Free Traffic Legal Advice
Live cases legal advice => Private parking tickets => Topic started by: Snapp1e on December 24, 2025, 04:52:57 pm
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It was just lucky that I remembered the subject had come up before and was able to find it. Glad it helped.
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jfollows
you saved the day for my appeal submission = big thank you for sending me the way around copying and pasting into IAS text boxes.
I took your technical info to a neighbour who sorted it out so that I could copy and paste my response to IAS. I did submit it in the end but not as Arbitration, I sent it as a response to the operator. There are reasons why = because of very unclear process. That just means there is another 8 days to wait and if the UKCPS does not reply it will automatically go to adjudication.
I was able to have a second chance to submit after an unsuccessful attempt because my message to IAS Enquiries about not having submitted my response, resulted in them re-setting my portal to allow me to submit. They even added on the day I lost and extended my deadline by a day. They did this because I was still in the deadline timescale and had a day left.
That is a good tip for appellants: aim to reply 2 days earlier than the given deadline in case you encounter technical issues and unclear submission information. If you have issue go to Enquiries and ask there.
I have not had an easy time in getting the second attempt response in. In fact, it has been awful and taken far too much time.
I ended up writing a complaint to the IAS about their unclear instructions on their online portal at the point of seeking arbitration. Whether I was partly wrong or not, it was my experience and I have certainly highlighted some inaccuracies and unclear messages from them. To ensure my complaint reached the IAS, I uploaded it as an evidence document because I could not copy and paste my complaint in to their Enquiries text bod (my neighbour had already changed back my settings and their portal did not allow copy and paste again). By default, this also means that my complaint has been sent to the UKCPS because it is an evidence document. My complaint to the IAS below:
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COMPLAINT for the IAS:
the IAS online process for Appeals is not user-friendly and creates barriers for the Appellant at the point of seeking Arbitration.
1. It does not allow the user to copy and paste text in response box without changing their technical set up.
2. The comment box states 'Response to operator'. Underneath are 2 options of where to send comment: 1/ "Submit response"; 2/ "Refer the case straight to Arbitration".
I wish to give a comment for Arbitration, not to the operator. There is NO text box with a title 'Response for Arbitration'. Logically the appellant would press 'Refer the case straight to Arbitration' to insert their comment.
3. If the appellant clicks 'Refer the case straight to Arbitration' then a warning box pops up. The instructions refer to using the comment box and evidence upload on the previous screen (a box titled: 'Response to operator') without being clear enough for those seeking Arbitration. This is confusing for those seeking to give a response for Arbitration.
4. There are words missing in the warning box "...you must GO BACK and submit your these within your response". This does not make sense.
5. The appellant has no idea if putting their comment in the 'Response to operator' box will successfully send their comment for Arbitration. For this reason, to cover my back, I have uploaded a copy of my Appeal for Arbitration as an Evidence document.
6. If the Appellant continues past the warning pop-up message, still expecting to find a comment box for Arbitration, then they discover that there is none. Instead, their request to seek Arbitration is logged without the appellant submitting their response. There is no way to rememdy this from the appellants live case. This happened to me and I contacted IAS through their Enquiries stating I had misunderstood their instructions and had not submitted my response for Arbitration, I provided my response for Arbitration. They replied to say they were unable to accept my response in Enquiries and they re-instated some time for me to reply through the portal because I was still within the deadline. This would have been helpful if the process was clear thereafter, it has not been.
7. On trying to submit my response for Arbitration AGAIN, I have encountered the above issues and have had to resort to uploading my Appeal as an evidence document due to unclear process.
8. If I click 'Submit response' (instead of Refer straight to Arbitration), because I have no choice but to use the 'Response to operator' box, then it does not work and gives me a screen error [2314130.220997]. I tried again and it did work. I changed my strategy of seeking Arbitration and clicked Submit response (to operator) given the unclear process. This means that the only option I have is to insert my comment in the 'Response to operator box'; upload my response for Arbitration as an evidence document as a back-up; click 'Refer the case straight to Arbitration'; ignore the warning box and click Submit.
Please respond to my complaint. I have also sent this complaint to IAS Enquiries.
Also uploaded: screenshot of Warning pop-up box when 'Refer the case straight to arbitration' is clicked. It has missing words and does not make sense.
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***MY ERROR IN ABOVE COMPLAINT***
In the end I clicked RESPONSE TO OPERATOR & UPLOADED my complaint to IAS via the Evidence route.
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Now I have 8 days to wait for a response from the UKCPS. If they do not, it will go straight to arbitration.
At least I got there in the end. All words for my appeal were kindly provided from InterCity 125 and advice from jfollows and others.
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Previously noted on the forum: https://www.ftla.uk/private-parking-tickets/private-estate/msg102156/#msg102156
The IAS deliberately blocks normal pasting into its response box using JavaScript. This is not a technical glitch; it is done to frustrate appellants and prevent structured rebuttals. It can be bypassed easily if you know how.
The most reliable method is to disable JavaScript for the IAS page. In Chrome, open the IAS appeal page, click the padlock icon in the address bar, go to Site settings, change JavaScript to Blocked, then refresh the page. Once the page reloads, the text box will accept pasted text normally. You can paste your prepared response in full and submit it. JavaScript can be re-enabled afterwards if you wish.
If you do not want to disable JavaScript, you can paste directly into the response box using the browser’s developer tools. Right-click anywhere on the IAS page and select Inspect. In the developer panel, locate the <textarea> element that corresponds to the response box. Click inside the <textarea> content in the code view and paste your prepared text there. Close the developer panel and submit. This bypasses all front-end restrictions.
In some browsers, the IAS blocks standard paste but still allows “paste without formatting”. Try using Ctrl+Shift+V (or Cmd+Shift+V on a Mac). This occasionally works depending on browser version and IAS updates.
If all else fails, paste the text into a plain text editor such as Notepad or TextEdit set to plain text, then copy and paste the response into the IAS box in smaller chunks. Starting to type a few characters manually before pasting often defeats the script trigger. This method is slower but works.
Always keep a saved copy of your full response before submitting. After pasting, scroll through the text box carefully to confirm that nothing has been truncated. Do not refresh the page after pasting unless you have confirmed the text is safely stored elsewhere.
These steps are sufficient to defeat the IAS paste restriction and allow the full rebuttal to be submitted exactly as written.
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There is an Enquiry tab. I am presently trying to send in my Appeal that way. Again the box DOES NOT ALLOW A COPY AND PASTE. A barrier for users for sure. I am trying to at least submit it this way so I have evidence for the CCJ (just in case it gets that far). I have no idea of word length yet. They should not be so harsh with User error. I am still in the deadline.
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I've cocked up submitting the appeal to IAS Arbitration. I have submitted an empty page in error.
I misunderstood the online instruction. I had not realised there was only one comment box for both reply to operator and submit to Arbitration.
I was also distracted. A yellow banner said the site had intermittent outages on Monday evening (when I submitted it) thru to Tuesday. I was wondering if my appeal might get lost. Then when I tried to use the comment box I found out it would not accept copy and paste, so I was thinking how could I read my statement and type it in at the same time. Then I misread the instruction and thought the comments box was only for reply to operator. So I pressed to Arbitration expecting to go to a screen to complete my appeal, but sadly I had pressed 'submit appeal' and there was no way of undoing it. I did not receive an email confirmation of submission from IAS which seemed strange. I still had a day until the deadline, so I have just tried to do it again now, but it is locked to further actions and states - Awaiting Adjudication.
I'm fed up about the time spent on this by advisors on here and the help my family and friends gave me. And now I don't have a chance to send it in. Sorry to everyone who helped.
What will it mean now?
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It doesn't look like ANPR, more like stills taken from a video CCTV feed. But that's not of much importance either way.
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Thanks Intercity
I will add that to the statement you kindly gave me before. Just the point I was wanting to make = brill.
The change to "non-ANPR" isn't important then? I thought they would have changed it to ANPR - I must not be understanding it properly.
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No contract was entered into as the Consumer Rights Act (2015) Schedule 2 Paragraph 10 states that, "A term which has the object or effect of irrevocably binding the consumer to terms with which the consumer has had no real opportunity of becoming acquainted before the conclusion of the contract" is to be regarded as an unfair term.
