Free Traffic Legal Advice
Live cases legal advice => Private parking tickets => Topic started by: ChrisS on February 19, 2026, 04:15:42 pm
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Thank you very much for the speedy responses, I feel somewhat calmer now and will respond as you have advised.
Watch this space, and my thanks again.
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7. That the attempt to use PoFA Keeper Liability is not applicable to this specific location since the location is not classed as 'relevant land' under the legislation - the location at Leeds Railway station is subject to Railway Byelaws and therefore it is excluded from PoFA.
One might argue it is overkill, but I would add to this point why the existence of railway byelaws means it is not relevant land. Namely, that these byelaws meant that the parking of vehicles on the land was subject to statutory control.
May also be worth being explicit about the dates, I.e. That the alleged contravention took place before the recent change to the railway byelaws.
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It was expected and is part of the process.
Nothing to worry about.
Your defence is very simple.
No need for an AOS - Just log onto MCOL and submit the following;
Leeds Railway Station defence.
1. This claim is denied in its entirety and no debt is owed to the Claimant.
2. It is acknowledged that I was the Registered Keeper of the vehicle at the material time.
3. That the driver of the vehicle is not known to the Claimant and that there is absolutely no legal requirement for me to reveal the drivers details to an unregulated private parking contractor.
4. That no assumption of who was driving can be drawn from me simply exercising my right to say nothing in a situation where the law does not require me to disclose driver information.
5. That the Claimant is using a 'Boiler-plate' Particulars of Claim which lacks accuracy and relevance to the particular matter.
6. That with the driver not known to the Claimant, the Claimant is attempting to use Protections of Freedoms Act (2012)(PoFA) in order to invoke what is known legally as 'Keeper Liability'.
7. That the attempt to use PoFA Keeper Liability is not applicable to this specific location since the location is not classed as 'relevant land' under the legislation - the location at Leeds Railway station is subject to Railway Byelaws and therefore it is excluded from PoFA.
8. That the Claimant's own Parking Charge Notice (PCN) Notice to Keeper (NtK) specifies, ironically, in large bold print, that the NtK is "Non-PoFA".
9. That PoFA Keeper Liability is therefore not available to the Claimant.
10. That with both the driver unknown and no Keeper Liability available, there is no legal route to liability in this matter.
11. That liability is therefore denied.
Additional Defence Points;
12. That it is not possible for the Claimant to have formed a contract with the driver in any circumstance since a driver would never consider that the Claimant's signage constituted an offer of contract since the signage simply resembles normal road signage.
13. That, in law, in order for a contract to have been formed there would need to be 'clear intent on the part of both parties to form a legal relationship' - it therefore stands that no contract can be formed in a situation where the driver does not recognise that a contract is being offered.
14. That the road markings and signage demonstrated in the parking operators evidence are contradictory in nature and are therefore in breach of the Parking Operators own industry Code of Practice.
15. That whilst some signage specifies, "No Stopping" there are additional road markings such as double yellow lines which allow brief stops for dropping off and picking up passengers.
16. That in order to be compliant, No Stopping signage can only be supported by double red lines.
17. That in previous correspondence, the Claimant's legal representatives have consistently sent me legal letters which attempted to completely misrepresent their true legal position in an attempt to pressure me into paying.
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It was all too quiet....
So this popped through the letterbox yesterday. As previously, any help / guidance as to how to complete the claim response would be most gratefully received. Thank you in advance.
https://imgpile.com/p/oOiCCKc#3tCf9Uy
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I should point out that the line about there not being clear signage might not work, because there are massive red and white signs that say "No stopping" in letters the size of my head and "£100 charge if you stop" in letters not that much smaller. You can see them on Street View.
We haven't said 'unclear signage'.
We ARE saying 'contradictory markings', namely; double yellow lines which allow brief stops for picking up / dropping off.
If they want a no stopping zone then double reds are required.
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I should point out that the line about there not being clear signage might not work, because there are massive red and white signs that say "No stopping" in letters the size of my head and "£100 charge if you stop" in letters not that much smaller. You can see them on Street View.
