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There is an Enquiry tab. I am presently trying to send in my Appeal that way. Again the box DOES NOT ALLOW A COPY AND PASTE. A barrier for users for sure.  I am trying to at least submit it this way so I have evidence for the CCJ (just in case it gets that far). I have no idea of word length yet. They should not be so harsh with User error.  I am still in the deadline.

Thanks Intercity
I will add that to the statement you kindly gave me before.  Just the point I was wanting to make = brill.

The change to "non-ANPR" isn't important then?  I thought they would have changed it to ANPR - I must not be understanding it properly.

Hi,
I have received advice from one person on here and I am grateful to Intercity125. 
I had added some queries and they haven't been answered.
I am assuming that other advisers agree that the reply I have received from Intercity125 covers all important bits and I'm good to go and submit it this evening.

I don't know if its usual behaviour or not for an operator to change the NtK at the stage of IAS appeal, but they have changed their claim (this is good news for me).

I also do not understand the change to "non-ANPR" when they have used ANPR through CCTV photo evidence (have I understood this correctly?). Should my response include something about this?

I know their claim is much more diluted now that they have withdrawn PoFA.  Ive read on here a response that the IAS sent to somebody else about signage and the law of Contract in the same location and dismissed their appeal, so I am anticipating a very similar response. 
If there was anything that I can add to my appeal to challenge what they will say then the time is today!  Or perhaps I already have it covered?  This forum has already advised me that IAS is a kangaroo court so perhaps there is nothing else to add to challenge them.

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Partial quote:
kbr1 - no stopping - Leeds city station  (November 28, 2025 at 07:08:20pm)

Appeal Outcome: Dismissed

The Adjudicators comments are as follows:

The terms of this appeal are that I am only allowed to consider the charge being appealed and not the circumstances of other drivers or other parking events. The guidance to this appeal also makes it clear that I am bound by the law of contract and can only consider legal challenges not mistakes or extenuating circumstances. I am satisfied that the Operator's signage, which was on display throughout the site and seemingly visible in the vicinity of the vehicle, makes it sufficiently clear that the terms and conditions are in force at all times and that a PCN will be issued to drivers who fail to comply with the terms and conditions, regardless of a driver's reasons for being on site or any mitigating factors. While noting their comments, it is clear from the evidence provided to this appeal that the Appellant did indeed stop otherwise than in accordance with the displayed terms as alleged by the Operator. I am satisfied on the evidence provided that the Operator has the authority to issue and enforce PCNs at this site. I am further satisfied as to the location of the contravention, that the correct vehicle has been identified stopped at the time suggested in the images provided and that the correct Appellant is pursued.

I am satisfied that the Operator has proven their prima facie case. Whilst having some sympathy with the Appellant's circumstances, once liability has been established, only the Operator has the discretion to vary or cancel the parking charge based on mitigating circumstances. Accordingly this appeal is dismissed.

As your appeal has been dismissed, the Independent Adjudicator has found, upon the evidence provided, that the parking charge was lawfully incurred.

Yours Sincerely,
The Independent Appeals Service
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Thanks for reading.

I don't think you can submit this.

Comments on the operators evidence can only cover appeal points which have already been made or points which cover the 'changes' which the operator is now trying to make to the NtK.

Other may feel different but I would just make some short simple comments along the lines of;



Comments on operators evidence.

The operator is now changing the nature of the NtK after it was pointed out that the original NtK contained a very serious breach of the operators own Code of Practice - namely; that the original NtK clearly states PoFA Keeper liability when no such liability exists at the location in question.

That the operator is now seeking to circumvent the requirements of PoFA in a desperate attempt to maintain keeper liability in a situation where PoFA cannot apply - the 'reasonable assumption' argument has already been defeated in the Appeal Court - VCS v Edward is the relevant authority in this precise matter - Also, if 'reasonable assumption' could be used in this way then PoFA need not exist - Elliot v Loake has also been mentioned but this is a criminal case and, as such, the case turns on its facts and at no point is 'reasonable assumption' ever mentioned or even implied.

The operator includes a number of pictures from the location but their own evidence shows a further breach of their agreed Code of Practice - Their CoP states that, "Signs and surface markings must be designed, applied and maintained in such a way as to be visible, legible and UNAMBIGUOUS TO DRIVERS." - In this instance the surface markings directly contradict the operators claim that the area is a 'no stopping zone' - the law allows brief stops on double yellow lines - in order to be compliant, double red lines should be used to indicate a no stopping zone - this point is confirmed on the relevant Government website.

The operators behaviour clearly shows the haphazard way that they are running their business - issuing non-compliant NtKs and trying to enforce double yellow lines as if they are double reds are all significant breaches of the CoP.


