
I am the registered keeper. APCOA has issued what purports to be a Penalty Notice, but it is impossible for this to be a real statutory penalty. This is a fake penalty and amounts to an unlawful attempt to mislead the recipient into believing that a private company has powers it does not possess. The matter will be reported to Action Fraud for misrepresentation and potential fraudulent demand.
As APCOA will be well aware, Penalty Notices under Railway Byelaws can only be enforced through statutory mechanisms, specifically by laying information before a magistrates’ court. They cannot be enforced through private debt collection or county court action, nor can a private parking company attempt to extract payment by conflating a civil contractual offer with a statutory penalty under criminal law.
If the landowner (Network Rail or the Train Operating Company) intended to enforce Railway Byelaws, that would be within their statutory remit, but that is not what APCOA is doing here. Instead, APCOA has issued a demand for payment designed purely for its own commercial gain while fraudulently misleading the recipient into believing they are liable for a statutory penalty. This is not only a serious misrepresentation of authority, but also an abuse of process.
The registered keeper cannot be presumed or inferred to have been the driver, nor pursued under a fabricated interpretation of agency law. There is no lawful basis for this demand, and APCOA is urged to cancel it immediately. Otherwise, I will escalate this complaint to the relevant authorities, including the British Parking Association, Trading Standards, and Action Fraud.

Subject: Formal Complaint – Fake Penalty Notice GTO0323254A – Criminal Misrepresentation and Extortion
To: APCOA Parking (UK) Ltd
Date: [Insert today's date]
Dear Sir/Madam,
Re: Penalty Notice GTO0323254A – GOVIA THAMESLINK, DORKING STATION (ANPR)
Vehicle Registration: [Insert VRM]
DRP Reference: 14626748
This is a formal complaint regarding your recent conduct and that of your appointed agent, Debt Recovery Plus (DRP), concerning the above matter.
On 12th February 2025, I submitted a detailed appeal as the registered keeper, clearly demonstrating that the document you issued—purporting to be a “Penalty Notice” under Railway Byelaw 14(4)(i)—is a fake penalty. That is to say, it mimics the appearance of a statutory fine but is instead being enforced via unlawful civil channels for your commercial gain, not by way of prosecution under statutory process by a competent authority.
This is not a genuine penalty issued or enforceable under the relevant provisions of the Transport Act 2000 or Railways Act 2005, which require the matter to be laid before a Magistrates’ Court by a prosecuting authority. You are a private company with no such prosecutorial powers, and yet you continue to present these documents as statutory penalties, thereby knowingly misrepresenting your authority and misleading the recipient.
Your subsequent referral of the matter to Debt Recovery Plus, a powerless private debt collector, confirms your intention to extract payment outside of any lawful framework, relying on intimidation, coercion, and misrepresentation.
Let me make this clear:• This is a criminal act.
• It constitutes fraud by false representation, contrary to section 2 of the Fraud Act 2006.
• It also meets the criteria for fraud by abuse of position, and fraud by failing to disclose information (sections 3 and 4).
• You are falsely representing that the recipient is liable for a statutory penalty, when in fact no such liability can arise without due process through the criminal courts.
Your use of DRP as an agent only worsens your position. I regard both APCOA and DRP as active participants in this fraudulent scheme, and both will be named and reported to the police for criminal investigation. This is nothing less than extortion under the guise of enforcement, and it will not go unchallenged.
For the avoidance of doubt, I will not engage with DRP under any circumstances. They are a legally irrelevant third party, incapable of enforcing a statutory penalty. Their threats will be retained as evidence for the police complaint.
Should APCOA fail to respond to this formal complaint and confirm cancellation of this fake penalty within 14 days, I will escalate the matter to:• The British Parking Association, for breach of its Code of Practice and your misuse of debt recovery services in the context of byelaw matters; and
• The DVLA, with a request that your access to registered keeper data be suspended or permanently revoked, due to your abuse of that data in pursuit of unlawful demands.
This is your final opportunity to bring this matter to an end before further regulatory and criminal complaints are lodged. I expect immediate written confirmation of cancellation.
Yours faithfully,
[Your Full Name]
[Your Address]
[Your Email Address]
[Optional: Contact Number]

