I responded to the NtK with:
I am the registered keeper and I dispute these parking charges. I deny any liability and no admission is made as to the identity of the driver.
The Notice to Keeper fails to comply with Schedule 4 of the Protection of Freedoms Act 2012 and therefore cannot transfer liability to the keeper. The NtK does not specify any “period of parking”, relying instead on single timestamps. A timestamp is not a period. This omission is fatal to any attempt to transfer liability to the keeper. Keeper liability does not apply.
Multiple PCNs have been issued for the same stationary vehicle over consecutive days 3002460480115,3002460490126,3002460500130. There is no evidence of the vehicle leaving and returning. This constitutes a single, continuous event, and the issuing of multiple charges is an unreasonable and punitive attempt to recover multiple sums for the same alleged contravention. The signage does not state that charges apply per day or per 24-hour period.
Further, the NtK fails to clearly specify the relevant land. The location details are inconsistent and ambiguous:
The street is stated as “Cottrells,” which does not exist as a legitimate street name. The closest match is Cottrell St (West Bromwich). The postcode (HP1 1JZ) corresponds to different locations including Hemel Hempstead Town Cricket Club and Station Road. Together, not a single identifier points to the same 'relevant land'.
There are too many conflicting identifiers resulting in multiple, inconsistent location references. These discrepancies fail to identify a single, clearly defined location, and the NtK is therefore non-compliant.
The vehicle was parked in a space associated with a residential property, advertised as including parking. This establishes a tenant pre-existing right to park, which cannot be overridden by a third-party operator’s signage.
UKPC has relied on contract law allegations of breach against the driver only. For all the above reasons, these charges must be cancelled.
