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Any appeal window has now passed - so Saba won't entertain any (not that they'd have been likely to accept one within the appeal period, but you would've possibly had a shot at POPLA).

The key potential grounds of challenge are:

• That the site is railway land and therefore subject to byelaws. As such, it is not relevant land for the purposes of Schedule 4 of the Protection of Freedoms Act (PoFA), therefore the keeper cannot be held liable
• That the location stated is too vague, so does not specify the land as required by PoFA
• Any meritorious defence you might have - You haven't told us anything about the circumstances. Was there a good reason for the failure to pay for parking?

Running those first two grounds at the same time could provide challenges, as the first argument requires a knowledge of where the incident took place, which could be seen to undermine the argument that they've failed to suitably specify it (although PoFA requires that the notice specifies the land, that the recipient knows where the incident took place does not mean that the notice has specified as such).

You could craft something up along these lines (sharing a draft if you'd like feedback) and send it to Saba. They'll ignore it of course, citing their missed appeal deadline, but it might help to show you know your stuff.

Alternatively, it's a case of waiting to see if they choose to go to court within the next 6 years. I'm not sure how litigious Saba are.

Hi chaps

Currently have received the attached

3rd letter stage now at QDR Solicitors

Read a few threads about Saba and ZZPS and most recommended to ignore or play ping pong to outlast 6 months
Is there any response I can provide at this stage?









Please also find signage pics attached

I've merged this with your existing topic.

What correspondence have you sent to Saba so far (if any)? All of the potential arguments I mentioned in my initial reply remain on the table.

One option here is to write to them explaining that the car park is not relevant land for the purposes of PoFA, being subject to byelaws, and that they cannot recover the charge from you, the keeper. You could then provide the name and address of the driver, noting that even if they otherwise could recover the charge from you as the keeper (which you deny), they still wouldn't be able to as they now know the name and address for service of the driver.

Do show us a draft before sending anything.

Seems fine to me. Although worth noting the point about relevant land becomes moot if they know the name and address of the driver, so that's almost an "even if you didn't know the driver..." type of point.

If you haven't already - it may be wise to make the nomination of the driver directly to Saba.

I'm not sure a response is necessarily required, you've set out your position to them fairly clearly. Just make sure you send the driver nomination directly to Saba, and keep hold of any certificate of posting etc.