In this instance the operators claim of what amounts to an 'instant contract' breaches the aforementioned paragraph of the Consumer Rights Act (2015) and is therefore an unenforceable term.
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IF the 5 minutes grace period was added to my appeal, would mentioning the stop was for 5 seconds also?Ive learned not to include things that given them ammunition to latch on to and dismiss my main points of law, so perhaps not.
I'm thinking further ahead if they did go to CCJ and a copy of my Appeal was made available.
I hear what you say Intercity about the IAS will never disagree with their members that a vehicle wasn't stopped/parked. Their UKCPS focus on the automatic contract is their only arguement.
I would like to add something specifically about the Contract, if that seems wise.
Sorry, I'm not able to fill in the blank here.
Please can someone give me the words for the EVEN / IF:
"No contract was entered into because ______, even if a contract was entered into, it is denied that the keeper is liable"
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Cool for IAS. I'm pretty sure a court would see a distinction if it got that far. However, if they want to consider that stopping is parking, then their code of practice mandates a 5 minute consideration period for drivers to read and accept the signs.
Can't have it both ways - either the consideration period doesn't apply because there's a distinction between stopping and parking (in which case PoFA doesn't apply either), or parking and stopping are the same thing, in which case the consideration period must be honoured.
Or, the Code of Practice is modified and special wording is introduced which creates the concept of 'instant automatic contracts' in situations where parking operators would find it 'inconvenient' to allow drivers a period of consideration.
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Cool for IAS. I'm pretty sure a court would see a distinction if it got that far. However, if they want to consider that stopping is parking, then their code of practice mandates a 5 minute consideration period for drivers to read and accept the signs.
Can't have it both ways - either the consideration period doesn't apply because there's a distinction between stopping and parking (in which case PoFA doesn't apply either), or parking and stopping are the same thing, in which case the consideration period must be honoured.
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I realise I'm late to the party, but it seems to me that the question of relevant land for PoFA doesn't even arise, because PoFA applies to Parking, and there is no dispute that OP did not in fact park. Unless I'm missing something, PoFA does not apply to "Stopping"
IAS conveniently (for their members) turn the mere act of stopping into 'parking' on the basis that anything other than moving represents parking.
Of course IAS do this as IAS are actually part of the larger fraud and their job is to persuade PCN recipients into paying - they are not an 'independent appeals service' as they state.
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Whilst you're not wrong, IAS are never going to agree with the 'stopping' point, so for the IAS at least, focusing on the PoFA issue is sensible. It's also always worth mentioning as an "even if" point - i.e. "No contract was entered into because ______, even if a contract was entered into, it is denied that the keeper is liable".
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I realise I'm late to the party, but it seems to me that the question of relevant land for PoFA doesn't even arise, because PoFA applies to Parking, and there is no dispute that OP did not in fact park. Unless I'm missing something, PoFA does not apply to "Stopping"
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Hi,
I have received advice from one person on here and I am grateful to Intercity125.
I had added some queries and they haven't been answered.
I am assuming that other advisers agree that the reply I have received from Intercity125 covers all important bits and I'm good to go and submit it this evening.
I don't know if its usual behaviour or not for an operator to change the NtK at the stage of IAS appeal, but they have changed their claim (this is good news for me).
I also do not understand the change to "non-ANPR" when they have used ANPR through CCTV photo evidence (have I understood this correctly?). Should my response include something about this?
I know their claim is much more diluted now that they have withdrawn PoFA. Ive read on here a response that the IAS sent to somebody else about signage and the law of Contract in the same location and dismissed their appeal, so I am anticipating a very similar response.
If there was anything that I can add to my appeal to challenge what they will say then the time is today! Or perhaps I already have it covered? This forum has already advised me that IAS is a kangaroo court so perhaps there is nothing else to add to challenge them.
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Partial quote:
kbr1 - no stopping - Leeds city station (November 28, 2025 at 07:08:20pm)
Appeal Outcome: Dismissed
The Adjudicators comments are as follows:
The terms of this appeal are that I am only allowed to consider the charge being appealed and not the circumstances of other drivers or other parking events. The guidance to this appeal also makes it clear that I am bound by the law of contract and can only consider legal challenges not mistakes or extenuating circumstances. I am satisfied that the Operator's signage, which was on display throughout the site and seemingly visible in the vicinity of the vehicle, makes it sufficiently clear that the terms and conditions are in force at all times and that a PCN will be issued to drivers who fail to comply with the terms and conditions, regardless of a driver's reasons for being on site or any mitigating factors. While noting their comments, it is clear from the evidence provided to this appeal that the Appellant did indeed stop otherwise than in accordance with the displayed terms as alleged by the Operator. I am satisfied on the evidence provided that the Operator has the authority to issue and enforce PCNs at this site. I am further satisfied as to the location of the contravention, that the correct vehicle has been identified stopped at the time suggested in the images provided and that the correct Appellant is pursued.
I am satisfied that the Operator has proven their prima facie case. Whilst having some sympathy with the Appellant's circumstances, once liability has been established, only the Operator has the discretion to vary or cancel the parking charge based on mitigating circumstances. Accordingly this appeal is dismissed.
As your appeal has been dismissed, the Independent Adjudicator has found, upon the evidence provided, that the parking charge was lawfully incurred.
Yours Sincerely,
The Independent Appeals Service
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Thanks for reading.
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Hi, I will be submitting to arbitration tomorrow. Thanks to Intercity I have a good statement.
If anybody has anything to add to it, please do.
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I don't think you can submit this.
Comments on the operators evidence can only cover appeal points which have already been made or points which cover the 'changes' which the operator is now trying to make to the NtK.
Other may feel different but I would just make some short simple comments along the lines of;
Comments on operators evidence.
The operator is now changing the nature of the NtK after it was pointed out that the original NtK contained a very serious breach of the operators own Code of Practice - namely; that the original NtK clearly states PoFA Keeper liability when no such liability exists at the location in question.
That the operator is now seeking to circumvent the requirements of PoFA in a desperate attempt to maintain keeper liability in a situation where PoFA cannot apply - the 'reasonable assumption' argument has already been defeated in the Appeal Court - VCS v Edward is the relevant authority in this precise matter - Also, if 'reasonable assumption' could be used in this way then PoFA need not exist - Elliot v Loake has also been mentioned but this is a criminal case and, as such, the case turns on its facts and at no point is 'reasonable assumption' ever mentioned or even implied.
The operator includes a number of pictures from the location but their own evidence shows a further breach of their agreed Code of Practice - Their CoP states that, "Signs and surface markings must be designed, applied and maintained in such a way as to be visible, legible and UNAMBIGUOUS TO DRIVERS." - In this instance the surface markings directly contradict the operators claim that the area is a 'no stopping zone' - the law allows brief stops on double yellow lines - in order to be compliant, double red lines should be used to indicate a no stopping zone - this point is confirmed on the relevant Government website.
The operators behaviour clearly shows the haphazard way that they are running their business - issuing non-compliant NtKs and trying to enforce double yellow lines as if they are double reds are all significant breaches of the CoP.
Many thanks,
xxxxxx xxxxxx
Thank you Intercity125 for such a quick and thoughtful response.
Your kisses brightened up my morning, even though I dont think they were for me, either way it made me smile.
I like your approach and agree that an overall summary of short, simple points is effective in this case because of the changes. Thank you for adding the second caselaw too
When I appealed first time it was short and simple too and the UKCPS response was short because they could not argue with the content.
I'm happy to submit this response to Arbitration but I will wait until the 9th to see if if others have anything to add, and to see if they agree that everything is covered in the statement.
e.g. they have changed tack and are now heavily relying on the the Contract thru their signage and sent me 77 photos. Should the high number of photos be mentioned as being the best they have to offer even though they do the opposite and evidence the point in my appeal, not their claim against the driver who is unidentified?
e.g. they have changed the charge from initial "no stopping" to reason for issue: "the charge is based in Contract".
e.g. I don't really understand the change to non-ANPR now that PoFA has been dropped by them. Should something be said about it? They have used CCTV to capture vehicle registration and have time stamped the photos of the vehicle to 5 seconds.
Many thanks
xxxxxx xxxxxx
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I don't think you can submit this.
