Free Traffic Legal Advice

OP, don't tell us what Horizon said in their response pl, show us.

Never mind, I notice that it is not in Scotland where there is no keeper liability. Horizon are plain, outright lying by stating that only the driver can appeal to POPLA.

An immediate complaint to Horizon pointing out their blatant lie about only the driver being able to appeal to POPLA deserves an explanation and an apology. When you get a response to the complaint, you should report them to the BPA.

I also note another problem with the NtK in that the location is not defined as relevant land. I can enter "Parkhouse Business Centre" and get several locations throughout the country with that name. As there is ambiguity with the relevant land, it is just another point to use in your POPLA appeal.

Basically... yes. However, it is advised to include as many points for the operator to rebut. They have to successfully rebut all points raised. The appellant only has to be successful on a single point.

You should lead with the lack of keeper liability due to non-PoFA NtK and then follow with the fact that the operator has not shown that the person it has issued the NtK to is the driver.

Use the following (but not limited to) points in your POPLA appeal:

1. The Notice to Keeper (NtK) does not meet PoFA requirements to hold the keeper liable.
2. The operator has not shown that the appellant is the driver.
3. The signage is inadequate and no contract was formed with the driver.
4. No landowner authority to issue PCNs in its own name.
5. No valid landowner contract.
6. Non compliance with any BPA Code of Practice rules you can find and so on...

You will need to expand on each point so that the assessor can understand your reasoning.