Free Traffic Legal Advice

Maybe a case can be made this is a driving manoeuvre with obvious intention to pass the bus.

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Dear [redacted]

We write in response to your correspondence received in our office.
We now respond to the same as follows.

When parking on private land, the contractual terms of the site are set out on the signs. You are entering a contract and agreeing to the terms by parking and staying on the site. Parking in breach of the terms as stipulated on the signage means that you are then breaking the terms of the contract.

The terms and conditions on the signs stated the maximum stay allowed, or otherwise a parking charge would be issued. The vehicle was recorded on the land for longer than permitted, as is demonstrated in the photographic evidence attached. The parking charge was issued correctly.

Schedule 4 (4)(1) of the Protection of Freedoms Act 2012 (“the Act”) states “The creditor has the right to recover any unpaid parking charges from the keeper of the vehicle”. For the purpose of the Act; “keeper” means the person by whom the vehicle is kept at the time the vehicle was parked, which in the case of a registered vehicle is to be presumed, unless the contrary is proved, to be the registered keeper. The DVLA confirmed that you were the Registered Keeper at the time the parking charge was issued and as no transfer of liability has been received by our client, they have the right to recover the parking charge from you as the Keeper of the vehicle.

In accordance with the British Parking Association (BPA) Code of Practice, where the Parking Charge (PC) becomes overdue and before Court proceedings have commenced, a reasonable sum may be added for the debt recovery fees. The correct recovery fees have been added and will not be removed. As such, the outstanding balance of £170.00 remains payable to prevent further action.

We refer to our communication as per our letter of claim, we confirm that despite your latest correspondence, our position remains as previously advised. As such, should our client instruct us to proceed with further legal action, we reserve the right to do so without any further reference to you. If you are at all unsure of your legal position, we recommend that you seek your own independent legal advice.

 You now have 30 days from the date of this email to make payment of £170.00. Failure to make payment may result in a Claim being issued against you without any further reference.
Payment can be made via bank transfer to our designated client account: -

    Account Name: DCB Legal Ltd Client Account
    Sort Code: 20-24-09
    Account Number: 60964441

You must quote the correct case reference (REDACTED) when making payment. If you do not, we may be unable to correctly allocate the payment. If further action is taken by us as a result of an incorrect reference being quoted, you will be liable for any further fees or costs incurred.

Alternatively, you can contact DCB Legal Ltd on 0203 838 7038 to make payment over the telephone or online at https://dcblegal.co.uk/response/pay-online/.

Kind Regards,

Re: Letter of Claim dated 3 August 2026
Your reference: [REFERENCE]
UKPC Parking Charge Reference: [REFERENCE]

Dear Sir/Madam,

I write in response to your Letter of Claim dated 3 August 2026. I dispute the alleged debt in its entirety.

I am the registered keeper of the vehicle. The identity of the driver has not been disclosed, and no admission or inference as to the identity of the driver should be made from this correspondence.

1. Keeper liability

Liability as registered keeper remains disputed. I maintain that UK Parking Control Ltd has not established keeper liability in accordance with the strict requirements of Schedule 4 of the Protection of Freedoms Act 2012.

I acknowledge that POPLA reached a contrary conclusion. I do not accept that POPLA's decision determines my legal liability, and liability remains denied.

2. Permission at this barrier-controlled site

This was not simply an unattended car park in which a vehicle entered and remained without interaction with site personnel.

Access was controlled by an on-site security guard at a barrier. The driver spoke to the security guard, explained that they intended to remain for some time and was permitted to enter. The driver reasonably understood the person controlling access to have authority to permit entry and relied upon that permission.

UKPC subsequently produced evidence showing that the vehicle registration was not entered on its authorised vehicle list. The absence of an entry on that system does not establish that permission was not given. It establishes only that the registration was not entered into the system.

3. Disability and Equality Act 2010

The driver was a disabled person, was using a valid Blue Badge and parked in a designated disabled bay.

The circumstances therefore raise issues concerning the provision of services to disabled persons and the duty to make reasonable adjustments under the Equality Act 2010. Disability may affect matters including time management and the additional time reasonably required when using a site.

POPLA's decision stated that the operator had not been told how the driver's disability affected their ability to comply with the parking terms and treated the circumstances principally as mitigation. That decision does not determine whether UKPC complied with its statutory obligations, which remains disputed.

4. Authority and signage

I continue to dispute whether UKPC has adequately demonstrated the necessary authority to enforce the charge. The documentation disclosed during the POPLA proceedings was heavily redacted and involved a managing agent rather than establishing a clear and verifiable chain of authority from the landowner.

I also continue to dispute the adequacy of the evidence concerning the applicable signage. In particular, UKPC relied during the POPLA proceedings upon signage photographs dating from 2023 in relation to a parking event on 12 November 2025.

