Given today’s deadline for paying the reduced £60 charge, I have decided to take my chances with the IAS appeal route, despite appreciating that IAS success rates are generally very low.
I would be grateful for any final comments on the proposed appeal wording below before I submit it.
My intended focus is not that a Blue Badge automatically overrides private parking terms. Rather, the point is that the displayed Blue Badge evidenced disability, and UKPPO appear to have failed to consider any reasonable adjustment under the Equality Act 2010. Their rejection simply stated that the Blue Badge had “no bearing” because the land was private.
Proposed IAS appeal wording:I appeal against this Parking Charge Notice.
The PCN alleges “
Parking in No Parking area” at Stadium Way, Wembley HA9 0EW on 21 June 2026. The operator relies on CCTV stills. The original PCN did not provide photographs of the signage, the wording of the alleged contractual restriction, or any site/location evidence showing how the alleged restriction was brought clearly to the driver’s attention.
The vehicle was parked for less than 10 minutes. The purpose was to allow two disabled passengers to disembark safely and use nearby facilities, including the toilet, before returning to the vehicle. Both disabled passengers are Blue Badge holders. A Blue Badge was displayed in the vehicle. The driver remained in the vehicle throughout.
This appeal is not advanced on the basis that Blue Badge rules automatically override private parking terms. I understand that private land may have its own restrictions. The point is different: the displayed Blue Badge was evidence that the vehicle was being used in connection with disabled passengers, and that reasonable adjustment should have been considered.
The Equality Act 2010 reasonable-adjustment duty requires a service provider, where its provision, criterion or practice puts disabled people at a substantial disadvantage, to take “
such steps as it is reasonable to have to take to avoid the disadvantage”. The duty is therefore not satisfied by simply applying a blanket policy without considering disability-related circumstances.
https://questions-statements.parliament.uk/written-questions/detail/2025-06-05/57793A written
Parliamentary answer dated 12 June 2025 confirms this principle specifically in relation to parking:
“
Both local authorities and private parking operators who provide parking are required under legislation, such as the Disability Discrimination Act 1995 and the Equality Act 2010, to make reasonable adjustments for disabled people and to provide them equal opportunities to access services.”
The same answer also states:
“
Further to this, the single industry code reminds operators of the obligations placed on them by the Equality Act 2010. This is irrespective of contractual changes.”
UKPPO’s rejection letter did not apply that principle. Instead, it stated:
“
Having a blue badge would have no bearing on your visit as the area is private land, any restrictions in place need to be adhered to.”
That is a blanket dismissal of the disability evidence. UKPPO did not consider whether a reasonable adjustment should have been made for a brief period of less than 10 minutes to allow two disabled passengers to disembark, use nearby facilities and return safely, while the driver remained in the vehicle and a Blue Badge was displayed.
The reasonable adjustment sought here is modest and fact-specific: allowing a short period for disabled passengers to safely disembark and return, rather than enforcing a £100 charge rigidly as if this were ordinary unattended parking for general convenience.
UKPPO’s position appears to be that because the land is private, the Blue Badge and disability context are irrelevant. That is wrong. The Blue Badge is not relied upon as an automatic exemption. It is relied upon as evidence of disability and of the need to consider reasonable adjustment.
There is also ambiguity arising from the road layout and markings. The vehicle was parked on double yellow lines in Brent/Wembley. At the time, the driver believed this was an ordinary Brent/public highway location where the displayed Blue Badge permitted parking on double yellow lines. The vehicle was not parked in a marked private parking bay.
This understanding was reinforced by the road layout: opposite, outside the Tesco convenience store, there were clearly marked loading-only bays, which Blue Badge holders know not to use unless loading/unloading applies. The driver therefore deliberately avoided those bays and parked on the double yellow lines.
Double yellow lines have a distinct and well-understood public-highway meaning: they indicate no waiting at any time, but Blue Badge holders may generally park on them for up to three hours unless there is a separate loading restriction. Where Blue Badge parking is not permitted because of a loading ban, that is normally indicated by yellow kerb markings/blips and accompanying signage. No such clear loading-ban marking was relied upon in the PCN.
If UKPPO intended the double yellow lines to convey a materially different private-land meaning — namely, that parking was absolutely prohibited even for a short period for disabled passengers — that distinction needed to be made explicit and prominent. It was not sufficient to rely on double yellow road markings that ordinarily convey a different meaning to Blue Badge holders.
The original PCN did not include photographs of the signage, the wording of the alleged contractual restriction, or any evidence explaining how the restriction was brought clearly to the driver’s attention. UKPPO has also not provided its disabled motorist/Blue Badge policy or any explanation of how reasonable adjustment was considered. In the circumstances, UKPPO has not shown that it properly considered the disability context before deciding to enforce the charge.
The appeal should be allowed because UKPPO failed to consider disability and reasonable adjustment. Its own rejection letter shows that it treated the displayed Blue Badge and disabled-passenger context as having “no bearing” solely because the land was private. That is inconsistent with the Equality Act duty and with the Parliamentary answer confirming that private parking operators must make reasonable adjustments for disabled people.
