Free Traffic Legal Advice

Live cases legal advice => Private parking tickets => Topic started by: danvic on November 10, 2023, 09:51:20 am

Title: Re: UKPC parking "not within bay"
Post by: DWMB2 on December 14, 2023, 01:34:25 pm
Well done for standing your ground, good result. Thanks for the update.
Title: Re: UKPC parking "not within bay"
Post by: danvic on December 14, 2023, 01:10:32 pm
Big thank you for all your amazing assistance !  They "investigated the appeal based on the information submitted" and cancelled it.
Really appreciate it.  8)
Title: Re: UKPC parking "not within bay"
Post by: DWMB2 on November 21, 2023, 12:33:58 pm
Yes please if you think its worth a shot. Thankyou
Depends what you mean by 'worth a shot' - it's unlikely to affect their approach at all, but you may feel it's worth responding all the same. Otherwise, you could legitimately ignore it and wait for them to proceed to claim - you've set out your position quite clearly.

Also the original notice was sent to lease company and not to our company so never benefitted from their initial appeal period
This is standard - they don't know who the hirer is until the lease company tell them, so could only send the original notice to them as the registered keeper.

If you are wanting to respond, perhaps something along these lines...
Dear Sirs

We note your comments about our inability to appeal the charge at this stage. We are not seeking to appeal the charge, but to respond to your Letter of Claim to set out why we are not liable for the alleged charge, and to make clear that we intend to rigorously defend any claim, on the grounds we have already explained.

In support of your claims, you have provided copies of the notices issued to our company. We note that despite your claims to the contrary, the Notice to Hirer does not contain the information required by sub-paragraph 14(5) of Schedule 4 of the Protection of Freedoms Act in the specified format. As an example, you have failed to include the warning required by 14(5)(c) of the Act. In addition to this, you failed to provide the following documents specified by 13(2) of the act:
  • a statement signed by or on behalf of the vehicle-hire firm to the effect that at the material time the vehicle was hired to a named person under a hire agreement;
  • a copy of the hire agreement;
  • a copy of a statement of liability signed by the hirer under that hire agreement
Sub-paragraph 14(2)(a) of PoFA makes clear that these documents must be supplied 'alongside' the Notice to Hirer. It is clear from the correspondence we have received, and indeed your own evidence provided most recently, that you have failed to do this, and that as such you cannot recover the charges from us as the hirer.

We deny liability for this alleged charge, and will thoroughly defend any claim brought against us. We trust this clarifies our position.

Yours...
Title: Re: UKPC parking "not within bay"
Post by: danvic on November 21, 2023, 11:43:38 am
Please let me know what response you'd suggest. Also the original notice was sent to lease company and not to our company so never benefitted from their initial appeal period !
Title: Re: UKPC parking "not within bay"
Post by: danvic on November 19, 2023, 04:08:29 pm
Yes please if you think its worth a shot. Thankyou
Title: Re: UKPC parking "not within bay"
Post by: DWMB2 on November 19, 2023, 12:03:10 pm
So we kindly request for evidence that this has not been complied with.
The documents they attached to that very email is evidence of their lack of compliance!

Your call what to do next. If you feel you ought to reply we can help you draft something. Otherwise it's a case of waiting for a claim form from court.
Title: Re: UKPC parking "not within bay"
Post by: danvic on November 19, 2023, 09:58:10 am
attached pics of the 2 "copies of correspondence" they attached with that reply

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Title: Re: UKPC parking "not within bay"
Post by: danvic on November 19, 2023, 09:51:11 am
I received this email back on Friday :

Good day,

We can confirm that all our notices comply with the Protection of Freedoms act and this was all served to the address that the letter of claim was issued to. So we kindly request for evidence that this has not been complied with.

In the meantime, please see attached all notices issued to you in relation to this charge, and we also wish to bring to your attention that the time to appeal this charge has unfortunately expired.

We therefore reject your denials and please refer to the letter of claim within your possession for next steps.



UKPC Litigation Team
Title: Re: UKPC parking "not within bay"
Post by: danvic on November 13, 2023, 12:07:29 pm
Perfect, thanks so much
Title: Re: UKPC parking "not within bay"
Post by: DWMB2 on November 13, 2023, 11:59:52 am
No - quite the opposite, you want to be able to show the court you contacted UKPC and tried to resolve the matter.
Title: Re: UKPC parking "not within bay"
Post by: danvic on November 13, 2023, 11:53:38 am
 Do I need to preface the email/letter to them with "WITHOUT PREJUDICE" or not necessary?
Title: Re: UKPC parking "not within bay"
Post by: danvic on November 12, 2023, 11:54:15 am
Thankyou everyone. Really appreciate your assistance. I'll give it a shot!
Title: Re: UKPC parking "not within bay"
Post by: H C Andersen on November 11, 2023, 04:18:08 pm

 :)
Title: Re: UKPC parking "not within bay"
Post by: DWMB2 on November 11, 2023, 11:14:39 am
For clarity HC, part of the reason I was adding in the point about it being impossible for the company to be driving was to counter any of the "We assume the keeper/hirer was driving" nonsense that is often spouted.

