Free Traffic Legal Advice

2 minutes is not generally regarded as a sufficient time to establish contract.

Yes, neither the parking company nor the IAS are likely to agree, but it should be a decent argument should a court claim result.

No harm in trying to beef your argument up somewhat - are you close enough to be able to acquire photos of the signage at the site?

Although maybe park elsewhere if travelling by car 

Is this a follow up to a ticket on the windscreen. ANPR NTKs generally have an entry and exit image, a single image like that suggests a foot patrol. If so the 2 minutes may be an observation rather than parking duration.

The latest joint code does allow zero length consideration periods in specific situations like no stopping zones, although it would be interesting to see how a PPC argues a valid contract was formed regardless of the CoP.

If so the 2 minutes may be an observation rather than parking duration.

I don't think that would change the argument - on the face of it an observation period of 2 minutes is not long enough to ascertain or demonstrate that the vehicle was parked for long enough for a contract to be formed.

Although if I were a betting man I'd wager the image on the PCN comes from CCTV footage, NPM often use CCTV to enforce.

I used the following template to appeal:

FINAL KEEPER APPEAL (CONSIDERATION PERIOD / NO CONTRACT)

Subject: Appeal as Registered Keeper – PCN [PCN NUMBER] – VRM [VRM]

Dear National Parking Management Ltd,

I am the registered keeper of vehicle [VRM]. I dispute Parking Charge Notice [PCN NUMBER] and require it to be cancelled.

1) No contract formed, the vehicle was present for less time than required to read the terms

Your Notice alleges a contravention period from 13:11:02 to 13:13:34, a total of 2 minutes 32 seconds.

I have since returned to the site and timed the reading of the signage in full. Reading the signage properly, in its entirety, takes approximately 3 minutes 31 seconds.

It is therefore impossible for a driver to:

locate the signage,

read and understand the terms in full,

and accept any contractual offer,

within the 2 minutes 32 seconds alleged.

A contract cannot be formed unless the terms are clearly brought to the driver’s attention and the driver has had a reasonable opportunity to read and consider them before acceptance. On your own timings, this was not possible. No acceptance occurred and no contract was formed.

2) The alleged duration is a reasonable consideration period

A presence of 2 minutes 32 seconds is entirely consistent with a driver:

entering the site,

locating signage,

attempting to read the terms,

and deciding whether to remain.

This is a classic consideration period, not a parking event. Charging £100 for a duration shorter than the time required to read the terms is neither reasonable nor enforceable.

3) “No valid e-permit” presupposes acceptance of terms

Your allegation of “No Valid E-permit” presupposes that the driver:

read the terms,

understood the e-permit requirement,

and accepted a contractual offer.

Given that the signage cannot be read in full within the time alleged, that presupposition fails. Without acceptance, no permit obligation arises.

4) CCTV evidence does not establish acceptance of contractual terms

I note that the evidence relied upon appears to be derived from CCTV footage rather than still-image timestamps.

CCTV evidence can show only presence and movement within the site. It does not establish that the driver:

read or understood the signage,

accepted any contractual offer,

or parked in circumstances capable of creating contractual liability.

Contractual acceptance requires conduct that objectively demonstrates agreement to the terms. A brief presence on site, captured on CCTV, does not meet that threshold. CCTV evidence therefore cannot establish acceptance of terms or the formation of a parking contract, particularly over a duration of 2 minutes 32 seconds, which is shorter than the time required to read the signage in full.

Accordingly, the CCTV evidence relied upon does not prove the alleged contravention.

5) Keeper liability is denied

I am the registered keeper. I am under no obligation to identify the driver and will not do so. You must therefore rely strictly on full compliance with Schedule 4 of the Protection of Freedoms Act 2012, which is denied. Any failure prevents keeper liability from arising.

6) Requirement to cancel or provide evidence

Given that the alleged contravention period is shorter than the time required to read the signage, this charge is not recoverable and must be cancelled.

If you reject this appeal, please provide:

All photographs relied upon, in full resolution with metadata

A site plan and contemporaneous photographs of all signage, including wording and placement

Your written landowner authority to issue and enforce charges at Bradford on Avon Health Centre

Any rejection must include confirmation of the IAS process.

Please cancel the Parking Charge Notice.

Yours faithfully,
[Your full name]
Registered Keeper of [VRM]
[Address]

And have now had this response.  The appeal has been rejected, unsurprisingly.

Dear Mrs XXXXXX,
Re: Parking Charge Reference XXXXX (Vehicle: XXXXX)
Contravention: No Valid E-permit / No Valid E-permit
Contravention Date: 28/12/2025 13:11:02
Issue date/time: 31/12/2025 07:33:53
Site Name: Bradford on Avon Health Centre
Town/City:Bradford on Avon
Postcode: BA15 1DQ

Thank you for your appeal received on 13/01/2026 regarding the above parking charge reference. The appeals
team have reviewed the case and considered the comments that you have made.