Comments on the operators evidence can only cover appeal points which have already been made or points which cover the 'changes' which the operator is now trying to make to the NtK.
Other may feel different but I would just make some short simple comments along the lines of;
Comments on operators evidence.
The operator is now changing the nature of the NtK after it was pointed out that the original NtK contained a very serious breach of the operators own Code of Practice - namely; that the original NtK clearly states PoFA Keeper liability when no such liability exists at the location in question.
That the operator is now seeking to circumvent the requirements of PoFA in a desperate attempt to maintain keeper liability in a situation where PoFA cannot apply - the 'reasonable assumption' argument has already been defeated in the Appeal Court - VCS v Edward is the relevant authority in this precise matter - Also, if 'reasonable assumption' could be used in this way then PoFA need not exist - Elliot v Loake has also been mentioned but this is a criminal case and, as such, the case turns on its facts and at no point is 'reasonable assumption' ever mentioned or even implied.
The operator includes a number of pictures from the location but their own evidence shows a further breach of their agreed Code of Practice - Their CoP states that, "Signs and surface markings must be designed, applied and maintained in such a way as to be visible, legible and UNAMBIGUOUS TO DRIVERS." - In this instance the surface markings directly contradict the operators claim that the area is a 'no stopping zone' - the law allows brief stops on double yellow lines - in order to be compliant, double red lines should be used to indicate a no stopping zone - this point is confirmed on the relevant Government website.
The operators behaviour clearly shows the haphazard way that they are running their business - issuing non-compliant NtKs and trying to enforce double yellow lines as if they are double reds are all significant breaches of the CoP.
Many thanks,
xxxxxx xxxxxx
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ignore the emojis in my draft reply.
i did not insert any emojis. they have appeared when i have done a copy and paste into here.
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DRAFT reply
7-day deadline. I am submitting it on 9th February
Not sure of decision:
Counter-respond to UKCPS: ? (I need to ensure assessor in appeal)
To IAS Arbitration: ? (I need to ensure adjudicator in appeal)
Guessing it is Arbitration - please confirm.
I might use NtK and CPN wrongly...
Lots of wording and layout taken from b789 previous posts to other cases. I hope we haven't used wording not relevant to my case.
This draft has taken 12 hours with 3 people involved!
Dear IAS Adjudicator,
I am the registered keeper of vehicle [XXXX] and wish to appeal the Parking Charge Notice (PCN) issued by UKCPS based on the following seven grounds:
1. The operator has now changed the PCN because it was not PoFA compliant.
2. The operator has failed to deliver a Notice To Keeper that is PoFA compliant.
3. The operator has not shown that the individual who it is pursuing is in fact the driver.
4. New claims? (non-ANPR, the charge is based in Contract)
5. Signage and the claim that the charge is based on Contract.
6. No evidence of Landowner Authority - the operator is put to strict proof of full compliance with the IPC Code of Practice. ???
7. Shambolic operator in breach of Code of Practice of IPS and DVLA.
1.
UKCPS has changed the PCN since the appellant submitted their appeal to the IAS:
from: PCN: "Notice to Keeper (Postal - PoFA) issued on private land, was sent on 17/12/2025. Reason for issue: no stopping."
to: Prima Facie Case: "The Notice to Keeper (Non-ANPR), was sent on 17/12/2025. The charge is based in Contract."
2.
The Notice to Keeper (NtK) issued by UKCPS fails to comply with the requirements of the Protection of Freedoms Act 2012 (PoFA). UKCPS has already admitted in their correspondence that they are no longer relying on PoFA to establish keeper liability and they have changed their claim. This admission unequivocally confirms that they acknowledge the PCN does not meet the statutory requirements. Therefore, as a matter of law, the operator cannot hold the registered keeper liable for this parking charge. The appeal must be allowed.
UKCPS changed the PCN:
New claim: "Please be advised that this charge was issued under the site's terms and conditions and not under the Protection of Freedoms Act 2012 (PoFA)."
2.1. UKCPS has agreed with my appeal. The definition of 'relevant land' was amended by The Protection of Freedoms Act 2012 (Definition of Relevant Land) (Amendment) Order 2025 to include railway land, and this amendment only came into force on 26th December 2025, and is not retrospective. This alleged parking event took place on 10th December 2025, before the amendment came into force.
3.
UKCPS: "It is a contractual notice directed at the driver of the vehicle for stopping in a prohibited area. Under this framework, liability is assumed to rest with the registered keeper unless evidence is provided to show that they were not the driver".
question - can I say there was no valid contract? does the VCS vs Edward evidence there was no contract or does signage only make the contract?
3.1. There is no evidence the Keeper was the driver – Keeper Cannot Be Held Liable.
(I found this from b789 for a different case, I have to be cautious because their case involved a parking metre, different to my case)
UKCPS has provided not provided any evidence whatsoever that the appellant was the driver at the time of the alleged contravention. The appeal made it clear that the identity of the driver has not been disclosed, and UKCPS has not disputed this or provided any evidence to the contrary.
3.2. This leaves the operator with just one legal route: to pursue the registered keeper under Schedule 4 of the Protection of Freedoms Act 2012 (PoFA). However, that mechanism only becomes available if the operator fully complies with every single mandatory condition set out in PoFA. UKCPS has now confirmed that the initial claim was not PoFA compliant, therefore the UKCPS has no legal route to pursue the registered keeper. The appeal must be allowed.
3.3. It is not appropriate to draw an inference that, on balance of probability, the registered keeper was driving on any given occasion. As explained in caselaw VCS v Edward H0KF6C9C [2023], the keeper’s refusal to identify the driver does not permit any assumption of driver identity. With PoFA compliance withdrawn by UKCPS, the only remaining option would be to prove — with actual evidence — that the keeper was also the driver. They have not done so. There is no legal presumption that the keeper was the driver. UKCPS has made no attempt to rebut this point, nor have they presented any evidence to support such an inference. The appeal must be allowed.
3.4. The UKCPS assessor who is supposedly legally qualified, should have considered, if such an assumption could be made that liability is assumed to rest with the registered keeper, why does PoFA exist?
3.5. If the owners of the land, Leeds Station, wanted to hold owners or keepers liable under Railway Bylaws, that would be within the landowner's gift and another matter entirely. However, not only is that not pleaded, it is also not legally possible because UKCPS is not the station owner and the UKCPS 'parking charge' is not and never attempts to be a penalty. The appeal must be allowed.
3.6. IAS is not entitled to make assumptions in the operator’s favour, nor is it permitted to apply a lower evidential threshold than the law requires. Keeper liability only arises if PoFA is complied with. It is not a default position, and it does not arise by implication. Accordingly, the only lawful conclusion is that UKCPS cannot pursue the appellant as keeper. There is no PoFA compliance, no driver identification, and therefore no legal basis for continuing enforcement of this charge. The appeal must be allowed.
4.
UKCPS has changed the NtK - "The Notice to Keeper (Non-ANPR)"
(Note: I don't know what to say about this? Do I need to say something?
I found some sentences from b789 on a different case involving "paying for parking" (different claim), but it applies to ANPR, not "non-ANPR)
(is this relevant here? I did not mention this in my appeal):
(found a quote from b789: 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). is that the wrong CoP, should it be IPS?
5.
UKCPS claim: "The charge was issued correctly in accordance with site regulations and the IPC Code of Practice and remains valid and enforceable".
5.1. Signage and the claim that the charge is based on Contract.
The IAS assessor must consider that the initial claim of 'No Stopping' and the new claim of "the charge is based in Contract, a contractual notice directed at the driver of the vehicle for stopping in a prohibited area" are not supported by the road markings which is in direct contravention of the IPC Code of Practice which specifically states:
"Signs and surface markings must be designed, applied and maintained in such a way as to be visible, legible and UNAMBIGUOUS TO DRIVERS."
The charge has not been issued correctly, it is not valid and it is not enforceable. The appeal must be allowed.
(Note: For a driver to have agreed to any contractual terms, the signage must have been legible, prominently positioned, and capable of being read before entering into a contract = I have left this out???)
5.2. The IAS assessor must consider the contradictory signage/ road markings. The driver is stopped briefly on double yellow lines which the law allows - only double reds can mean no stopping. The appeal must be allowed.
