Free Traffic Legal Advice

This is what I've currently got as a draft for the IAS appeal.

For the questions in the initial part of the appeal, I have answered as follows:

WERE YOU: The DRIVER at the time of the parking event? (please tick): Not prepared to say
The KEEPER of the vehicle at the time of the parking event? (please tick): Yes

Why do you say the parking charge is not payable?

The operator is attempting to rely on keeper liability under Schedule 4 of the Protection of Freedoms Act 2012 (“POFA”). However, the Notice to Keeper does not comply with the mandatory requirements of POFA and therefore keeper liability cannot apply.

Schedule 4, Paragraph 9(2)(a) of POFA states that the Notice to Keeper must:

“specify the vehicle, the relevant land on which it was parked and the period of parking to which the notice relates.”

The notice I received does not specify any period of parking. Instead, it only provides a single timestamp:

“Incident Time/Date: 11:15 16/01/2026”
I have enclosed the notice and highlighted this part of it in red.

A single moment in time does not constitute a period. The combination of a date and instant in time does not constitute a period. Parliament deliberately required the notice to specify a period of parking, which necessarily implies a defined duration with both a start and end. The operator has failed to provide this.

This omission is not a triviality. As you will be aware, compliance with Schedule 4 is a strict statutory requirement if a parking operator wishes to transfer liability from the driver to the registered keeper. Where the statutory conditions are not met, keeper liability simply does not arise.

As the Notice to Keeper fails to specify the period of parking as required by Paragraph 9(2)(a), it is not compliant with Schedule 4 of POFA. Consequently, the operator cannot rely on keeper liability and is out of time to issue a corrected NTK.

The operator is therefore limited to pursuing the driver, who has not been identified. As the keeper, I cannot be held liable for this charge. For this reason alone, the appeal must be allowed.

The operator has failed to consider or respond to any of these points which I raised in my initial appeal and appears not to have even finished writing the appeal rejection notice before printing it and sending it to me.

Not going to hold my breath on a positive response, but keen to engage fully. Hopefully it will cost UKPPO a bit, too; and they can enjoy dealing with it all via post again.

Any feedback/amends appreciated.

Where is the “period of parking”?

See also https://www.ftla.uk/private-parking-tickets/pcn-from-uk-parking-patrol-office/msg105542/#msg105542

Cheers (and thanks for the link), you're quite right that it's simply an instant in time specified on the NTK, rather than a range.

So, standard reply appears to be along these lines:

I am the keeper of the vehicle with registration [REG] and I dispute your 'parking charge', received 27th January 2026. I deny any liability or contractual agreement and I will be making a complaint about your predatory conduct to your client landowner.

As your Notice to Keeper (NtK) does not fully comply with all the requirements of PoFA 2012, you are unable to hold the keeper of the vehicle liable for the charge. It does not specify “the period of parking” as required. This omission renders the notice non-compliant, and as such, the operator cannot rely on PoFA to pursue the registered keeper.

Partial or even substantial compliance is not sufficient. There will be no admission as to who was driving and no inference or assumptions can be drawn. UK Parking Patrol Office 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.

Presumably appealing via recorded post is the method likely to incur UKPPO the most handling fees. Given we're outside the 14 day period now, there's no remedy for UKPPO - right? They're out of time to deliver a fixed NTK.

I will do some digging into who the landowner is; I think a lot of what's near Wembley Stadium is Quintain's.

I'll reply here once the initial appeal has been rejected, assume the next step then may as well be a POPLA appeal.