Free Traffic Legal Advice

Dear Sirs,

Your Letter of Claim contains insufficient detail of the claim and fails to provide copies of the evidence your client places reliance upon, putting it in clear breach of the Pre-Action Protocol for Debt Claims.
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As a supposed firm of solicitors, one would expect you to comply with paragraphs 3.1(a)–(d), 5.1 and 5.2 of the Protocol, and paragraphs 6(a) and 6(c) of the Practice Direction. These provisions exist to facilitate informed discussion and proportionate resolution. You may wish to reacquaint yourselves with them.
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The Civil Procedure Rules 1998, Pre-Action Conduct and Protocols (Part 3), require the exchange of sufficient information to understand each other’s position. Part 6 clarifies that this includes disclosure of key documents relevant to the issues in dispute.
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Your template letter refers to a “contract” yet encloses none. That omission undermines the only foundation upon which your client’s claim allegedly rests. It is not possible to engage in meaningful pre-litigation dialogue while you decline to furnish the very document you purport to enforce.
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I confirm that, once I am in receipt of a Letter of Claim that complies with para 3.1(a), I shall seek advice and submit a formal response within 30 days, as required. Accordingly, please provide:
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A copy of the original Notice to Keeper (NtK) and any notice chain relied upon to assert PoFA 2012 liability.
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A copy of the contract you allege exists between your client and the driver, being an actual photograph of the sign(s) in place on the material date (not a stock image), together with a site plan showing the sign locations.
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The precise wording of the clause(s) allegedly breached.
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The written agreement between your client and the landowner evidencing standing/authority to enforce and to litigate.
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A breakdown of the sums claimed, identifying whether the principal sum is claimed as consideration or damages, and whether the £70 “debt recovery” add-on includes VAT.
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I am entitled to this information under paragraphs 6(a) and 6(c) of the Practice Direction, and I require it to meet my own obligation under paragraph 6(b).
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If you fail to provide the above, I will treat that as non-compliance with the PAPDC and Pre-Action Conduct and will raise a formal complaint to the SRA regarding your conduct. I reserve the right to place this correspondence before the Court and to seek appropriate sanctions and costs (including, where appropriate, a stay and/or other case management orders).
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Until your client complies and provides the requested material, I am unable to respond properly to the alleged claim or to consider my position. It would be premature and a waste of costs and court time to issue proceedings. Should you do so, I will seek immediate case management relief pursuant to paragraph 15(b) of the Practice Direction and an order compelling provision of the above.
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Please note, I will not engage with any web portal; I will only respond by email or post.
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Yours faithfully,
[My name]

I am the registered keeper. APCOA cannot hold a registered keeper liable for any alleged contravention on land that is under statutory control. As a matter of fact and law, APCOA will be well aware that they cannot use the PoFA provisions because Luton Airport is not 'relevant land'.

If Luton Airport wanted to hold owners or keepers liable under Airport 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 APCOA is not the Airport owner and your 'parking charge' is not and never attempts to be a penalty. It is created for APCOA’s own profit (as opposed to a bylaws penalty that goes to the public purse) and APCOA 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. APCOA have no hope at POPLA, so you are urged to save us both a complete waste of time and cancel the PCN.

Dear H,

Your timeframe to respond to the operator regarding the PCN detailed below has now expired. The contents of the appeal has been passed onto the adjudicator for their decision.

Parking Charge Number (PCN): ANPR283097
Vehicle Registration: ST61RZJ

Operator's Prima Facie Case
The operator made their Prima Facie Case on 18/09/2025 12:00:57.
The operator reported that...
The appellant was the driver.
The appellant was the keeper.
The operator is seeking keeper liability in accordance with PoFA..
ANPR/CCTV was used.
The Notice to Keeper was sent on 23/07/2025.
A response was received from the Notice to Keeper.
The ticket was issued on 23/07/2025.
The Notice to Keeper (ANPR) was sent in accordance with PoFA.
The charge is based in Contract.

The operator made the following comments...
The appellant was captured entering the car park at 11:46 and captured leaving at 12:05.

The Vehicle in question was parked in the car park without paying for their duration of stay. The screenshot uploaded shows the vehicle did not pay for their duration of stay.

There is pay by phone, cash, card and contactless available for payments.

The signage throughout is clear that you must pay for the whole duration of your stay.

In regards to the comments made by the appellant, please see photos of the signage on site, the NTK, the ANPR log and other payments made by other motorists at the time of the contravention.