Many thanks,

xxxxxx xxxxxx

Thank you Intercity125 for such a quick and thoughtful response.
Your kisses brightened up my morning, even though I dont think they were for me, either way it made me smile.

I like your approach and agree that an overall summary of short, simple points is effective in this case because of the changes.  Thank you for adding the second caselaw too

When I appealed first time it was short and simple too and the UKCPS response was short because they could not argue with the content. 

I'm happy to submit this response to Arbitration but I will wait until the 9th to see if if others have anything to add, and to see if they agree that everything is covered in the statement.

e.g. they have changed tack and are now heavily relying on the the Contract thru their signage and sent me 77 photos. Should the high number of photos be mentioned as being the best they have to offer even though they do the opposite and evidence the point in my appeal, not their claim against the driver who is unidentified? 

e.g. they have changed the charge from initial "no stopping" to reason for issue: "the charge is based in Contract".

e.g. I don't really understand the change to non-ANPR now that PoFA has been dropped by them.  Should something be said about it? They have used CCTV to capture vehicle registration and have time stamped the photos of the vehicle to 5 seconds.

Many thanks
xxxxxx xxxxxx

DRAFT reply
7-day deadline.  I am submitting it on 9th February

Not sure of decision:
Counter-respond to UKCPS: ?  (I need to ensure assessor in appeal)
To IAS Arbitration: ? (I need to ensure adjudicator in appeal)
Guessing it is Arbitration - please confirm.

I might use NtK and CPN wrongly...

Lots of wording and layout taken from b789 previous posts to other cases. I hope we haven't used wording not relevant to my case. 

This draft has taken 12 hours with 3 people involved!


Dear IAS Adjudicator,

I am the registered keeper of vehicle [XXXX] and wish to appeal the Parking Charge Notice (PCN) issued by UKCPS based on the following seven grounds:

1. The operator has now changed the PCN because it was not PoFA compliant.
2. The operator has failed to deliver a Notice To Keeper that is PoFA compliant. 
3. The operator has not shown that the individual who it is pursuing is in fact the driver.
4. New claims? (non-ANPR, the charge is based in Contract)
5. Signage and the claim that the charge is based on Contract.
6. No evidence of Landowner Authority - the operator is put to strict proof of full compliance with the IPC Code of Practice.
7. Shambolic operator in breach of Code of Practice of IPS and DVLA.

1. 
UKCPS has changed the PCN since the appellant submitted their appeal to the IAS:

from: PCN: "Notice to Keeper (Postal - PoFA) issued on private land, was sent on 17/12/2025. Reason for issue: no stopping."

to: Prima Facie Case: "The Notice to Keeper (Non-ANPR), was sent on 17/12/2025. The charge is based in Contract."

2.
The Notice to Keeper (NtK) issued by UKCPS fails to comply with the requirements of the Protection of Freedoms Act 2012 (PoFA). UKCPS has already admitted in their correspondence that they are no longer relying on PoFA to establish keeper liability and they have changed their claim. This admission unequivocally confirms that they acknowledge the PCN does not meet the statutory requirements. Therefore, as a matter of law, the operator cannot hold the registered keeper liable for this parking charge.  The appeal must be allowed.

UKCPS changed the PCN:
New claim: "Please be advised that this charge was issued under the site's terms and conditions and not under the Protection of Freedoms Act 2012 (PoFA)."

2.1.  UKCPS has agreed with my appeal. The definition of 'relevant land' was amended by The Protection of Freedoms Act 2012 (Definition of Relevant Land) (Amendment) Order 2025 to include railway land, and this amendment only came into force on 26th December 2025, and is not retrospective. This alleged parking event took place on 10th December 2025, before the amendment came into force. 

3.
UKCPS: "It is a contractual notice directed at the driver of the vehicle for stopping in a prohibited area. Under this framework, liability is assumed to rest with the registered keeper unless evidence is provided to show that they were not the driver".
question - can I say there was no valid contract? does the VCS vs Edward evidence there was no contract or does signage only make the contract?

3.1.  There is no evidence the Keeper was the driver – Keeper Cannot Be Held Liable.
(I found this from b789 for a different case, I have to be cautious because their case involved a parking metre, different to my case)

UKCPS has provided not provided any evidence whatsoever that the appellant was the driver at the time of the alleged contravention. The appeal made it clear that the identity of the driver has not been disclosed, and UKCPS has not disputed this or provided any evidence to the contrary.

3.2.  This leaves the operator with just one legal route: to pursue the registered keeper under Schedule 4 of the Protection of Freedoms Act 2012 (PoFA). However, that mechanism only becomes available if the operator fully complies with every single mandatory condition set out in PoFA.  UKCPS has now confirmed that the initial claim was not PoFA compliant, therefore the UKCPS has no legal route to pursue the registered keeper.  The appeal must be allowed.