This appeal has been considered in conjunction with the multiple date/time stamped pictures gathered at the time
of event, along with any applicable comments from the enforcement team, weighted against any relevant and fully
substantiated mitigating circumstances that may have been supplied with this appeal.

Reason for issue: No Valid E-permit / No Valid E-permit

It’s important to understand that that parking on private land that is contracted to and managed by National
Parking Management (NPM) is not a right, its conditional, the (T&C’s) apply to all users of the site and are fully and
clearly displayed on the parking signs (“The Parking Contract”).

Whilst a consideration period is typically afforded to the driver to read the parking T&C’s sign they must either
comply with the T&C’s or remove the vehicle from site, a grace/consideration period is not a free parking period
and will not apply if the driver is making use of the land, in addition choosing to not read the T&C’s of parking is not
considered a mitigating circumstance it’s a choice.

National Parking Management Limited (NPM) is a business registered in England & Wales (08237818)
Registered Office: 95 Arundel Road, Worthing, BN13 3EU
Telephone: 0330 043 0342
Website: www.npmservices.co.uk
When the driver decided to park and/or remain on the contacted land (“The Site”) whilst failing to comply with the
clearly displayed T&C’s the driver automatically entered into a contractual agreement with NPM and agreed to pay
the amount stated on the parking contract to The Creditor (NPM).

The driver did not have a valid E-permit for the duration of the parking session (No E-Permit) and therefore parked
in direct contravention of the clearly displayed terms and conditions.

The appeals team are writing to inform you that the appeal has been unsuccessful. The driver failed to park the
vehicle in accordance with the clearly displayed T&C’s, additionally the appellant has failed to substantiate and/or
provide sufficient evidence to the contrary.

As you have declined to nominate a Driver, the named Keeper remains liable for payment of this Parking Charge.
The internal appeals team find this parking charge to be issued correctly, we must advise you that once the
discounted settlement rate (if applicable) passes it will not be offered again, you have now reached the end of our
internal appeals procedure. You may now either pay the amount due OR appeal further with the Independent
Appeals Service.

If you still believe that the parking charge was issued incorrectly, then you may appeal further to the Independent
Appeals Service (IAS). You must submit an appeal directly to them online using the following link:
https://www.theias.org/appeal

If you wish to appeal to the IAS, you should ensure to do so within 28 days of the date of this letter.
Please note, that should you choose to use the IAS, you will automatically lose the opportunity to pay the
discounted rate of the charge. If you appeal to the IAS and then subsequently pay the charge prior to the appeal
being determined, then the appeal will be cancelled, and you will not be given a further opportunity to contest this
charge.

If you are not appealing to the IAS, you are now required to make a payment of £60 to reach us by 03/02/2026 or
£100 to reach us by 17/02/2026 to avoid this charge being passed on to a debt resolution firm, and/or to avoid
county court proceedings. Please be advised that any further action will incur additional costs.
Payments can be made using a debit or credit card calling the automated payment line on 0333 023 6890 or
paying online at www.npmservices.co.uk please note NPM do not accept American Express (AMEX), the payee
will need the parking charge reference number and the vehicle registration mark (VRM) to use the digital payment
services.

Alternatively, payments can be made by cheque or postal order made payable to National Parking Management
Limited, it is recommended that all post is sent recorded delivery to the following address:
Payment Processing Department
National Parking Management Limited
95 Arundel Road
Worthing
West Sussex
BN13 3EU

Please ensure you write the parking charge reference number and vehicle registration clearly on the reverse, it is
advised that you do not send cash through the post, all postal payments that arrive be checked and verified
against the date of sending on the envelope.

Please note that we are unable to take telephone conversations regarding appeals.
The internal appeals process is full and final, and we are unable to issue any further correspondence regarding
this matter.

Yours sincerely,
Appeals Department
National Parking Management Ltd.

_________________

I think the following is telling:

Whilst a consideration period is typically afforded to the driver to read the parking T&C’s sign they must either
comply with the T&C’s or remove the vehicle from site, a grace/consideration period is not a free parking period
and will not apply if the driver is making use of the land, in addition choosing to not read the T&C’s of parking is not
considered a mitigating circumstance it’s a choice.

I argued that 2 mins is not not sufficient time to read the signage, but they have CCTV evidence that will show that there was no attempt to read the signage.

Is this worth fighting further?

TIA
Stu

ok, in for a pennie in for a pound.
What next?  Do I just wait and hope it goes away or do I need to do something more formal?