5.3. The CPN is created for UKCPS’s own profit (as opposed to a bylaw's penalty that goes to the public purse) and UKCPS has relied on contract law allegations of breach against the driver only.
6.
No evidence of Landowner Authority - the operator is to provide strict proof of full compliance with the IPC Code of Practice. ???
Flawed Assumption Regarding Signage and Landowner Authority ???
6.1. The operator has provided an undated site plan, the date of July 2025 is in the file name only which can be changed at the users' discretion. (Valid?)
(Note: all wording provided by b789 in another case with edits relevant to evidence provided to me. I do not know how much of this (if any) applies to me? I did not cover signage in my appeal, but since then the PCN has changed substantially and is more focused on the Contract now. All the evidence photos submitted by UKCPS to me for my appeal are dated 24/07/2025 and 27/07/2025. Is this timescale relevant? Because I am raising signage now, do I need to return to the UKCPS (not arbitration?)
6.2. They have provided signage templates and in location photographs of signage all digitally dated 25th and 27th July 2025, but no photographs showing how the signs actually appeared on-site at or around the date of the alleged contravention on 10th December 2025.
6.3. There is no evidence the signage was present, visible, or reflected any landowner-approved terms at that time.
(Note: there is no signage in the photos of my vehicle. They have sent me many generic photos of locations with signage and I do not know how close signage was to my vehicle).
6.4. They have not shown that the signage was authorised by the landowner, nor that it matched any valid, current agreement. A layout plan that is not dated on the template and file images of signs for a different time period, prove nothing in isolation.
6.5. It is inappropriate for IAS to assume that signage is valid or authorised simply because it exists. Contracts often remain static while terms change — such as grace periods, charge levels, or maximum stay durations — and if the signage was updated without a revised landowner agreement, then the operator is enforcing terms never approved. The appeal must be allowed.
7.
Shambolic operator in breach of Codes of Practice
7.1. By sending me an initial NtK which states PoFA, keeper liability is unlawful in situations where PoFA cannot apply, this is clearly evidence of UKCPS having haphazard methods of running their enforcement operations at this site. It is totally unprofessional and a breach of their Code of Practice. The appeal must be allowed.
7.2. The NtK is not supported by the road markings of yellow double lines which is in direct contravention of the IPC Code of Practice.
7.3. Further evidence of unprofessionalism and breach of UKCPS: UKCPS has contradicted the DVLA Code of Practice. The IAS assessor must consider that operators are not allowed to claim that they can rely on PoFA in situations where they can not when making requests to the DVLA for the registered keeper's details. In this case, a parking contravention has not occurred.
question - can I say lack of "reasonable cause" to contact the DVLA?
question - and requesting data when no contract was formed?
question - can they be reported?
8.
In short, I dispute this charge in its entirety, primarily based on the operator not showing that the individual who it is pursuing is in fact the driver. I require full evidence of compliance with the law, industry codes of practice, and basic contractual principles. (question - is this point only valid for the UKCPS or is it ok for arbitration?)
If the assessor chooses to overlook these legal requirements and accept vague assertions about no stopping violations and unhelpful dated photographs from the operator, then this will lend further weight to the growing concern that this appeals service is neither independent nor genuinely legally qualified. An erroneous and non valid NtK was issued to me and this case now needs to stop.
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The End
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There must be a lot to correct and improve on this draft. I hope someone can help.
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Is this point correct?:
The operator can only approach the DVLA for a registered keeper's vehicle registration and name and address IF a parking contravention has occurred on relevant land.
Not quite - they're allowed to request keeper details on land that isn't relevant land, what they're not allowed to do is claim that they can rely on PoFA in situations where they cannot.
The "if" would relate to if a parking contravention has occurred. In this case there's a fair argument that one hasn't
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Intercity
My friend and I are digesting your info. Thanks for your time.
Quote: "Point out that sending an NtK which states PoFA keeper liability is unlawful in situations where PoFA cannot apply - point out their clearly haphazard methods of running their enforcement operations at this site - totally unprofessional and a breach of their Code of Practice".
Is this point correct?:
The operator can only approach the DVLA for a registered keeper's vehicle registration and name and address IF a parking contravention has occurred on relevant land.
If so, is the UKCPS also in breach of DVLA of .... (I dont know the right words).
Is this relevant to put in my response?
Are you advising I go straight to arbitration now?
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I am cobbling a draft and will put it on here for feedback. I'll try and get it done for tomorrow.
It's good to know from jfollows that by dropping the PoFA they have agreed to my appeal in law, even though they will not say that.
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Research VCS v Edward - this should allow you to disprove their assertion that liability is automatically passed to the keeper. Also, if such an assumption could be made, why does PoFA exist??
Point out that sending an NtK which states PoFA keeper liability is unlawful in situations where PoFA cannot apply - point out their clearly haphazard methods of running their enforcement operations at this site - totally unprofessional and a breach of their Code of Practice.
Draw the assessors attention to the contradictory signage / markings - you are stopped briefly on double yellow lines which the law allows - only double reds can mean no stopping. Claims of 'No Stopping' are not supported by the road markings which is in direct contravention of the Code of Practice which specifically states, "Signs and surface markings must be designed, applied and maintained in such a way as to be visible, legible and UNAMBIGUOUS TO DRIVERS."
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The UKCPS finish their evidence by stating:
"The charge was issued correctly in accordance with site regulations and the IPC Code of Practice and remains valid and enforceable."
The UKCPS has not dropped the charge.
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Hi Jfollows
thanks for your reply.
I'm coming to this from knowing nothing as you can see. I seem to have totally misunderstood their reply regarding PoFA and non-ANPR.
Yes it is non-ANPR - see the copy and pasted wording for Notice to Keeper. It is now different.
So you're saying it's good news?
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You’re still trying to make this too complicated.
Your appeal stated that they could not use PoFA to transfer liability to you.
They now confirm to the IAS that you were correct, so should have upheld your appeal initially, and the IAS should also uphold your appeal.
You also need to rubbish their statement “liability is assumed to rest with the registered keeper unless evidence is provided to show that they were not the driver”. Liability rests with the driver, and can only be transferred to the registered keeper if the provisions of PoFA are all followed, which in this case they can not be and UKCPS has admitted this.
When you say “Non-ANPR” is that correct, or did you mean “Non-PoFA”?
PoFA is completely relevant, and since they now admit they’re not using its provisions (as they couldn’t, anyway, but they originally claimed they could) they can’t transfer liability to you, the registered keeper, which is what you said at the start.
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hi!
Did you see this coming?!!
1.
I have got the reply from UKCPS to the IAS.
UKCPS has now changed my charge notice!!
I was issued with: Notice to Keeper (Postal - PoFA) Issued on private land
They have now told the IAS the charge is not under the Protection of Freedoms Act 2012 (PoFA)! They have changed it to: The Notice to Keeper (Non-ANPR)
Does this mean they are using the change of Law from 26th December 2026?
UKCPS has correctly stated the NtK was issued on 10/12/2026
Well, well, well...!! BLATANT LYING.
I'm FUMING AND LAUGHING AT THE SAME TIME. >:( ;D
Copy and pasted (see this screen shot in the link below)
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The operator made their Prima Facie Case on 04/02/2026 14:02:13.
The operator reported that...
The appellant was the keeper.
The Notice to Keeper (Non-ANPR) was sent on 17/12/2025.
The ticket was issued on 10/12/2025.
The charge is based in Contract.
The operator made the following comments...
Please be advised that this charge was issued under the site's terms and conditions and not under the Protection of Freedoms Act 2012 (PoFA). It is a contractual notice directed at the driver of the vehicle for stopping in a prohibited area. Under this framework, liability is assumed to rest with the registered keeper unless evidence is provided to show that they were not the driver.
The charge was issued correctly in accordance with site regulations and the IPC Code of Practice and remains valid and enforceable.
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https://ibb.co/7NJdkCMT Email from IAS side 1 with instructions
https://ibb.co/Gvwx0Jy5 Email from IAS side 2 with instructions
https://ibb.co/JRy2nzHq IAS - UKCPS Prima Facie response
2.
