Author Topic: PCN - School Car Park Over Stayed without Registering.  (Read 12037 times)

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Re: PCN - School Car Park Over Stayed without Registering.
« Reply #15 on: »
Also I know it stated taht most of these will eventually have some form of debt letter then fail to go through to County Court, however I've just seen a post that's before mine for 'Gladstones' where OP states they've received a County Court Claim from Euro Parking Services Limited :O and it totals £257.50 - So worst case scneario I could end up having to may a similar amount if I am unable to fight the final stage at county court?

Re: PCN - School Car Park Over Stayed without Registering.
« Reply #16 on: »
Also I know it stated taht most of these will eventually have some form of debt letter then fail to go through to County Court, however I've just seen a post that's before mine for 'Gladstones' where OP states they've received a County Court Claim from Euro Parking Services Limited :O and it totals £257.50 - So worst case scneario I could end up having to may a similar amount if I am unable to fight the final stage at county court?

Just because a claim is issued does not mean that it will ever get as far as a hearing. These companies all rely on you being low-hanging fruit on the gullible tree who can be intimidated into paying up out of ignorance and fear. Unless you understand their modus operandi and your lawful rights like we do, then good luck to you.

As long as you don’t identify the driver they can’t use PoFA 2012 as they continue to claim.

If at any point I am asked if I was the drive, would that mean one has to say no or decline to comment, ie nor confirm nor deny?

There is no legal obligation on the Keeper to identify the driver to an unregulated private parking firm. There is no need to lie either. All you do is refer to the driver in the third person. No "I did this or that", only "the driver did this or that". Understood?

If the operator is unable to rely on PoFA to transfer liability from the unknown (to them) driver to the known Keeper, the burden of proof is on them, not you. How do you imagine that can prove you were the driver if you decline to assist them by identifying the driver for them?

I have just submitted the following FoI request to foi@redbridge.gov.uk

Did you ever get anything back from the FOI request for this?

Yes, and it was a non answer which I have complained about and asked for a review:




And my response, to which they have not yet replied:

Quote
Subject: Request for Internal Review – FOI Ref: 29095861

Dear FOI Team,

I am writing to request an internal review of your response to my Freedom of Information request regarding the contracting of UK Car Park Management (UKCPM) at Cranbrook Primary School.

Your reply stated that the information I requested is not held by the London Borough of Redbridge and advised me to contact the private parking firm directly. I believe this response is inadequate for the following reasons:

1. Failure to confirm land ownership and delegation
Even if the Council does not hold the UKCPM contract itself, you are still able – and obliged – to confirm whether the land in question is Council-owned or controlled, and if so, whether any delegation has been granted to the school governing body to enter into such arrangements. This is relevant context squarely within the scope of my request.

2. Duty to advise and assist (s16 FOIA)
The Section 45 Code of Practice requires public authorities to advise and assist applicants. Directing me to contact a private company that is not subject to FOIA does not satisfy this duty. You should instead have identified or signposted the correct public body likely to hold the requested information – in this case, the governing body of Cranbrook Primary School – or considered whether a transfer under FOIA was appropriate.

3. Incomplete handling of the request
My request covered not just the specific contract with UKCPM but also any agreements, delegations, or authorisations by the Council concerning parking enforcement at this location. These are matters the Council is in a position to confirm.

I therefore request that the internal review addresses:

• Whether the land at Cranbrook Primary School, including the car park, is owned or controlled by the Council.

• Whether the Council has delegated authority to the school governing body to enter into parking enforcement arrangements.

• Whether the Council holds any records, correspondence, or authorisations relating to the introduction of private parking enforcement at this site.

• Proper signposting or transfer to the public body that does hold the requested contract (likely the school/governing body).

Please ensure this review is conducted in line with the FOIA Code of Practice and completed within 20 working days.

Yours sincerely,

B789

For now, you can submit the following as your IAS appeal (for what it's worth):

Quote
This appeal addresses the operator’s rejection and explains why this PCN cannot lawfully be enforced.

