Free Traffic Legal Advice

The driver entered the car park to the leisure centre which they have used regularly before.  The car park allows 3 free hours for customers.  On this occasion the driver was volunteering to help out on football pitches so parked closest to those.
The picture showing a yellow barrier and obsolete booth is the only delineation of the area but neither is ever used.

A PCN has been issued because that area is permit only for JP Morgan staff between the times of 9 - 5.  The driver did not realise that the signs in that part of the car park are different to the first area of the car park (both are shown in pictures)

The close up of the car park shows where the vehicle was parked (blue dot) and the notices in that area (white dots).

A PCN arrived in the post on the 30/11/2025 as my son is the Registered keeper. The Notice has not yet been appealed and I would appreciate any advice.


https://www.imagebam.com/view/ME18H8V8 https://www.imagebam.com/view/ME18H8V9 https://www.imagebam.com/view/ME18H8VA https://www.imagebam.com/view/ME18H8VB https://www.imagebam.com/view/ME18H8VE

What time of day was the vehicle parked there? Can you get some contemporaneous photos (not GSV) of the signs you say are there and the general view showing the layout of the car park and signage location. Also, a phot of the entrance sign.

READ THIS FIRST - Private Parking Charges Forum guide

Posting Images

Just realised Google Street View?

Do you need me to take photos of all the signs in the JP Morgan area? 

It’s a large car park put can try to take photos from the leisure centre which ,at give an overview of the area if that would help?  I will also show a picture of the entrance but I don’t recall any main signage at entrance just the smaller signs scattered around, but will check and send tomorrow as dark now

This is an image of reverse of PCN

https://www.imagebam.com/view/ME18H9XE

If the driver is not identified, then

9(1)A notice which is to be relied on as a notice to keeper for the purposes of paragraph 6(1)(b) is given in accordance with this paragraph if the following requirements are met.

(2)The notice must—

(a)specify the vehicle, the relevant land on which it was parked and the period of parking to which the notice relates;

PoFA 2012 (https://www.legislation.gov.uk/ukpga/2012/9/schedule/4) can not be used to transfer liability from the unknown driver to the registered keeper because, inter alia, no “period of parking” is given in the notice.

I am the keeper of the vehicle and I dispute your 'parking charge'. 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. Horizon 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. Your NtK can only hold the driver liable. UKPC have no hope at POPLA, so you are urged to save us both a complete waste of time and cancel the PCN.

Horizon will reject your appeal “after careful consideration”, meaning the red button, but it’s a process which you must follow and for which you will get further advice here when they do.