at the exact location of the alleged contravention. This must include a detailed site plan showing the placement of each sign and legible images of the signs in situ. The operator must demonstrate that signage was visible, legible, and compliant with the IPC Code of Practice that was valid at the time of the alleged contravention, including requirements relating to font size, positioning, and the communication of key terms.
2. Strict proof of a valid, contemporaneous contract or lease flowing from the landowner that authorises the operator to manage parking, issue PCNs, and pursue legal action in its own name. I refer the operator and the 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.
3. Strict proof that the enforcement mechanism (e.g. ANPR or manual patrol) is reliable, synchronised, maintained, and calibrated regularly. The operator must prove the vehicle was present for the full duration alleged and not simply momentarily on site, potentially within a permitted consideration or grace period as defined by the PPSCoP.
4. Strict proof that the Notice to Keeper complies with the Protection of Freedoms Act 2012 (PoFA), if the operator is attempting to rely on keeper liability. Any failure to comply with the mandatory wording or timelines in Schedule 4 of PoFA renders keeper liability unenforceable.
5. Strict proof that the NtK was posted in time for it to have been given within the relevant period. The PPSCoP section 8.1.2(d) Note 2 requires that the operator must retain a record of the date of posting of a notice, not simply of that notice having been generated (e.g. the date that any third-party Mail Consolidator actually put it in the postal system.)
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.
2) The driver is aware that there could be other offences in play which could be made subject of there own penalty given the area is a red route etc.
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 of clear, prominent, and adequate signage that was in place on the date in question, at the exact location of the alleged contravention. This must include a detailed site plan showing the placement of each sign and legible images of the signs in situ. The operator must demonstrate that signage was visible, legible, and compliant with the IPC Code of Practice that was valid at the time of the alleged contravention, including requirements relating to font size, positioning, and the communication of key terms.
2. Strict proof of a valid, contemporaneous contract or lease flowing from the landowner that authorises the operator to manage parking, issue PCNs, and pursue legal action in its own name. I refer the operator and the 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.
3. Strict proof that the enforcement mechanism (e.g. ANPR or manual patrol) is reliable, synchronised, maintained, and calibrated regularly. The operator must prove the vehicle was present for the full duration alleged and not simply momentarily on site, potentially within a permitted consideration or grace period as defined by the PPSCoP.
4. Strict proof that the Notice to Keeper complies with the Protection of Freedoms Act 2012 (PoFA), if the operator is attempting to rely on keeper liability. Any failure to comply with the mandatory wording or timelines in Schedule 4 of PoFA renders keeper liability unenforceable.
5. Strict proof that the NtK was posted in time for it to have been given within the relevant period. The PPSCoP section 8.1.2(d) Note 2 requires that the operator must retain a record of the date of posting of a notice, not simply of that notice having been generated (e.g. the date that any third-party Mail Consolidator actually put it in the postal system.)
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.