1. Keeper liability cannot apply (land is not “relevant land”)
Under PoFA Sch 4 para 3(1)(b), a parking place provided or controlled by a traffic authority is excluded from “relevant land.” Para 3(2) defines a traffic authority to include a London borough council. Cranbrook Primary School is a community school on land owned and controlled by the London Borough of Redbridge. Control therefore rests with a traffic authority, excluding the site from relevant land. In the alternative, para 3(1)(c) excludes land where parking is subject to statutory control; this site is governed under the Education Acts and controlled by a London borough exercising statutory powers. PoFA keeper liability cannot arise on this land.

2. Standing not evidenced (PPSCoP §14)
The operator refuses to disclose the landowner agreement yet relies on it to found authority. PPSCoP §14.1(a)–(j) requires written confirmation from the landowner covering identity, boundary plan, applicable byelaws, permission and duration, applied terms, method of issuing charges, responsibility for consents, Code-compliance obligations, documentation to be supplied on request, and approach to appeals. These are core standing documents. Redactions for pricing are acceptable, but the authority clauses, boundaries, byelaw status, scope/duration, operative terms, and method of charge must be evidenced. Absent this, standing is not proven.

3. Contravention not proven: ANPR and “37 minutes”
ANPR records site entry/exit, not a period of parking. The operator must evidence a period of parking and also demonstrate compliance with consideration and grace periods required by the PPSCoP. Strict proof is required of ANPR reliability, maintenance, calibration, and clock synchronisation, and (if relevant) patrol notes. None has been produced. Assertions are not evidence.

4. “No permit found” requires strict proof
If relying on a permit system, strict proof is required of the audit trail: the query performed, timestamps, system clock synchronisation with ANPR, and the data extract showing no valid permission at the material time. A generic “no permit found” statement is insufficient.

5. NtK service and PoFA compliance (only if PoFA is claimed)
If the operator seeks to rely on PoFA notwithstanding point 1, strict proof is required of a fully compliant NtK (including para 9(2)(a), 9(2)(e), 9(2)(f)) and proof of posting/service within the relevant period (PPSCoP 8.1.2(d) Note 2 requires a record of the date of posting, not merely the date of generation or consolidator handover). No such proof has been provided.

6. Annex F “Appeals Charter” is irrelevant to liability
Whether the case falls within Annex F does not determine enforceability. Liability depends on (i) applicability of PoFA, (ii) operator standing, and (iii) proof of contravention with compliant evidence. None is satisfied here.

Conclusion
Because the site is not relevant land, PoFA keeper liability cannot arise. In any event, the operator has not proven standing under PPSCoP §14, has not proven a period of parking or ANPR reliability, has not strictly proven the “no permit” allegation, and has not proven NtK service/compliance if they seek to rely on PoFA. The PCN should be cancelled.
« Last Edit: September 25, 2025, 01:36:25 pm by b789 »
Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain

Re: PCN - School Car Park Over Stayed without Registering.
« Reply #17 on: »
Thank you for your details reply and assistance, unfortunately I replied yesterday as I was worried yesterday was the last day to appeal, I used the same reason you provided at the start, as I did in the first appeal.

The additional reasons you have mentioned in the previous post give much more of a defence, although confident IAS will just discard and ignore still. Unfortunately I am unable to add or update according to the IAS appeal process, that once submitted nothing can be added to it after, which is a shame :(

Also a shame the council have not provided the information requested as it would have helped.. If the land is council owned/controlled, however a delegation was/is provided to to the governing body to give permission to the parking operator, then I guess I have no leg to stand on?
« Last Edit: September 26, 2025, 12:02:47 am by LondonTraveller84 »

Re: PCN - School Car Park Over Stayed without Registering.
« Reply #18 on: »
Actually, I may have one chance to still respond, although I will have to wait for the operator to reply first, to which I can provide a response, below extract from the IAS email received following the submission

Your appeal has been sent to the parking operator so that they can provide their account.

The Parking Operator is now provided 5 working days to upload sufficient evidence to show that you are liable for the charge.