5. Additional £70

I dispute the additional £70 described as debt recovery costs. Please identify the precise contractual and legal basis upon which your client contends that this additional sum is recoverable from me.

6. Request for information and documents

In accordance with the Pre-Action Protocol for Debt Claims, please provide:

The contractual and legal basis for the additional £70, including the specific contractual term relied upon.
The evidence upon which your client intends to rely to establish keeper liability under Schedule 4 of the Protection of Freedoms Act 2012.

Contemporaneous evidence of the signage and terms in force at the site on 12 November 2025.

Evidence establishing UKPC's authority to enforce parking charges and bring proceedings at this location, including the relevant chain of authority where authority derives through a managing agent.

The procedures, instructions or contractual arrangements applicable on 12 November 2025 concerning the authority of security or concierge personnel controlling the barrier to admit vehicles, and the process for registering or exempting authorised vehicles.

Any records held concerning the vehicle's admission or authorisation at the site on 12 November 2025, including any relevant security, concierge, barrier-access or vehicle-registration records.

This response is intended to make my position clear and to engage constructively with the pre-action process. The alleged debt remains disputed in its entirety.

In light of the matters above, I invite your client to reconsider whether proceedings are appropriate. If your client intends to continue pursuing the claim, please provide a substantive response to the disputed issues and the information and documents requested above before commencing proceedings.

Yours faithfully,

Tomorrow. Se win lo  their website and unlawful threats.

The Protection of Freedoms Act (PoFA) 2012 is a law that allows parking operators to transfer the liability to the registered keeper if the driver or hirer is not identified. Parking operators must follow certain rules including warning the registered keeper that they will be liable if the parking operator is not provided with the name and address of the driver. In this case, the PCN in question has the necessary information and the parking operator has therefore successfully transferred the liability onto the registered keeper as the driver’s details were not provided within the given timescale stated on the Notice to Keeper (NTK).

The Single Sector Code of Practice has been jointly created by the British Parking Association (BPA) and the International Parking Community (IPC). It is largely based on the Government’s Private Parking Code of Practice, which was published in February 2022, and subsequently withdrawn in June 2022. The new Code is effective for all parking events that occur on or after 1st October 2024. Parking operators have until 31st December 2026 by which to comply with the signage standards set out in The Single Sector Code of Practice.

As such, I will consider the signage standards as set out in the BPA Code of Practice Version 9 and refer to the Single Sector Code of Practice for all other relevant issues to summarise my reasons. Section 14.1 of the Code states that where controlled land is being managed on behalf of a landowner, written confirmation must be obtained before a parking charge can be issued. In this case, the appellant has questioned landowner authority of which the operator has responded to be providing the landowner contract.

After review, I am satisfied that this complies with section 14.1 of the Single Code and the operator has authority to manage the site and issue PCN’s to those who do not comply with the terms and conditions. Section 19.2 of the BPA’s Code says operators need to have entrance signs that make it clear a motorist is entering onto private land.

The operator has provided an image of the entrance sign that tells motorists they are entering a car park where terms and conditions apply so I am therefore satisfied this complies with section 19.2 of the BPA’s code of practice and motorists are warned accordingly on entry to the car park. An entrance sign is only there to warn motorists that they are entering private land and terms and conditions are applicable. A motorist is not expected to read the entrance sign in full while driving so the terms and conditions are not included. However, they are expected to read the signs throughout the site having been warned they apply on entry.

Section 19.3 of the BPA’s Code says parking operators need to have signs that clearly set out the terms. The parking operator has provided images of the signs which are placed throughout the car park and advise of the terms of parking. The terms and conditions shown on these signs state, “Visitor parking only, 1-hour maximum stay”. They also inform motorists that a £100 PCN charge will be issued to those who do not comply. The driver remained at the site for 1 hour and 38 minutes, so a PCN was issued for a 38 minute overstay.

The appellant has started that the driver is disabled and the operator has failed to consider this which is a breach of the Equality Act 2010. I acknowledge their comments; however, the operator was unaware of any personal disabilities prior to the parking event.

The appellant appealed to the operator as the registered keeper and said the driver had a valid blue badge without explain how their disability may have affected their ability to comply with the term and conditions.

This was rejected because the terms and conditions do not state there are any concessions for disabled badge holders and the appellant failed to provide them with anything to consider. I must also advise the appellant that, when looking at appeals, POPLA can only consider if the PCN has been issued correctly in line with the terms and conditions of the site in question.

POPLA cannot allow an appeal based on mitigating or personal circumstances as this is the operator’s decision at the first point of appeal on how they wish to progress after the terms and conditions were breached. After considering the evidence from both parties, the driver exceeded the maximum stay time, so therefore did not comply with the terms and conditions of the site.

As such, I am satisfied the parking charge has been issued correctly and I must refuse the appeal.