UKCPS has also responded with 'more evidence' to the IAS with their Leeds Station Site Images. A total of 77 additional photos all taken on 25/07/2025 (not on the day or month of the charge sent to me). I have saved these in 42 screen shot images. The photos cover: station map of site, signage in various locations, various vehicles parked next to signs or in stopping areas. For obvious reason, I have not uploaded these images, many random. People on here already know the signage across the site.
3.
Please, please advise me on wording for a reply.
A. Jfollows advised above to give a response if they do not respond to the PoFA. Now they're saying PoFA isn't relevant.
If this option is advised in preparation for sending to adjudication please ley me know and please help with the response.
B. Or, I could go straight to arbitration. How can IAS arbitration agree with a change in Law in the Ntk charge? Surely if the IAS do not drop this charge now, they are also breaking the Law?
I know this isn't relevant, but I like to say it. The UKCPS photo evidence shows that the vehicle was stopped for 5 seconds only and nobody got in our out of the vehicle.
I'm looking forward to reading your responses for my next steps. Thanks!
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If their evidence is all about what the driver did, and does not respond to the PoFA main point, then you should respond to the effect that by not responding they accept the point and therefore the stuff about the driver is irrelevant. But that’s only a guess for now - the common tactic we’ve already seen is to ignore things that go against them.
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Here are the screenshots for my confirmation of my appeal submission to the IAS.
It's the same info I sent in my appeal to the UKCPS.
https://ibb.co/HTdBT07d = page 1
https://ibb.co/PGYYFTbr = page 2
Ive read on here that it will cost UKCPS Ł23 now. :)
I'll come back here when I receive a response.
There will be 2 options for me at that point:
1. to reply to their evidence.
2. refer straight to arbitration.
I assume I will chose option 2 because I have no further evidence to upload and I have nothing else to say to them, except for the double yellow lines which I did not mention.
I wonder how many'no stopping' charges are sent out for Leeds Station on a daily basis?
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I've been reading reports about the Litter Enforcement scams where pedestrians, and some motorists, are being accosted on the streets and told to pay an immediate fine. One lady who was walking her dog was told to show she had poo bags otherwise she would be fined. It was a short walk, her dog has already done its business, and she didn't have any bags. A passer-by intervened and told her the 'officer' had no powers. The scam reminded me of this parking charge scam (private land and no jurisdiction) and that the helpfulness of kind and savvy people really does help people.
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Thanks Intercity
I have sent in the appeal now. From what I understand, whatever I write wont stop the charge but it's good to have your point noted in case it progresses to the SCC.
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Also, the vehicle is stopped on double yellow lines which is not a 'no stopping' restriction.
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Thank you jfollows.
I will follow your advice. I want to do the best and keep it to the point.
Thank you for correcting to IPS.
I'm going to send it off now.
I really appreciate your help with this.
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As I’ve already said, I would remove all the stuff about the driver, because otherwise the IAS will latch on to it and use it against you as a reason for denying your appeal. But take input from others as well first.
And it’s neither IPS or IPA, it’s the IAS, the supposed - but not - Independent Appeals Service.
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Draft 2 Appeal to the IPS -
thanks for earlier comments to help me do a good appeal.
I don't need to include the last bit about the driver's actions, it just boils my blood, but I could remove those points about the driver...
To IPS
Appeal against PCN from UPCPS - Notice to Keeper (Postal - PoFA) issued on private land
Reason for issue: no stopping
Name and address of site: Leeds City Station, LS1 4DY
UKCPS sent me a Parking Charge Notice letter dated 17th December 2025 with photos relating to 5th December 2025. They had used the vehicle registration number and requested the registered keeper's name and address details from the DVLA.
I am the registered keeper of the vehicle. I have not confirmed to UKCPS who the driver was at that time on that date.
I submitted an appeal to UKCPS on 27/12/2025 via their website. Here is a copy of my appeal to UKCPS:
APPEAL TO UKCPS:
I am the registered keeper. UKCPS cannot hold a registered keeper liable for any alleged contravention on land that is under statutory control (until 26 December 2025). As a matter of fact and law, UKCPS will be well aware that they cannot use the PoFA provisions because Leeds Station is not 'relevant land'.
If Leeds Station wanted to hold owners or keepers liable under Railway Bylaws, that would be within the landowner's gift and another matter entirely. However, not only is that not pleaded, it is also not legally possible because UKCPS is not the station owner and your 'parking charge' is not and never attempts to be a penalty. It is created for UKCPS’s own profit (as opposed to a byelaw's penalty that goes to the public purse) and UKCPS has relied on contract law allegations of breach against the driver only.
The registered keeper cannot be presumed or inferred to have been the driver, nor pursued under some twisted interpretation of the law of agency. Your Notice to Keeper can only hold the driver liable. UKCPS have no hope should you try to litigate, so you are urged to save us both a complete waste of time and cancel the PCN.
Your photo evidence showed a stop of 5 seconds only where the vehicle car door remained closed.
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UKCPS replied to me on 20th January 2026 by email saying my appeal to them was unsuccessful in their opinion.
I request that the IPS considers this appeal based on the following:
1/ UKCPS cannot hold a registered keeper liable for any alleged contravention on land that is under statutory control (until 26 December 2025).
2/ As a matter of fact and law, UKCPS cannot use the PoFA provisions because Leeds Station is not 'relevant land'.
3/ If Leeds Station wanted to hold owners or keepers liable under Railway Bylaws, that would be within the landowner's gift and another matter entirely. However, not only is that not pleaded, it is also not legally possible because UKCPS is not the station owner and the UKCPS 'parking charge' is not and never attempts to be a penalty.
4/ The CPN is created for UKCPS’s own profit (as opposed to a bylaw's penalty that goes to the public purse) and UKCPS has relied on contract law allegations of breach against the driver only.
5/ The registered keeper cannot be presumed or inferred to have been the driver, nor pursued under some twisted interpretation of the law of agency.
6/ The UKCPS Notice to Keeper can only hold the driver liable.
7/ UKCPS has not been notified of the driver's identity.
Noteworthy to show how ridiculous the UKCPS parameters are:
a) The vehicles was stopped for 5 seconds only as shown in the UKCPS photo evidence (4 photos).
b) The vehicle was not purposefully stopped or waiting.
c) The car doors remained closed.
d) The UKCPS photos show there were no people outside of the vehicle intending to get in. It is an empty road and pavement for the duration of the 5 seconds.
e) The first photo shows the engine lights are on. The photo showing it at 5 seconds after shows the engine lights are off. It appears plausible that the vehicle stalled the engine and had to restart the power.
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oh yes youre right.
I had mentioned them further up in the letter but I will add them to the bottom as the more important points. Thank you.
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Why have you moved away from your appeal point, which is that it’s irrelevant what the driver did or did not do, you as registered keeper can not be liable for the driver’s actions?
If you give the IAS all these points about the driver, they’ll reject the appeal based on them.
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Their privacy policy should explain what they do with data provided, but I've never heard of anyone receiving a phone call from the IAS.
You do not need to provide a copy of the PCN or anything from the operator. It is for the operator to prove their case, so it is for them to provide the PCN.
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To IPS
Appeal against PCN from UPCPS - Notice to Keeper (Postal - PoFA) issued on private land
Reason for issue: no stopping
Name and address of site: Leeds City Station, LS1 4DY
UKCPS sent me a Parking Charge Notice letter dated 17th December 2025 with photos relating to 5th December 2025. They had used the vehicle registration number and requested the registered keeper's name and address details from the DVLA.
I am the registered keeper of the vehicle. I have not confirmed to UKCPS who the driver was at that time on that date.
I submitted an appeal to UKCPS on 27/12/2025 via their website. Here is a copy of my appeal to UKCPS:
APPEAL TO UKCPS:
I am the registered keeper. UKCPS cannot hold a registered keeper liable for any alleged contravention on land that is under statutory control (until 26 December 2025). As a matter of fact and law, UKCPS will be well aware that they cannot use the PoFA provisions because Leeds Station is not 'relevant land'.
If Leeds Station wanted to hold owners or keepers liable under Railway Bylaws, that would be within the landowner's gift and another matter entirely. However, not only is that not pleaded, it is also not legally possible because UKCPS is not the station owner and your 'parking charge' is not and never attempts to be a penalty. It is created for UKCPS’s own profit (as opposed to a byelaw's penalty that goes to the public purse) and UKCPS has relied on contract law allegations of breach against the driver only.
