Free Traffic Legal Advice

Hi there.
I could really do with your expertise and help on a PCN I have been issued (and am currently appealing against) from Gemini.
This is my first post, so apologies if I break any protocols or miss anything.
Thanks!

Contravention: Parking in a Non-Parking Area
Issuing Company: Gemini Parking Solutions LTD
Date of Contravention: 08/02/2026
Location of Contravention: GLL Crystal Palace / Crystal Palace Sports Centre (London)
Appeal in process: Yes - Initially refused by Gemini - option to proceed with appealing via IAS

Context of Contravention:
I visited the Crystal Palace Sports Centre on a very busy day with lots of fixtures taking place. The concrete car park area was full and many other drivers had parked on a grass area. I assumed this was a temporary way to manage to the volume so I too parked here.
There were no signs indicating that this was not explicitly allowed - only signs relevant to the car park area itself. Access to the area was through an entrance gap in the bollards. There were no signs at this entrance area specifically indicating that this was a no parking area. I returned to my vehicle an hour later just as a Gemini representative was issuing tickets to all the cars on the grass area.

I have gone through the first part of the appeal (which they have refused ) and have copied in my appeal points below (which I formally responded to Gemini with).


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"Dear Sir or Madam,

I am writing to formally appeal the Parking Charge Notice referenced above.

The charge has been issued on the basis that the vehicle was allegedly “not parked in a parking area.” I dispute that any contract was formed or breached for the following reasons.

Firstly, the signage at the exact location I was parked was inadequate, unclear and only positioned for parts of the tarmac parking area. There was no clear signage at the open access entrance to the area I parked on, nor in the vicinity of the grass where the vehicle was parked that stated parking on this area was prohibited, or that a charge would apply. The only visible signage indicated restrictions within the tarmac car park area itself. There were no road markings, bays, barriers, or physical indicators to distinguish this area as restricted and the fact that many other cars were parked there suggested that the grass area may have been available on this day to park on for sports fixtures. A driver cannot be deemed to have accepted contractual terms that were not clearly communicated before parking.

Secondly, the photographic evidence provided does not demonstrate any signage or markings relevant to the alleged contravention. The images merely show the vehicle parked on some grass and do not evidence the existence, visibility, or wording of any terms and conditions applicable to that location or indeed the area that Gemini is contracted over. As such, the evidence you provided fails to support the assertion that the driver was in breach of any clearly displayed contractual terms for the area.

Thirdly, I put the operator to provide strict proof that it has the necessary landowner authority to issue parking charges on the specific area of land where the vehicle was parked (namely a grass area and not the car park). Please provide irrefutable evidence to me that the grass area forms part of the land covered by your enforcement contract and that you are authorised to pursue charges in respect of it.

In the absence of clear signage, defined parking boundaries for the grass area, and proof of landowner authority over the area in question, the Parking Charge Notice has been issued incorrectly and should be cancelled.

Should you choose to reject this appeal, please provide further appeal details and evidence requested so that the matter may be referred to independent adjudication.

I look forward to your confirmation that the charge has been cancelled.

Yours faithfully..."

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What I need help with?
1 - Please can someone help me with understanding if my appeal points are valid and also if they carry enough weight to continue with the appeal?
2 - Gemini has advised that I must continue my appeal with IAS (Independent Appeals Service) - but on even cursory investigation it seems this organisation is biased to the private operator with a low chance of appeal success. Is it even worth carrying on the appeal with them?



Thanks so much in advance for any help!
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Photos provided by Gemini of alleged contravention
https://photos.app.goo.gl/8Hs51oMSH4Hab5ug9

My photos of the signage and area:
https://photos.app.goo.gl/G3wLrwiS5fvyrCqz5

As already indicated, better to take advice then appeal rather than the other way around.

Do you have a NtK or was it purely a windscreen NtD?

NTK = something that's come via the postal system (notice to keeper)
NTD = something that's stuck to your windscreen usually in a cellophane package (notice to driver)

Ah thanks. No it came via email from my company. They received a postal pcn first and digitised it to me.

So it's a company car but you appealed as the registered keeper?