The reply from Northern Trains’ Debt Recovery & Prosecutions Unit (DRPU) is a common attempt to pressure a response from the driver, despite the fact that:
• There is no legal obligation for the registered keeper to identify the driver under Railway Byelaw 14; and
• Liability under the byelaw attaches only to the driver or the owner, not the registered keeper, and ownership must be proven beyond reasonable doubt in a criminal court if they pursue prosecution.
Northern’s response is designed to bait you, the keeper, into identifying the driver or giving “permission” for the keeper to act on their behalf — both of which would compromise your strategic position by effectively admitting driver identity. Do not do either.
Send this (preferably on day 6 or 7) to maintain the timing strategy. Also CC it to yourself:
Subject: Re: Penalty Parking Notice [Insert Number]
Dear Suzanne,
Thank you for your response.
I am the registered keeper of the vehicle and am responding solely in that capacity. I do not intend to identify the driver, nor am I under any legal obligation to do so.
My earlier correspondence stands and was made without prejudice as to the identity of the driver or owner. As no further liability is accepted, and in the absence of any clarification regarding the signage or basis for enforcement, I consider the matter closed unless and until formal proceedings are issued.
Yours faithfully,
[Your Full Name]
Key Points to UnderstandDo not give permission for the DRPU to speak to anyone else "on your behalf". You’re not appealing — you’re responding to a penalty invitation and asserting your rights as the registered keeper, nothing more.
Do not answer their phone number. It's designed to extract admissions or gather evidence. Keep all correspondence strictly in writing.
Byelaw prosecution must be commenced within 6 calendar months of the alleged offence (in this case, by 23 December 2025). Until then, you continue the strategy of delaying without admitting.
They may send further letters or demands. You only need to respond once more, and only if they issue a formal Notice of Intended Prosecution or initiate a Magistrates' Court summons — both of which are rare.
Let me know if they escalate or send another communication.