The registered keeper cannot be presumed or inferred to have been the driver, nor pursued under some twisted interpretation of the law of agency. Your Notice to Keeper can only hold the driver liable. UKCPS have no hope should you try to litigate, so you are urged to save us both a complete waste of time and cancel the PCN.
Your photo evidence showed a stop of 5 seconds only where the vehicle car door remained closed.
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UKCPS replied to me on 20th January 2026 by email saying my appeal to them was unsuccessful in their opinion.
I request that the IPA looks at the photo evidence to recognise the following:
1/ The vehicles was stopped for 5 seconds only.
2/ The vehicle was not purposefully stopped or waiting.
3/ The car doors remained closed.
4/ The UKCPS photos show there were no people outside of the vehicle intending to get in. It is an empty road and pavement.
5/ The first photo shows the engine lights are on. The photo showing it at 5 seconds after shows the engine lights are off. It appears plausible that the vehicle stalled the engine and had to restart the power.
6/ A 5 second stop is not violating any bylaws on private land.
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The IPS
I have just registered for an account with the IPS. I am not happy it wont let me do it without providing my phone numbers.
Is there any chance they will phone me?
Do they pass on phone numbers to any other person or body?
After registering the IPS explains I have to verify the account through email verification. I then realised my email address was incorrect. I re-registered with my correct email address.
The IPS pop up window said that hotmail users might have an issue with receiving their verification email and I would have to add them to my email safe list then redo the request for a verification email. I have never come across issues with hotmail being singled out for not receiving safe emails before... The IPS gives a link of how to add their email to hotmail safe addresses bu using an Outlook link. Thankfully I am relieved to say that I received the email verification on my hotmail because otherwise this would have been stressful given that I am not IT savvy and have to rope in family and friends to help!
The IPS had also said that I would have now lost my chance to send in my Appeal by post because I had set up the PCN reference number. So if I had not received the email verification, I would be locked out of submitting the Appeal!
So far on the IPS system, I cannot see if I can attach UKCPS letters. Do you know if they already have copy letters through the PCN or it is expected that I upload them?
My draft appeal to the IPS is in my next message here.
If you think any more is needed please let me know. Thanks a million.
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See also https://www.ftla.uk/private-parking-tickets/ukcps-leeds-station-notice-to-keeper-postal-pofa/msg107637/#msg107637
As with the other case, they simply ignored your appeal and sent you an irrelevant response.
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A copy of the UKCPS letter rejecting my appeal. Short response from them.
3 pages:
https://ibb.co/FqKg7xrt = page 1
https://ibb.co/Hc3TJwT = page 2
https://ibb.co/Fqc6tG58 = page 3
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Copied and pasted:
Parking Charge Reference:
Vehicle Registration:
Location: Leeds City Station, LS1 4DY
Issued: 10/12/2025 at 14:54:54
Dear
Thank you for your appeal submitted on 27th December 2025. After reviewing your comments, and carefully considering the evidence collected at the time the Parking Charge was issued, we regret to inform you that your appeal has been unsuccessful.
The reasons for our decision are detailed below:
The area where the vehicle stopped is designated as private land where parking, stopping, or waiting is strictly prohibited at all times.
At the time of the event, the vehicle was parked, stopped or waiting in this area, and as a result, the driver contractually agrees to pay a parking charge.
Attached, you will find photographic evidence showing the vehicle parked at the location mentioned above.
We have extended the opportunity for you to pay the reduced amount of, Ł60.00, until 05/02/2026, after this date, the full amount of Ł100.00 will be due.
Regards,
Appeals Team
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Copy of my Appeal to UKCPS. Submitted through their online link.
2 pages
https://ibb.co/album/MyjW5k
https://ibb.co/album/MyjW5k
Plus a screenshot of their receipt of my Appeal
https://ibb.co/hxtmGPSv
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I used the wording from B789 for my appeal to UKCPS:
I am the registered keeper. UKCPS cannot hold a registered keeper liable for any alleged contravention on land that is under statutory control (until 26 December 2025). As a matter of fact and law, UKCPS will be well aware that they cannot use the PoFA provisions because Leeds Station is not 'relevant land'.
If Leeds Station wanted to hold owners or keepers liable under Railway Bylaws, that would be within the landowner's gift and another matter entirely. However, not only is that not pleaded, it is also not legally possible because UKCPS is not the station owner and your 'parking charge' is not and never attempts to be a penalty. It is created for UKCPS’s own profit (as opposed to a bylaws penalty that goes to the public purse) and UKCPS has relied on contract law allegations of breach against the driver only.
The registered keeper cannot be presumed or inferred to have been the driver, nor pursued under some twisted interpretation of the law of agency. Your NtK can only hold the driver liable. UKCPS have no hope should you try to litigate, so you are urged to save us both a complete waste of time and cancel the PCN.
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The only differences I made was:
- google to abbreviations and write them in full because I didn't understand them.
- state their photo evidence showed a stop of 5 seconds only where the vehicles car doors remain closed.
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Its annoying that I cannot find an actual copy of my appeal for my own records. UKCPS online appeal system doesn't give me access to my appeal now, and their email confirmation of receiving my appeal doesn't include what I wrote. But, as I said, I simply submitted what I was advised to.
Could someone help me with wording to submit to the IPS now please. Thanks.
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You obviously submitted a strong appeal - this is evidenced by their failure to engage with any points raised.
You now have a choice - I personally recommend going down the IAS route as it shows that you are willing to engage / resolve the issue.
Could you post the content of your original appeal?
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Hi again
I got the appeal reply back from UKCPS by email today. A three-page letter. Side 1 is their response, side 2 is the automatic blurb and side 3 shows the 4 photos they have supplied and I have already posted in this thread.
I've copied and pasted the wording of their letter below.
As expected UKCPS declined my appeal, gave their reasons why and extended the time period for a payment to be made before the amount increases.
So now I have to appeal to the IAS. I see your good advice above B789 about this and note this is just a procedural step and not to expect much from it.
I would be grateful if there is some text you could copy to me to send off my appeal to the IPS please. I will also emphasise that the stop was for 5 seconds, all of the car doors stayed closed and the vehicle was not waiting or stopped. The fact the vehicle headlights are on and 5 seconds later they are off shows it is likely that it had mechanical failure and stalled for 5 seconds.
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LETTER - RESPONSE FROM UKCPS TO APPEAL:
UKCPS Ltd
City West Business Park
Building 3
Gelderd Road
Leeds
LS12 6LN
Name
Address
20th January 2026
Current Balance:
Ł60.00
Parking Charge Reference: X
Vehicle Registration: X
Location: Leeds City Station, LS1 4DY
Issued: 10/12/2025 at 14:54:54
Dear X,
Thank you for your appeal submitted on 27th December 2025. After reviewing your comments, and carefully considering the evidence collected at the time the Parking Charge was issued, we regret to inform you that your appeal has been unsuccessful. The reasons for our decision are detailed below:
The area where the vehicle stopped is designated as private land where parking, stopping, or waiting is strictly prohibited at all times.
At the time of the event, the vehicle was parked, stopped or waiting in this area, and as a result, the driver contractually agrees to pay a parking charge.
Attached, you will find photographic evidence showing the vehicle parked at the location mentioned above.
We have extended the opportunity for you to pay the reduced amount of, Ł60.00, until 05/02/2026, after this date, the full amount of Ł100.00 will be due.
Regards,
Appeals Team
PAGE 2 OF UKCPS RESPONSE:
Payment options are available as follows:
Online: Visit ukcps.ec6pay.com
By Phone: Make payments using Debit/Credit card by calling 0333 023 0121
By Mail: Send a Cheque/Postal order payable to UKCPS Ltd to the address provided at the top of this
correspondence
Alternatively, you can make payment by scanning the QR code provided
Payments received which are not accompanied by this information will be cashed but the creditor will be unable to allocate the payment to the correct Parking Charge. The Parking Charge will therefore remain unpaid and enforcement action may be taken. This will result in additional cost being incurred.
Independent Appeals Service
If you believe this decision is incorrect, you are entitled to appeal to the Independent Appeals Service (''IAS''). In order to appeal, you will need your Parking Charge Reference and your vehicle registration. Appeals must be submitted to the IAS within 28 days of the date of this response. Please note if you make an appeal with the IAS then the discounted rate is no longer available.
