Hi, I have used the template wording as part of my appeal and some further wording.
https://i.postimg.cc/FKTTRf34/Parking-redacted.pngI dispute your 'parking charge'. I deny any liability or contractual agreement and I will be making a complaint about your predatory conduct to your client landowner.
As your Notice to Keeper (NtK) does not fully comply with ALL the requirements of PoFA 2012, you are unable to hold the keeper of the vehicle liable for the charge. Partial or even substantial compliance is not sufficient. There will be no admission as to who was driving and no inference or assumptions can be drawn. ECP has relied on contract law allegations of breach against the driver only.
The registered keeper cannot be presumed or inferred to have been the driver, nor pursued under some twisted interpretation of the law of agency. Your NtK can only hold the driver liable.
Further information attached:
I write this notice on behalf of the registered keeper, this is the first notice that has been received and does not comply with PoFA Schedule 4, paragraph 9(5) which means any Ntk should have been delivered within 14 days.
ECP have provided no photos nor evidence of parking and therefore there is no case to answer.
The car park referred to provides free parking for 3 hours, a charge of £100 for overstay as claimed by 20 minutes is wholly disproportionate.