Once they have submitted their evidence you will be able to log in and see it. You will then have 5 working days to respond in one of TWO ways:

1) SUBMIT YOUR APPEAL - You can respond to the evidence by making any representations that you consider to be relevant as to the lawfulness of the charge any by uploading any photographs or other evidence that you may have. Once you submit your response it will go back to the operator who may wish to respond or send the appeal straight to arbitration. In the case of the operator responding, you will receive another chance to respond.

- OR -

2) REFER THE CASE STRAIGHT TO ARBITRATION - If you consider that the information provided is not capable of showing that you are, on the face of it, responsible for the parking charge, then you may choose this option. The Adjudicator will assess the evidence provided by the operator and appellant. You will not have the opportunity of making representations and the Adjudicator will decide, on the balance of probabilities, whether you are liable for the parking charge.

Re: PCN - School Car Park Over Stayed without Registering.
« Reply #19 on: »
What are you talking about not having a "leg to stand on"? You are assuming that the IAS is anything but an incestuous firm of corrupt and mendacious scammers. If the IAS do not uphold your appeal, so what? They are a kangaroo court and their decisions are not binding on you and have absolutely no bearing on anything going forwards.

The very simple fact is that without the drivers identity, they don't have a "leg to stand on" if this were to ever reach a hearing in the small claims court. The simple fact is that PoFA does not apply. The driver is not identified. Liability for the charge cannot be transferred to the Keeper. End of!
Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain

Re: PCN - School Car Park Over Stayed without Registering.
« Reply #20 on: »
So they had offered me a reduced charge of £20 dropped from £100, which I had not seen, as I did not check my emails in time. They have now officially responded with the below

"The operator made their Prima Facie Case on 30/09/2025 09:45:17.

The operator reported that...
The appellant was the keeper.
The operator is seeking keeper liability in accordance with PoFA..
ANPR/CCTV was used.
The Notice to Keeper was sent on 22/07/2025.
A response was received from the Notice to Keeper.
The ticket was issued on 18/07/2025.
The Notice to Keeper (ANPR) was sent in accordance with PoFA.
The charge is based in Contract.

The operator made the following comments...
The appellant has been captured by ANPR entering and leaving the car park.

The vehicle was at the car park for 37 minutes, evidence of this can be seen in the attached document '70009722'.

The appellant has parked within the car park and did not register their vehicle.

Signage clearly states "MOTORISITS MUST REGISTER WITH A VALID E-PERMIT OR HAVE A VALID EXEMPTION BY ENTERING THEIR FULL, CORRECT VEHICLE REGISTRATION INTO THE KIOSKS LOCATED WITHIN THE RECEPTION AREAS OR BE REGISTERED VIA SIPPI".

Please be advised, physical permits are not currently in use at this location. Our records indicate that vehicle registration GK16BKY was not registered on the E-Permit system, however other vehicles are registered on the E-Permit system on the date of contravention. This can be seen in the attached document '70009722'.

The signage is clear within the area and states the terms and conditions for parking. It is the driver's responsibility to ensure they register their vehicle. This is the only way we can determine which vehicles are authorised to be parked within the restricted area.

The Appellant accepts that they were the registered keeper of this car at the time of this incident but has not been prepared to identify the driver. The provisions of the Protection of Freedoms Act schedule 4 enable the Parking Operator to recover against the keeper if they fail or refuse to name the driver.

Please be advised that, in accordance with the Single Code of Practice, the appellant was offered a reduced payment of £20 as a gesture of goodwill. However, as this offer has not been accepted, the full amount of £100 is now due.

We note your point that the primary school car park is managed by UKCPM (UK Car Park Management). We write to clarify our position, and confirm that despite UKCPM being the operator, the legal basis upon which liability is sought remains governed by the Protection of Freedoms Act 2012 (“PoFA”), including its Schedule 4 — specifically paragraph 9(2)(f) — under which a registered keeper can be held liable if the driver cannot be identified.

