Cranbrook Primary School is a community school under the control of the London Borough of Redbridge. It is not an academy or independent school, and therefore its land is under statutory control.
Since Cranbrook Primary School is a local authority-maintained community school, its land is not “relevant land” for the purposes of PoFA. This means the operator cannot transfer liability to the keeper under PoFA Schedule 4.
As CPM is relying on PoFA to pursue the keeper (rather than the driver), their claim is legally flawed. You can challenge the Parking Charge Notice (PCN) on the basis that the land is not relevant under PoFA, and therefore keeper liability does not apply.
The Keeper must always refer to the driver in the third person. No "I did this or that", only "the driver did this or that".
There is no legal obligation on the
known keeper (the recipient of the Notice to Keeper (NtK)) to reveal the identity of the
unknown driver and no inference or assumptions can be made.
The NtK is not compliant with all the requirements of PoFA which means that if the
unknown driver is not identified, they cannot transfer liability for the charge from the
unknown driver to the
known keeper.
I advise you send the following as your appeal from the Keeper:
Subject: Formal Challenge to Parking Charge 70009722 – Invalid Reliance on PoFA
To Whom It May Concern,
I am responding as the Registered Keeper (RK) to Parking Charge Notice 70009722, issued as a Notice to Keeper (NtK) in relation to an alleged contravention on 18 July 2025 at Cranbrook Primary School, The Drive, Ilford, IG1 3PS.
Your NtK explicitly invokes paragraph 9(2)(f) of Schedule 4 of the Protection of Freedoms Act 2012 (PoFA), asserting a right to recover the unpaid charge from the registered keeper. This reliance is legally flawed.
Cranbrook Primary School is a community school under the control of the London Borough of Redbridge. As such, the land on which the vehicle was parked is subject to statutory control and does not meet the definition of “relevant land” under Schedule 4 of PoFA. Keeper liability under PoFA applies ONLY to land that is privately owned and NOT subject to statutory control.
Therefore, your attempt to transfer liability to the keeper is invalid. You are required to cancel this charge immediately. Any continued pursuit of this notice will be considered an attempt to misrepresent legal rights and will be reported to the relevant authorities, including the DVLA and the ICO, for breach of data handling obligations.
I require written confirmation that this charge has been cancelled. No further correspondence will be entered into unless you provide compelling evidence that the land in question is relevant under PoFA—which, given the school's status, you cannot.
Yours faithfully,
[Your Name]
Just be aware that CPM and any other IPC member firm will reject any appeal and the secondary appeal service, the IAS, is also likely to do the same as they are nothing but a Kangaroo court. However, you have to go through the motions.
It will also involve some useless debt recovery letters. Debt collectors are powerless to actually do anything except to try and persuade the low-hanging fruit on the gullible tree to pay up out of ignorance and fear.
The most likely outcome of this will be an eventual county court claim which will never reach a hearing as it would be either struck out or discontinued. Unfortunately, the process is prolonged and will take anything from 9 months to over a year to conclude.
However, if you follow the advice you receive here, you will not be paying a penny to CPM and you are likely to learn a lot about your rights and how to defend them.
