To whom is your daughter writing and what is she hoping to achieve? The period for arguing the toss ended 5 years ago. She's now involved in process.
The letter admits the contravention i.e. she acknowledges that parking rights ended at 16.49 and the car left the car park at 17.00. As the judge said in the cited case, it would be wrong to ignore the regulatory framework which controls a claimant's access to keeper data. But I cannot understand your desire to argue what is unarguable, a penalty charge was not incurred until a period of 10 minutes had elapsed after parking rights ended. The framework has been complied with, so what's your point? If you are seeking to differentiate between the parking charge and, dare I say, semantics regarding the notice of the parking charge sent to the keeper i.e. NTK, then be clear
Can you pl assemble the evidence and decide what line to adopt should proceedings commence.
Sorry if this goes against the grain, but evidentially it must surely be the case.