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Good point - thanks for the reminder !
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Best to remove the personal details of the upload, (address etc).
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Hi, thank you for the quick and detailed response, I will do as you suggest.
Could I ask if the SRA investigations against Moorside are documented / evidenced somewhere the general public would have access to ?
Many thanks
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Normal drivel from the hapless Moorside Legal.
You could replay with the following;
To whom it may concern,
I write in response to your letter dated 5th March 2026.
I am the vehicle keeper and the driver it not known by your client.
Once again, I refute that any monies are owed by me (the keeper) to either you or your client.
Your client should contact the driver directly if they feel that a parking charge is owed - I will not be providing driver details because the law does not require it.
The Letter Before Claim was from Moorside Legal and, as such, my replies are directed at you and not your client.
My previous letter was NOT an appeal but a legitimate response by myself to a LBC.
Your latest letter contains a clear legal inaccuracy which is specifically designed to mislead me into thinking that the vehicle keeper can be held liable in a scenario where the legislation clearly shows that keeper liability is specifically excluded.
Given that Moorside are being extensively investigated (by the SRA) I am surprised that you continue to deliberately misrepresent your true legal position in matters such as these.
The fact is that liability remains with the unknown driver - you do not have the legal authority to reallocate liability in the manner which you imply.
Your client and yourselves are, of course, entitled to pursue a registered keeper for any reason you wish - that is your right as a Claimant - however, this is, as a County Court Judge recently pointed out to a parking operator (who was attempting to rely on 'reasonable assumption' to move liability onto a keeper), 'This is actually a commercial decision by the parking operator and NOT an already established legal position' (paraphrased). The Judge then continued by pointing out that a parking operator 'must still PROVE their case in the same manner as any other Claimant and that an assumption of who was driving must still be materially evidenced in order to establish that the keeper was liable' (paraphrased).
So, to be clear, at the present time the liability remains with the individual who formed the alleged contract with your client - you cannot simply shift liability due to that inconvenience.
Liability in this matter has NEVER been with the vehicle keeper at any stage.
I also note that your previous letter does not address the other aspects which were raised.
In particular, the contradictory road markings demonstrated by your client's own evidence.
I am sorry that I cannot help your further in this matter.
Have a great day,
xxxxx xxxxxxx
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Hello again, Moorside Legal have responded promptly - please see below link.
Link removed
I have logged into their portal to view the reply claimed to reside in the "my documents" section and a message pops up to say "Oops, this page currently isn't available, please try again or contact us" Needless to say repeated attempts yield the same outcome.
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Yes.
Please don’t start a new thread, just add to this one.
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Hi, thankyou, I will respond as you suggest. I doubt this will conclude matters, given what I have read on other posts here so when I hear back from them, do I resume on this post please ?
Many thanks in advance.
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If it were me, I would respond with a simple reply pointing out that I am the keeper and that liability is denied.
To whom it may concern,
I write in response to your letter of claim.
I am the vehicle keeper.
Liability for the alleged debt is denied in its entirety.
For the purposes of clarity; the vehicle driver is not known to your client and there is no legal requirement for me to reveal the driver.
Your assertion that the keeper can still be held liable is also rebutted and has no basis in law whatsoever - if you are in any doubt over this then I would respectfully draw your attention to the Judge's comments in the Appeal Court case of VCS v Edward.
Your feeble attempts to imply keeper liability are a very obvious attempt to circumvent the requirements of PoFA - if what you suggest were true then PoFA need not exist.
I would also point out that, having examined the evidence, it is clear that the vehicle driver appears to be stopped briefly on double yellow lines - double yellow lines constitute a statutory road marking with specific meaning - double yellow lines DO NOT mean 'No Stopping' and, as such, your client's attempts to enforce a no stopping zone are in clear violation of their Code of Practice which demands that signage and markings be UNAMBIGUOUS in nature - in this instance, the markings are in direct contradiction of the alleged term of 'no stopping' - double red lines would be needed in order to satisfy the requirements of your client's Code of Practice.