POPLA Verification Code: [insert code]
Penalty Notice Reference: [insert reference]
Registered Keeper: [insert name if appropriate]
This is a formal appeal against a so-called “Penalty Notice” issued by APCOA Parking. However, it must be made absolutely clear from the outset that this is not a valid Parking Charge Notice (PCN) and not a legitimate Penalty Notice (PN). It is neither.
What has been issued is a deliberately fabricated hybrid document, falsely styled to resemble a statutory enforcement notice. It is designed to deceive, with language and formatting mimicking criminal penalty processes despite carrying no lawful authority whatsoever. It is the product of calculated misrepresentation.
APCOA’s conduct amounts to fraud by false representation, contrary to section 2 of the Fraud Act 2006, and may also engage the offence of blackmail, under section 21 of the Theft Act 1968, by threatening financial harm unless payment is made. This is not a civil contractual dispute. It is a serious and ongoing criminal matter.
Furthermore, APCOA escalated the matter to a third-party debt recovery agent—Debt Recovery Plus Ltd—before the appeal had been concluded. The debt recovery letter is dated 28/02/2025, while the appeal rejection from APCOA is dated 31/03/2025. This chronology clearly shows that the matter was escalated to debt recovery while the appeal was still under consideration, which is a direct breach of Section 10.1 of the Private Parking Single Code of Practice (PPSCoP). That section states clearly that debt recovery must not be initiated until the appeals process has concluded. This also puts APCOA in breach of its KADOE contract with the DVLA, as the Keeper's data has been misused to support unlawful processing.
Additionally, the Keeper was not the driver, and since the land in question is subject to statutory control (railway land), PoFA 2012 does not apply. Therefore, no liability can be transferred to the Keeper.
It is important to reiterate that this is not a generic scam. It is a deliberate and unlawful act by a well-known company in the parking industry. A document falsely labelled as a Penalty Notice, containing legalistic threats and a demand for payment, was issued without statutory authority. This is a textbook example of fraud by false representation, and potentially blackmail, due to the misuse of process and threatening tone of correspondence issued with no lawful basis.
Should POPLA proceed to assess this appeal, it must be understood that it would be acting entirely outside its lawful remit, which is confined to the assessment of civil Parking Charge Notices issued under contract law. POPLA has no legal authority to adjudicate on a matter that concerns criminal conduct or the misuse of a fraudulent legal instrument.
While POPLA does have the authority to instruct the operator to cancel the charge—and it is submitted that you should do so without delay—this in itself will not prevent the appellant from pursuing the matter as a criminal breach of the Fraud Act 2006. Cancellation does not erase the fact that a fraudulent document was issued with intent to mislead, nor does it absolve any party who, once aware of the fraud, chooses to engage with it as though it were a legitimate civil matter.
POPLA has now been placed on notice that the charge is not a lawful Parking Charge Notice under contract law, nor a statutory Penalty Notice under any applicable legislation. If POPLA proceeds to assess this case or purports to validate or legitimise the charge in any way—despite knowing it to be fraudulent and beyond POPLA’s jurisdiction—then it risks becoming complicit in the offence, either by aiding and abetting, or through reckless indifference to the legal status of the charge.
Even if POPLA now instructs the operator to cancel the charge, its involvement up to this point may still be viewed as complicity by association, particularly if it continues to process similar fraudulent charges in future. That position will be brought to the attention of the authorities, and the appellant reserves the right to pursue the matter further on grounds of complicity in fraud and unlawful processing of personal data.
Yours faithfully,
[Your name]


? You must make yourself clear and understood for heavens sake!!! Show it to us!!!!