3.3.  It is not appropriate to draw an inference that, on balance of probability, the registered keeper was driving on any given occasion. As explained in caselaw VCS v Edward H0KF6C9C [2023], the keeper’s refusal to identify the driver does not permit any assumption of driver identity.  With PoFA compliance withdrawn by UKCPS, the only remaining option would be to prove — with actual evidence — that the keeper was also the driver. They have not done so.  There is no legal presumption that the keeper was the driver. UKCPS has made no attempt to rebut this point, nor have they presented any evidence to support such an inference.    The appeal must be allowed.

3.4.  The UKCPS assessor who is supposedly legally qualified, should have considered, if such an assumption could be made that liability is assumed to rest with the registered keeper, why does PoFA exist?

3.5.  If the owners of the land, Leeds Station, wanted to hold owners or keepers liable under Railway 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 UKCPS is not the station owner and the UKCPS 'parking charge' is not and never attempts to be a penalty.  The appeal must be allowed.

3.6.  IAS is not entitled to make assumptions in the operator’s favour, nor is it permitted to apply a lower evidential threshold than the law requires. Keeper liability only arises if PoFA is complied with. It is not a default position, and it does not arise by implication.  Accordingly, the only lawful conclusion is that UKCPS cannot pursue the appellant as keeper. There is no PoFA compliance, no driver identification, and therefore no legal basis for continuing enforcement of this charge. The appeal must be allowed.
 
4.
UKCPS has changed the NtK - "The Notice to Keeper (Non-ANPR)"
(Note: I don't know what to say about this? Do I need to say something? 
I found some sentences from b789 on a different case involving "paying for parking" (different claim), but it applies to ANPR, not "non-ANPR)
 (is this relevant here? I did not mention this in my appeal):

(found a quote from b789: Strict proof that the enforcement mechanism (e.g. ANPR or manual patrol) is reliable, synchronised, maintained, and calibrated regularly. The operator must prove the vehicle was present for the full duration alleged and not simply momentarily on site, potentially within a permitted consideration or grace period as defined by the PPSCoP). is that the wrong CoP, should it be IPS?

5.
UKCPS claim: "The charge was issued correctly in accordance with site regulations and the IPC Code of Practice and remains valid and enforceable".

5.1.  Signage and the claim that the charge is based on Contract.
The IAS assessor must consider that the initial claim of 'No Stopping' and the new claim of "the charge is based in Contract, a contractual notice directed at the driver of the vehicle for stopping in a prohibited area" are not supported by the road markings which is in direct contravention of the IPC Code of Practice which specifically states: 
"Signs and surface markings must be designed, applied and maintained in such a way as to be visible, legible and UNAMBIGUOUS TO DRIVERS."
The charge has not been issued correctly, it is not valid and it is not enforceable. The appeal must be allowed.
(Note: For a driver to have agreed to any contractual terms, the signage must have been legible, prominently positioned, and capable of being read before entering into a contract = I have left this out???)

5.2.  The IAS assessor must consider the contradictory signage/ road markings.  The driver is stopped briefly on double yellow lines which the law allows - only double reds can mean no stopping.  The appeal must be allowed.

5.3.  The CPN is created for UKCPS’s own profit (as opposed to a bylaw's penalty that goes to the public purse) and UKCPS has relied on contract law allegations of breach against the driver only.

6.
No evidence of Landowner Authority - the operator is to provide strict proof of full compliance with the IPC Code of Practice. 
Flawed Assumption Regarding Signage and Landowner Authority 

6.1.  The operator has provided an undated site plan, the date of July 2025 is in the file name only which can be changed at the users' discretion. (Valid?)

(Note: all wording provided by b789 in another case with edits relevant to  evidence provided to me. I do not know how much of this (if any) applies to me?  I did not cover signage in my appeal, but since then the PCN has changed substantially and is more focused on the Contract now.  All the evidence photos submitted by UKCPS to me for my appeal are dated 24/07/2025 and 27/07/2025. Is this timescale relevant? Because I am raising signage now, do I need to return to the UKCPS (not arbitration?)

6.2.  They have provided signage templates and in location photographs of signage all digitally dated 25th and 27th July 2025, but no photographs showing how the signs actually appeared on-site at or around the date of the alleged contravention on 10th December 2025.

6.3.  There is no evidence the signage was present, visible, or reflected any landowner-approved terms at that time. 
(Note: there is no signage in the photos of my vehicle. They have sent me many generic photos of locations with signage and I do not know how close signage was to my vehicle).

6.4.  They have not shown that the signage was authorised by the landowner, nor that it matched any valid, current agreement. A layout plan that is not dated on the template and file images of signs for a different time period, prove nothing in isolation.

