I would add a quote to the relevant legislation as well, eg Paragraph 3(1).
Oh sorry I took your original post to mean a quote “to” not “of” the legislation. Thanks for confirming 👍😊
I have adjusted below. I would appreciate you looking over and confirming if this is adequate.
Thanks again 🙏
“I am the registered keeper of the vehicle. I am not obliged to identify the driver and decline to do so.
1. NCP/Times24 cannot hold a registered keeper liable for any alleged contravention on land that is under statutory control. Gatwick Airport is not 'relevant land' as defined in Schedule 4 to the Protection of Freedoms Act 2012 ("POFA").
Specifically POFA 2012 section 3 states:
(1)In this Schedule “relevant land” means any land (including land above or below ground level) other than—
(a)a highway maintainable at the public expense (within the meaning of section 329(1) of the Highways Act 1980);
(b)a parking place which is provided or controlled by a traffic authority;
(c)any land (not falling within paragraph (a) or (b)) on which the parking of a vehicle is subject to statutory control.
NCP/Times24 is well aware that the POFA keeper liability provisions do not apply here, and has no lawful basis on which to pursue the registered keeper.
2. NCP/Times24’s 'parking charge' is not and never purports to be a byelaws penalty, it is a charge created for NCP's own commercial profit. If Gatwick Airport wished to enforce against vehicle owners or keepers under Airport Byelaws, that would be a matter for the landowner alone. NCP is not the airport owner and has no standing to invoke byelaws. Its claim rests solely on alleged breach of contract against the driver, not the keeper.
I ask that you cancel the notice and find in my favour, taking into account all the above “