I feel that I have now set out my legal position.
I am sorry that I cannot help you further.
Best wishes,
xxxxxx xxxxxxxxx
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Revised uploads below. Hopefully easier to read.
https://i.postimg.cc/x8VtMsL9/Scan2026-02-19-174242.png
https://i.postimg.cc/rwsC067Z/Scan2026-02-19-174405.png
https://i.postimg.cc/JzYxP7bV/Scan2026-02-19-174334.png
https://i.postimg.cc/N04gWVjG/Scan2026-02-19-174405.png
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Apologies - I did explain the blurred document, I'm using the upload links from this resource. I'm not sure why the documents are at 90 degrees, they weren't orientated that way on the scan. I will try again.
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You've made no effort. Your first link goes to a blurred document.
Your second link goes to a series of very small documents orientated at 90 degrees.
Come on man, you have to do better than that if you want help.......if you can't put some basic effort into it at this stage then maybe you should just cough up?
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Sorry, the upload was all blurred on last one - this is clearer, there are another couple of pages to come - sorry for the fragmented parts...
https://i.postimg.cc/nhjwDQDn/Scan2026-02-19-171906.png
https://i.postimg.cc/7605GXx3/Scan2026-02-19-171906.png
Thank you
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Another upload - the first only took part of the scan...
https://ibb.co/8gKmJwGd
Many thanks !
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Hi
Please see link below to documents requested.
https://i.postimg.cc/mgsFQvc6/Scan2026-02-19-171906.png
I didn't submit an appeal to IAS.
Best
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THIS (https://www.ftla.uk/announcements/posting-images/)
Redact your name and address and any claim reference number or QR code.
If you're super paranoid then redact your registration number.
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HI, sorry, please could you direct me to where to upload the documents and also what to redact ?
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To provide sound advice it would be good to see:
- The original PCN
- Your appeal* to UKCPS
- Your appeal to IAS
- Moorside's Letter of Claim
*I'm not entirely sure I understand the point you're making around UKCPS referring to your correspondence as an 'appeal', your reluctance to call it the same, or you writing to them to claim you had not submitted an appeal. An appeal is essentially written correspondence in which you set out why you believe you do not owe the charges being claimed. You appear to have sent them written correspondence in which you set out why you believe you do not owe the charges being claimed. For all intents and purposes that seems like an appeal, and there is no adverse consequences for you to it being described as such.
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If you want the best advice then post the PCN (both sides).
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Hi
I received a "Notice to Keeper (Postal - Non PoFA)" parking charge from UKCPS on 22 August 2025.I responded to confirm I am the keeper of the vehicle identified on the parking charge, and disputing the charge. I confirmed I would not be identifying the driver, and requested the parking charge be cancelled.
UKCPS wrote back to me to advise that my appeal (!) had not been successful, along with a page of video stills showing my car and a number of random images of "No Stopping" notices and colour coded satellite images of the road area in question.
I wrote again to UKCPS, re-stating my position and confirming that I had not submitted an appeal, and pointing out that contrary to their claim, they could not recover the outstanding balance from myself as registered keeper on the assumption that I was the driver.
They wrote again to me to tell me that they were "satisfied the parking charge was issued correctly in line with the terms and conditions displayed on site" and that the charge remains valid. They also pointed out I had missed my timeframe to submit an appeal to the IAS. Which I had.
The next correspondence came from Trace Debt Recovery on 10/12/25, again on 5/1/26 and finally again on 21/1/26. All correspondence from Trace Debt Recovery went unanswered.
The latest correspondence is from Moorside Legal, received today (19/2/26) and dated 11/2/26 as a Letter of Claim.
I have read a number of posts on FTLA and have been guided by them up until this point. As we are now going into the "fun" legal part, I am keen to proceed as correctly as possible. I need to respond to Moorside Legal's letter of claim within 30 days (advised by them) and their letter is dated 11/2/26.
I would thus be very grateful for help / direction as to response at this point.
Kind regards