#4 Re: PCN - PPS Royal Victoria Docks E16
on 18 Nov, 2025 01:29 in Private parking tickets
Coming back with an update and as expected PPS have sent a rejection to the appeal.https://ibb.co/tpS186DJI have formed an initial draft appeal below for POPLA, just wanted to know if it's worth adding anything else into it before I send it off to them?POPLA APPEAL – PPSPCN: 410887216 • Vehicle: WHZ5275 • POPLA Code: 5663185373NTK Location: 1 Western Gateway, E16 1XL (incorrect)Actual Location: 27 Western GatewayDate: 16/10/2025Appellant: Registered Keeper (driver not identified)1. No Keeper Liability – NTK Not Compliant with POFA 2012PPS cannot pursue the keeper because the NTK fails several mandatory requirements of POFA Schedule 4:No period of parking (POFA 9(2)(a)) – only a single timestamp.Incorrect/missing statutory wording (9(2)(e) & 9(2)(f)).Creditor not identified (9(2)(h)).Wrong location stated (“1 Western Gateway”) – the vehicle was at 27 Western Gateway.A materially incorrect location invalidates the notice.Keeper liability cannot apply.2. The Alleged Contravention Is ImpossiblePPS alleges “Parked on Red Route”, yet:No double red lines exist.PPS’s own photos show the vehicle in a marked bay, not on a Red Route.The alleged contravention could not have occurred.3. Signage Unreadable, Unlit, and Not Linked to the BayPPS’s signage photo is:Taken in darknessUnlit and unreadableNot adjacent to the bayNot proven to apply to that areaThis breaches BPA Code of Practice S.19.7 & S.21.1 (signs must be clear and legible before parking).No contract can be formed with invisible or irrelevant signage.4. Contradictory Signage – Terms Cannot Be EnforcedTwo conflicting sets of signs exist:Bay signage: “20 minutes free parking”.A distant Red Route sign.Where terms contradict, ambiguity is interpreted against the operator.The bay signage governs the bay.No enforceable terms exist for a “Red Route” within a marked parking place.5. PPS’s Own Evidence Shows 7 Minutes Stopping – AllowedPPS evidence timestamps:First photo: ~21:12Last photo: ~21:19Total: 7 minutes.The bay clearly allows 20 minutes free parking. Their evidence proves compliance, not a breach.6. Authorised Permission – Operator Is EstoppedThe driver was expressly told by a PPS warden that:Waiting to collect passengers was allowedUp to 30 minutes was permittedNo PCN would be issuedThis is a representation by PPS’s authorised agent.Under estoppel, PPS cannot penalise the driver for relying on permission granted by their own staff.7. No Site Map – PPS Cannot Prove Any Terms AppliedPPS supplied no site plan, no map, and no evidence showing:Where signs are placedWhether the Red Route sign applies to the bayWhether any sign was seen before parkingPOPLA routinely upholds appeals where operators fail to prove signage placement.ConclusionThe PCN must be cancelled because:The NTK is invalid under POFA → no keeper liability.The alleged “Red Route” breach is impossible.The vehicle was parked for 7 minutes within the permitted 20 minutes.Signage was unreadable, unlit, contradictory, and not linked to the bay.PPS stated the wrong location.A PPS warden authorised the waiting.PPS failed to provide a site map proving any terms. For these reasons, this appeal must be upheld and the PCN cancelled.