Free Traffic Legal Advice

I have written this to respond to the LOC.
Please tell me your comments.Thank you



Dear Sir/Madam,

I am writing in response to your Letter of Claim regarding an alleged debt stemming from a Parking Charge Notice (PCN) issued by Parking & Property Management Ltd. I formally dispute the entirety of this alleged debt. I am the registered keeper of the vehicle, and liability is completely denied.

Your client cannot transfer liability to me as the registered keeper because the Notice to Keeper (NTK) fails to comply with the requirements of Schedule 4 of the Protection of Freedoms Act 2012 (POFA). Accordingly, keeper liability has not been established, and I do not accept that I am liable for the alleged charge.

Your client’s claim relies entirely on Automatic Number Plate Recognition(ANPR) camera data, which merely records images of a vehicle passing a boundary line. This data fails to provide any evidence of actual parking. I deny liability on the absolute grounds that the vehicle was never parked. The vehicle was in continuous motion for the entire duration, with the driver inside, navigating the property at Parkwood.

The ANPR timestamps therefore do not establish the duration of any parking event. They merely indicate the times at which the vehicle passed the relevant entry and exit camera points. If your client alleges that a parking contract was formed and subsequently breached, it must provide evidence establishing the actual parking event relied upon, rather than simply relying on the vehicle's passage between ANPR camera locations.

Under the International Parking Community (IPC) Code of Practice, operators must provide a mandatory Consideration Period to allow drivers to enter a site, read the terms and signage, and exit safely if they choose not to park. The time spent driving around the property clearly falls within a reasonable period of consideration and navigation. Because the vehicle never came to a rest in a bay, no contract was ever formed, and no breach occurred.

Pursuant to the Pre-Action Protocol for Debt Claims under the Civil Procedure Rules, I request that you provide the following essential documentation within 30 days of this letter:
•Conclusive, date-and-time-stamped photographic evidence proving that the vehicle was stationary and parked in a designated bay, rather than merely moving around or exiting.

•A copy of the contract or written authority from the landowner at Parkwood permitting Parking & Property Management Ltd to issue charges and bring legal action.

•A full, transparent breakdown of the sum claimed, as arbitrary "debt collection/solicitor fees" represent unlawful double recovery under consumer protection laws.

If you proceed to issue county court proceedings without providing proof of actual parking, I will robustly defend the claim and bring this letter to the court's attention regarding your unreasonable conduct.
Yours faithfully,

I can see in the original PCN those matters have been mentioned and asked me to tell them the name and address of the driver and the PCN says this has been sent to me under the paragraph 9-2-f of POFA.

Can I still say they cannot transfer the liability to keeper?

When you say "The NTK is not compliant with POFA to transfer liability to the keeper" what action can I take against them?
Is there any template here to respond to LoC?

Thanks

Hi,
Thank you for the reply.
Here is the original PCN. https://ibb.co/kVqz96sf
Looking forward hearing from you