6.5.  It is inappropriate for IAS to assume that signage is valid or authorised simply because it exists. Contracts often remain static while terms change — such as grace periods, charge levels, or maximum stay durations — and if the signage was updated without a revised landowner agreement, then the operator is enforcing terms never approved.  The appeal must be allowed.

7.
Shambolic operator in breach of Codes of Practice
7.1.  By sending me an initial NtK which states PoFA, keeper liability is unlawful in situations where PoFA cannot apply, this is clearly evidence of UKCPS having haphazard methods of running their enforcement operations at this site.  It is totally unprofessional and a breach of their Code of Practice. The appeal must be allowed.

7.2.  The NtK is not supported by the road markings of yellow double lines which is in direct contravention of the IPC Code of Practice. 

7.3.  Further evidence of unprofessionalism and breach of UKCPS: UKCPS has contradicted the DVLA Code of Practice. The IAS assessor must consider that operators are not allowed to claim that they can rely on PoFA in situations where they can not when making requests to the DVLA for the registered keeper's details.  In this case, a parking contravention has not occurred.
question - can I say lack of "reasonable cause" to contact the DVLA?
question - and requesting data when no contract was formed?
question - can they be reported?

8.
In short, I dispute this charge in its entirety, primarily based on the operator not showing that the individual who it is pursuing is in fact the driver.  I require full evidence of compliance with the law, industry codes of practice, and basic contractual principles. (question - is this point only valid for the UKCPS or is it ok for arbitration?) 

If the assessor chooses to overlook these legal requirements and accept vague assertions about no stopping violations and unhelpful dated photographs from the operator, then this will lend further weight to the growing concern that this appeals service is neither independent nor genuinely legally qualified. An erroneous and non valid NtK was issued to me and this case now needs to stop.

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The End
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There must be a lot to correct and improve on this draft.  I hope someone can help.

The UKCPS finish their evidence by stating:

"The charge was issued correctly in accordance with site regulations and the IPC Code of Practice and remains valid and enforceable."

The UKCPS has not dropped the charge.

hi!

Did you see this coming?!!
 
1.
I have got the reply from UKCPS to the IAS.
UKCPS has now changed my charge notice!! 
I was issued with: Notice to Keeper (Postal - PoFA) Issued on private land
They have now told the IAS the charge is not under the Protection of Freedoms Act 2012 (PoFA)! They have changed it to: The Notice to Keeper (Non-ANPR)

Does this mean they are using the change of Law from 26th December 2026?
UKCPS has correctly stated the NtK was issued on 10/12/2026

Well, well, well...!!  BLATANT LYING. 
I'm FUMING AND LAUGHING AT THE SAME TIME.   

Copy and pasted (see this screen shot in the link below)
 ----------------------------------
The operator made their Prima Facie Case on 04/02/2026 14:02:13.

The operator reported that...
The appellant was the keeper.
The Notice to Keeper (Non-ANPR) was sent on 17/12/2025.
The ticket was issued on 10/12/2025.
The charge is based in Contract.

The operator made the following comments...
Please be advised that this charge was issued under the site's terms and conditions and not under the Protection of Freedoms Act 2012 (PoFA). It is a contractual notice directed at the driver of the vehicle for stopping in a prohibited area. Under this framework, liability is assumed to rest with the registered keeper unless evidence is provided to show that they were not the driver.

The charge was issued correctly in accordance with site regulations and the IPC Code of Practice and remains valid and enforceable.
---------------------------------------------------

https://ibb.co/7NJdkCMT  Email from IAS side 1 with instructions
https://ibb.co/Gvwx0Jy5  Email from IAS side 2 with instructions
https://ibb.co/JRy2nzHq  IAS - UKCPS Prima Facie response


2.
UKCPS has also responded with 'more evidence' to the IAS with their Leeds Station Site Images. A total of 77 additional photos all taken on 25/07/2025 (not on the day or month of the charge sent to me). I have saved these in 42 screen shot images. The photos cover: station map of site, signage in various locations, various vehicles parked next to signs or in stopping areas.  For obvious reason, I have not uploaded these images, many random.  People on here already know the signage across the site.


3.
Please, please advise me on wording for a reply.
A.  Jfollows advised above to give a response if they do not respond to the PoFA.  Now they're saying PoFA isn't relevant. 
If this option is advised in preparation for sending to adjudication please ley me know and please help with the response.

B. Or, I could go straight to arbitration.  How can IAS arbitration agree with a change in Law in the Ntk charge?  Surely if the IAS do not drop this charge now, they are also breaking the Law?   
 

I know this isn't relevant, but I like to say it. The UKCPS photo evidence shows that the vehicle was stopped for 5 seconds only and nobody got in our out of the vehicle.

I'm looking forward to reading your responses for my next steps.  Thanks!