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Thank you all, appeal successful on the grounds of no keeper liability. They were also called out for claiming they got keeper details from DVLA despite showing no evidence of such a request.

I used b789's template which contains the phrase you highlighted that they seem to have just cherry picked in that block in their summary.

Submitted to POPLA and the operator has now uploaded the case summary below as well as a 30 page PDF of photos and text.

Doesn't make sense to me and the English seems a little broken in places like "Dvla legally send elite the keeper details" I didn't even know they had asked the DVLA for the registered keepers details.

Operator Case Summary

The motorist has said POPLA code: XYZ - PCN: ABC - Vehicle Reg XX

Dear POPLA assessor, The appellant is the registered keeper and is under no legal obligation to identify the driver. The operator has failed to comply with the requirements of Schedule 4 of the Protection of Freedoms Act 2012 (PoFA), and therefore keeper liability does not apply. As such, the burden remains with the operator to prove who was driving. The POPLA assessor is reminded that no adverse inference may be drawn from the keeper’s silence, and no assumption may be made that the keeper was the driver. However, Dvla legally send elite the keeper details. Therefore, it is the keepers liability to send us the details of the driver at the time of the offence, if the keeper does not challenge this the case will then be kept as the keepers details.

Shall I try upload the PDF here?

Yeah sorry a bit too cautious on my end. If in doubt I'd rather remove and reveal later.

Thank you very much submitted my comments

thank you so much, submitting now

So is my response correct and polished enough to submit?