"and now that train operating companies have been advised to instruct their parking operators to issue parking charge notices rather than penalties"
- please could you point me to where this information comes from? Thanks.
If APCOA etc are switching from penalties issued under byelaws (criminal law) to PCNs issued under civil contract law, they will need to change all their station car park signage to make clear that a contract is being created and failure to pay for parking would be a breach of that civil contract etc etc. That change of signage will be expensive and will take a long time!
[Just to reiterate: Only a Magistrate's court can impose a legally binding penalty. In such a court the defendant is innocent until proven guilty. Fines are paid to the Govt, not to APCOA, not to the TOC. The APCOA "penalty" is actually just an offered contract, which means "pay us the £100 and we will then promise not to prosecute you for alleged breach of byelaws". Nobody has any legal obligation to accept an offered contract. So nobody has any legal obligation to pay the APCOA fake "penalty". You are perfectly entitled to go to court, which in the case of APCOA will never happen because they don't litigate].