Please visit their website www.theias.org
Complaints
If you wish to complain, you MUST complain to us directly in the first instance by writing to us at the address at the top of this letter. If you are not satisfied with our response, then you may refer your complaint to the IPC.
Further details can be found at www.theIPC.info
UKCPS Ltd Registered Company Number 5090613; Registered in England and Wales
Due to data protection, we regret there is no public access to the registered office.
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Thanks for you help with this.
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Hello InterCity125 and b789 and thank you both for replying.
B789 I can see why you are a hero member with your knowledge and thoroughness, it's pretty amazing to read. And I love your term about them being spanked ;D
I will use the wording that you gave me previously b789 and get it sent off.
This site has been really good at preparing me on how this will play out. I am not a low-hanging fruit thanks to your explanations and I will see this through.
I appreciate your help with this THANK YOU
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I have looked carefully at the UKCPS notice, the signage, and the status of the location, and I want to explain why the claim they are making is fundamentally flawed.
The road (Princes Square) where this was issued is part of the railway estate owned by Network Rail. At the time of the alleged event, land forming part of the railway estate was subject to statutory control through railway byelaws and was therefore not “relevant land” for the purposes of the Protection of Freedoms Act 2012. Because of that, UKCPS could not rely on PoFA to transfer liability from the unknown driver to the known registered keeper, regardless of the fact that their Notice to Keeper is headed “Postal – PoFA”. Keeper liability simply did not arise on railway land at the time of this incident, and any suggestion otherwise is misleading.
There has since been a legislative change, taking effect from 26 December 2025, which alters the definition of relevant land so that certain railway land may fall within PoFA going forward. However, that change is not retrospective. The applicable law is the law in force on the date of the alleged event. As this incident predates 26 December 2025, the change does not apply here and cannot be relied upon by UKCPS to create keeper liability after the fact.
The signage at the location is also contradictory and incapable of creating clear contractual terms. There is no PPSCoP- or IPC Code of Practice-compliant entrance sign to the station estate or to Princes Square itself. The only identifiable compliant entrance sign is positioned as drivers turn off Princes Square into the station forecourt and is specific to that forecourt area alone, not to the wider station estate or Princes Square roadway. That sign states “Private Land – Pick up & drop off only” and directs drivers to see signage within the pick-up/drop-off area for further terms. It therefore expressly permits stopping for the purpose of picking up or dropping off passengers, which necessarily involves stopping, even if only briefly. This permission cannot be reconciled with the separate repeater signs along Princes Square stating “No Stopping – Ł100 charge”, which purport to impose an absolute prohibition. Taken together, the signage is fragmented and internally inconsistent, and does not communicate any clear or coherent set of contractual terms to a driver.
Separately and in any event, a “No Stopping” sign is inherently prohibitive in nature. It does not make an offer capable of acceptance. A contract requires an offer and acceptance, and a sign that simply bans an activity does not offer permission to carry it out on terms. Where stopping is forbidden outright, there is nothing a driver can accept and no contractual licence being granted. At most, such signage could give rise to an allegation of trespass, which is a matter solely for the landholder and does not entitle a private parking company to impose a fixed contractual charge.
There is also a basic defect in the Notice to Keeper itself. It does not specify any period of parking. It provides only a single “time of issue”. A single timestamp is not a period. Despite this, the notice claims that the charge relates to “the period of parking specified above”, when no such period exists. That alone defeats any attempt to rely on PoFA, even on land where PoFA might otherwise apply.
The positioning of the signage further undermines their case. The alleged “No Stopping” sign is placed as drivers leave a public highway roundabout and enter Princes Square, and it runs parallel to the direction of travel. That placement does not give a driver a fair opportunity to read, understand, and consider terms before any alleged breach. Terms cannot be accepted if they are not reasonably communicated in advance.
It is also important to be clear about what actually happened. Stopping for a few seconds to check where you are or to look at directions is not the same as waiting or parking. Double yellow lines prohibit waiting, not stopping. The Highway Code makes a clear distinction between the two. Waiting means remaining in place for longer than is needed for the normal flow of traffic. A brief stop to orient yourself, check a sign, or confirm a turning is part of normal and safe driving and is not treated as waiting.
Even where there are double kerb blips, the restriction is only on loading and unloading. It does not create a no-stopping restriction. A genuine no-stopping restriction requires a clearway, a red route, or a specific no-stopping order backed by a Traffic Regulation Order. Without that, the law does not prohibit a momentary stop to check directions.
Private parking companies often try to pretend that any pause equals prohibited stopping, but that is not how road markings work and not how the Highway Code defines these restrictions. A momentary stop to check your location is simply not the kind of behaviour these restrictions are designed to regulate.
The overall position is that this was railway estate land where PoFA did not apply at the relevant time, the entrance signage expressly permits stopping for pick-up and drop-off, the signage relied upon by UKCPS is contradictory and prohibitive and incapable of forming a contract, the Notice to Keeper does not specify a period of parking, and the alleged conduct amounts to nothing more than a brief, lawful stop that forms part of normal driving. You should deal with this strictly as the registered keeper and you should not identify the driver.
So, the advice about the initial appeal still stands. We can make a clearer argument in the secondary appeal to the IAS, although that is not "independent" and is also not likely to be successful for the simple fact that you are now in the middle of a scam. That does not mean we don't try but, realistically, this would be easily defeated if they try to progress it to litigation in the county court as a small claim. There is no way they would let this progress to a hearing as they know they would be spanked.
Their MO is to hope that you are low-hanging fruit on the gullible tree and can be intimidated into paying out of ignorance and fear. That is the truth behind how these bottom-dwelling firms operate. Submit the appeal and come back when they reject with their reasoning.
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So the alleged contravention appears to have occurred on an access road which we believe is not relevant land for PoFA - so they have no ability to hold the keeper liable - the only person who can be held liable is the unknown driver - there is no way they can ever find out the driver details because there is no legal obligation for the keeper to provide that information to an unregulated parking operator.
Further, the pictures show a vehicle stopped on a double yellow line - double yellow lines do not mean 'no stopping' - so the 'signage' is not consistent across the site assuming that they are alleging some kind of breach of contract based on the drivers agreement as they entered the site.
Also, their PCN NtK is in breach of the parking operators code of conduct as the NtK clearly attempts to mislead the keeper into believing that the keeper could be held liable for the charge when no such liability can ever exist.
A breach of the CoC is automatically a breach of the DVLA KADOE agreement.
Wait for a further update regarding the precise wording to use in any appeal.
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I have held off sending in the appeal and will send it in as soon as someone on here says I can!
Thank you for the words already given.
I have to submit the appeal via UKCPS own website.
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side 2 of letter
https://ibb.co/G3CkXzPD
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side 1 of letter
https://ibb.co/39CXvL1Z
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photo 4 overview of road location, vehicle is on the right
https://ibb.co/WW34mFm5
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photo 3
https://ibb.co/1f6r6PGc
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photo 2
https://ibb.co/V0kCj037
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photo 1
https://ibb.co/HL7C85YV
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Hello!
I have got sorted out and got the photos on ibb and can now share them with you. If you have the time to have a little look I would appreciate it.
The time of stopping is 5 seconds, I did my maths wrong the other day when I said 6 seconds, hahaha. Presumably the engine stalled, this is backed up by the vehicle's lights being on then in the last photo the lights are switched off.
Please check the location for me, they give a nice shot of the entire road.
Thank you.
I'm going to add 6 photos:
4 = of the vehicle
2 = side a and b of the charge letter
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you show us the NtK and the evidential photos, we can help identify whether the alleged contravention was on relevant land or not.
If you need an initial appeal, the just use the following. Almost no initial appeal is ever upheld so don't waste any effort on it.
I am the registered keeper. UKCPS cannot hold a registered keeper liable for any alleged contravention on land that is under statutory control (until 26 December 2025). As a matter of fact and law, UKCPS will be well aware that they cannot use the PoFA provisions because Leeds Stationt is not 'relevant land'.