Of course it should be obvious that to the parking company, but when do they ever read appeals thoroughly...?  ;D
Title: Re: UKPC parking "not within bay"
Post by: H C Andersen on November 11, 2023, 11:03:36 am

OP, for information who was driving isn't the issue so in truth that part of the draft could be omitted. However, as this would disturb the flow I'd leave it in.

As regards PoFA, the buck stops with the hirer, there is no option to name drivers or whatever, that horse doesn't even get to the starting gate.
Title: Re: UKPC parking "not within bay"
Post by: DWMB2 on November 10, 2023, 04:13:09 pm
In which case something along the lines of the above could be an option.
Title: Re: UKPC parking "not within bay"
Post by: danvic on November 10, 2023, 02:04:35 pm
Thankyou. They did NOT provide any of those documents to us.
Title: Re: UKPC parking "not within bay"
Post by: DWMB2 on November 10, 2023, 01:56:55 pm
When you received that notice [direct from UKPC], was there anything else sent alongside it, in particular:
  • a statement signed by or on behalf of the vehicle-hire firm to the effect that at the material time the vehicle was hired to a named person under a hire agreement;
  • a copy of the hire agreement; and
  • a copy of a statement of liability signed by the hirer under that hire agreement.
Are you able to confirm the above?

If they did not send the additional documents mentioned above, then they have failed to comply with the requirements of Schedule 4 of the Protection of Freedoms Act 2012 (PoFA) (there's a link in my signature at the bottom of each of my posts), and as such they are unable to recover the charge from you as the hirer.

I think PoFA is probably your strongest defence - looking at the photo of the car, it does appear to be straddling two bays, so probably 'bang to rights' in terms of the actual contravention alleged.

As you haven't replied to any correspondence so far you'd be wise to reply to the Letter of Claim to set out your position. Here's a starter for 10, others can chip in if they wish:

Dear Sirs,

We have received your Letter of Claim (UKPC Litigation Reference Number: ________), relating to a Notice of Parking Charge (NoPC) in which you allege that the driver of the vehicle registration mark _______ became liable for a parking charge, that currently remains outstanding.  We, [COMPANY NAME], are the hirers of this vehicle. As a body corporate, we cannot have been driving. At the time of the parking event, the vehicle was not being used for business purposes, or otherwise in connection with our business. This matter therefore concerns whether the charge is recoverable from us as the vehicle's hirer.

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

  • A failure to serve a Notice to Hirer containing all the information required by 14(5) of the Act.
  • A failure to include alongside the Notice to Hirer the additional documents mentioned by 13(2) of the Act.
We therefore deny that you are able to recover this charge from us as the hirer of the vehicle. We trust that this correspondence resolves the matter, and look forward to your confirmation that no further action will be taken in respect of this. If you choose to proceed with a claim, we intend to defend this thoroughly.

Yours
[COMPANY NAME]
Title: Re: UKPC parking "not within bay"
Post by: danvic on November 10, 2023, 12:59:45 pm
Thankyou. I've attached scans of the initial letter that was merely forwarded to our company from the lease company, the next letter that then came directly from UKPC and the follow-on.    Hope that helps.  In this instance the car was driven for personal purposes.

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Title: Re: UKPC parking "not within bay"
Post by: DWMB2 on November 10, 2023, 11:16:40 am
Thanks. What's done is done, and we can't change that, but for future reference in case you are unfortunate enough to receive another charge in the future:

Looking at this charge - it would be useful if you could show us a copy of the Notice to Hirer that you received (i.e. the first notice from UKPC that was addressed to your company and not the lease company). When you received that notice, was there anything else sent alongside it, in particular:

A last question on the incident itself - was the vehicle being driven on company business?

Another interesting phenomenon to be aware of - in recent months (well, over a year now), there have been quite a high number of instances of UKPC appearing to essentially play 'chicken' with the court process, issuing claims, waiting until a hearing date is given etc., and then discontinuing at the last minute. There's a thread about it here: (https://forums.moneysavingexpert.com/discussion/6377263/dcb-legal-record-of-private-parking-court-claim-discontinuations/ (https://forums.moneysavingexpert.com/discussion/6377263/dcb-legal-record-of-private-parking-court-claim-discontinuations/p1)). There's no guarantee this will happen, and you should proceed on the assumption that you will have to go to court, but it's something to be aware of. One final point to be aware of, as it is the company being sued, then if a hearing does take place it may well be in a court of UKPC's choosing rather than yours, so you may have to travel.
Title: Re: UKPC parking "not within bay"
Post by: danvic on November 10, 2023, 10:56:48 am
Limited Co
Title: Re: UKPC parking "not within bay"
Post by: DWMB2 on November 10, 2023, 10:43:17 am
the first notice was sent to the leasing company who then advised UKPC to send it to our business.
Before we provide any more detailed advice, to ensure we're doing so on the right lines - is the Letter of Claim issued to a limited company, or you as an individual?
Title: UKPC parking "not within bay"
Post by: danvic on November 10, 2023, 09:51:20 am
I was parked in a free-to-park retail park while visiting one of the stores there and my car was slightly out of one of the marked bays and then received a ticket from UKPC with a fine.  I have thus far ignored their letters and having not heard anything for a few months thought they had given up. Now received a "pre-action protocol for debt claims".   NB it's a lease car so the first notice was sent to the leasing company who then advised UKPC to send it to our business.
 I'd be very grateful for any advice.
many thanks

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