If Leeds Station wanted to hold owners or keepers liable under Railway Bylaws, that would be within the landowner's gift and another matter entirely. However, not only is that not pleaded, it is also not legally possible because UKCPS is not the station owner and your 'parking charge' is not and never attempts to be a penalty. It is created for UKCPS’s own profit (as opposed to a bylaws penalty that goes to the public purse) and UKCPS has relied on contract law allegations of breach against the driver only.
The registered keeper cannot be presumed or inferred to have been the driver, nor pursued under some twisted interpretation of the law of agency. Your NtK can only hold the driver liable. UKCPS have no hope should you try to litigate, so you are urged to save us both a complete waste of time and cancel the PCN.
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That's good to know thank you. I was not in the car, I am sorting this out as the registered keeper and it was initially difficult because the driver had no recollection of stopping and also the link to the photo evidence did not initially available to help the driver remember.
Now that I have seen the photo evidence, it has not helped the driver to remember because the stop was for a few seconds. It's good to know that the driver doesn't need to remember anything more to help me appeal this case. And it's true to say that the driver did have a passenger and I am not sure who paid for the parking.
I will upload the info hopefully tomorrow so that I can get advice on here before replying to UKCPS. Thanks again.
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The ONLY way an unregulated private parking firm can identify the driver is if the Keeper tells them. There is absolutely no other way for them to identify the driver.
Even if they had a close up HD photo of the driver, there is no way they can identify the person. There is no magical unicorn database they can input an image and out will spit the persons identity.
The only identity they have is the Keepers. They got that from the DVLA. There is absolutely no presumption in law that the Keeper is also the driver. Anyone with third party insurance cover can drive the car, not just named drivers covered under a comprehensive policy. Anyway, these bottom-dwelling private firms have no powers to check who is on an insurance policy.
So, the absolutely ONLY thing you need to do as Keeper is to NOT identify the driver. No "I did this or that", only "the driver did this or that". The ONLY way they can transfer liability from the unidentified driver to the known Keeper is if the NtK is 100% compliant with ALL the requirements of PoFA 2012 and the location is land that is "relevant" to the Act.
This is why it is important to establish exactly where they claim the vehicle "stopped". If it is on railway property, then until 26th December, it is NOT relevant land and they cannot rely on the provisions of PoFA.
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Unless you want this to escalate, DO NOT post anything to the parking company until we've seen all the paperwork. I don't see how a parking company could identify a driver through paying at a cash machine. a passenger in the car could be paying for the parking.
Don't panic, it's Christmas and some of us may not want to look in here this time.
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thank you b789, I appreciate your speed of reply and your knowledge!
Nobody has replied about the possibility of UKCPS identifying a driver thru the electronic payment method used when departing from the multi storey car park. Can this happen? If it can happen, how can the driver be safe by me putting all the info on here?
Once info has been confirmed about identity, I will read up on how to upload all the photos, their 2 page letter and my draft reply.
I will do this within the next few days, or maybe tomorrow if I get some help sooner.
I won't send my reply till I hear back on here.
I know I have to submit within 28 days of the day after the notice is given. I think that means the day after the alleged incident happened? Or does it mean the day after the date of their letter? Either way I have enough time over the next few days.
For clarity, the letter does not state any detail except No stopping. It does not mention the multi storey carpark. I mentioned it because the location of stopping is different from the majority of cases on here because it is not at the station door. From the photos you might recognise where the vehicle stopped for 6 seconds.
If a car stalls and the engine loses functioning, I don't see how that is seen as purposeful stopping and I assume the CCJ would view this too if it reaches that point.
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Stop!!!!! Do not appeal anything until you have shown us the Notice to Keeper (NtK), both sides. We need to see the EXAXT wording they have used to describe the alleged contravention. We also need to establish exactly where the alleged contravention took place because the multi-storey car park at Leeds Station is relevant land but the station itself is not.
If they are alleging that the driver breach a contractual sign that forbids stopping, then they ar lying because a forbidding sign cannot for a contract with the driver. There are many elements to this that we do not yet know. So, before you do anything else, post photos of the NtK and if possible any supposed evidential photos they may have included on their website.
READ THIS FIRST - Private Parking Charges Forum guide (https://www.ftla.uk/private-parking-tickets/read-this-first-private-parking-charges-forum-guide/)
Posting Images (https://www.ftla.uk/announcements/posting-images/#new)
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The letter of parking charge from UKCPS for Leeds Station does not provide an email address.
I would prefer to send in the appeal by email.
The only contacts given for appeals are by post and via their website.
Are all Keepers having to send in the appeal via the UKCPS website? Does it have tracking?
The letter does not include an email address anywhere for anything.
Thanks!
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hi jfollows and thank you,
I have edited my post because their web link is working now.
6 seconds is the time of stopping. 6 seconds.
Should I mention 6 seconds in my short reply to them if only to ridicule them?
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You will have seen from your research that it’s not “relevant land” as defined for PoFA 2012, and therefore the liability can’t be transferred from the unknown driver to you, the registered keeper.
Don’t identify the driver and appeal accordingly.
The appeal, although correct, will be rejected “after careful consideration” because it’s what they do.
No matter. You continue with advice here and eventually they’ll give up.
Since your initial appeal will be rejected anyway, don’t go overboard with it. Search the forum for sample appeals from the same location.
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I joined here today, read some past cases and advice given to parking charge notices issued by UKCPS at Leeds train station. It is an excellent source of info of how to progress.
I will post here the photos of the letter I received but please bear with me, I need assistance to do this so it will take a few days to do it. Looking at those already provided on here, it is an identical letter for this location, Leeds Station.
From the info I have cobbled together a letter to appeal to UKCPS. I have cut down the detail as advised. I have also followed a more concise reply to them as found on here (see below). I did try and thank those who I took info from by using the emojis, but as a first-time user of this site I am not sure I did it properly because the site said "loading" and I'm not sure if the emoji messages were sent... I am grateful for the help you gave to previous cases.
One thing, most of the cases at Leeds Station involve drivers stopping for a very short space of time for passengers to alight. The driver of this case has a different set of circumstances which I will list here in case there has to be a change to the wording at this stage or the next stage (appeal to the IPS which will also be rejected probably) which will come along soon enough when UKCPS rejects my appeal.
THIS CASE:
We cannot tell from the picture provided where the contravention of stopping is supposed to have happened.
The driver had left the station's multi storey car park where they had paid for parking for a few hours and was driving away when the photo was taken. The driver has no recollection of stopping for a purpose.
The driver believes they did not stop. If they did stop it was for something very inconsequential and for a very short space of time. Most certainly the car doors were not opened and the engine was not switched off. The photo provided shows the car has its lights on.
The driver recalls leaving the car park without any different circumstances, probably following other cars, with pedestrians around and just driving onwards in the flow of traffic. Or, perhaps the car stalled. The driver has checked their phone and text logs and confirms there was no need to pull over to use their mobile.
EDIT: the time frame of stopping is 6 seconds. Let's all laugh LOUDLY.
Questions:
1. EDIT: the UPCPS web link now works and the timescale is now confirmed to be 6 SECONDS DURATION!!
Should I mention 6 seconds in my appeal to UKCPS?
INITIAL QUESTION: The link provided in the letter does not work so I cannot see additional information on the duration of the time stopped. I assume this is where this information should be because other users have mentioned it and it is not stated in the letter (only the time of the stop). Obviously this information is important to have. How do I deal with this missing information? Presumably it will be for a few seconds.
2. For the IPS when that comes next:
If we provide information that we had parked in the multi storey car park, can UKCPS identify the driver through the time of departure from multi story car park and the electronic method of payment used? This could be risky information?
3. I had initially thought it helped to prove that the driver had parked legally and paid in the multi storey, then when the driver left they were driving a short distance through ‘presumably’ railway land to the public road and the car did not stop unless it had to through flow of traffic or pedestrians crossing. Or perhaps the car stalled. However, it may need careful consideration about divulging it and only necessary at CCJ?
Defence at CCJ if it reaches that point:
4. How can the driver make a defence if they have no memory of stopping?
Will the duration of the stop provide the evidence that the stop was not illegal? As I mentioned above I do not yet have this information because the link in the letter does not work.
is the defence affected because the driver has no explanation?
Thanks for your help!
It's Christmas Eve and I must do some things, then I will return and I will post the appeal to UKCPS I have done.
In the next few days I will upload the letter from UKCPS