Under Schedule 4 of PoFA, keeper liability only applies if the land is “relevant land.” The definition of “relevant land” excludes, among other things:

Highways maintainable at public expense;

Parking places provided or controlled by a traffic authority;

Any land on which parking of a vehicle is subject to statutory control.
GOV.UK

Legislation.gov.uk

We assert that Cranbrook Primary School car park, though managed by UKCPM, is not under statutory control (nor a public highway, traffic authority controlled parking place, or otherwise subject to byelaws or similar). Therefore, we consider it “relevant land” under PoFA. This allows us to lawfully issue a Notice to Keeper and seek liability under paragraph 9(2)(f) in absence of driver identification.

Management of a car park by a private operator (UKCPM) does not in itself change the nature of the land for the purposes of PoFA. What matters is whether statutory control or public authority control is present. Being a private operator contracted to manage the parking does not remove the land from being “private relevant land” if all criteria are otherwise satisfied.

For keeper liability to be valid, certain procedural requirements must be satisfied under PoFA (e.g., signage, Notice to Driver (if applicable), timely Notice to Keeper, etc.). We believe these have been met in your case. If you have evidence disputing any of them (for example, that signage was inadequate, or that the Notice to Keeper was not issued within the required timeframe), we invite you to provide that, and we will review.

By the appellant parking at the restricted area, they have contractually agreed to pay the parking charge notice"


Ive tried to get my head around what they've said about the PoFA but am a bit brain fried from driving 8 hours.. But they see this as relevant land - Await to get your take on their response and the reply if any I should submit.
« Last Edit: September 30, 2025, 10:23:25 pm by LondonTraveller84 »

Re: PCN - School Car Park Over Stayed without Registering.
« Reply #21 on: »
Respond to their prima facie evidence with the following which you can copy and paste verbatim:

Quote
Response to the operators prima facie evidence/case:

1) No keeper liability: this is not “relevant land” under PoFA – and in any event PoFA has not been strictly complied with:
Maintained school = public authority site. Cranbrook Primary is a maintained (community) school of the London Borough of Redbridge. The premises are under public authority control and occupation. Private parking firms don’t magic that into “private relevant land” by stapling on a services contract. PoFA Schedule 4 excludes land where parking is “subject to statutory control”. School sites sit within the Council’s statutory framework and governance; any parking arrangements/authorisations arise from (and are constrained by) public law duties, not private whim.

Your “no TRO, therefore relevant land” line is garbage. The absence of a TRO doesn’t prove relevance. “Statutory control” in PoFA isn’t limited to TROs or byelaws. Show contemporaneous documentary proof that, on 18/07/2025, this site wasn’t (a) owned/controlled by the local authority for the purposes of education; (b) managed by or on behalf of that authority; and (c) regulated under any statutory framework/policy that governs use of school premises (which it is). You’ve produced nothing—just assertions.

Burden of proof is yours. If you want to rely on keeper liability, you prove relevance with evidence, not bluster. That means:
• Land status/ownership (Land Registry or Council confirmation);
• The governing body/LA delegation showing who controls parking and under what statutory footing;
• A positive statement (with citations) that the parking of vehicles at this location is not subject to any statutory control/policy/instrument on the material date.

You’ve filed zero of the above. Keeper liability fails at the starting gate.

Even if (which is denied) this were relevant land, PoFA still isn’t met. You haven’t exhibited the NtK or walked the assessor through strict Schedule 4 compliance. Fail any of these and keeper liability is dead:
• 9(2)(a): A period of parking (ANPR entry/exit ≠ parking period).
• 9(2)(b)–(d): Circumstances/charge/when payable (exact statutory content).
• 9(2)(e)(i): The invitation to the keeper (correct wording).
• 9(2)(f): The warning of keeper liability after 28 days (correct wording).
• 9(2)(h): Creditor identity (who is the creditor?).
• 9(2)(i), 9(5): Service within the relevant period and proof of posting (PPSCoP 8.1.2(d) Note 2 = record of date of posting, not just “generated”).

You’ve dumped a narrative and hid the paperwork. That’s not compliance.

Your boilerplate about PoFA 9(2)(f) is meaningless without the actual notice. Put the full NtK in evidence and point to the precise lines that meet each statutory limb—or stop pretending you’ve established keeper liability.

Reality check for the IAS: an assertion that “this is relevant land” is not evidence. If the IAS is prepared to accept keeper liability on a maintained school site without hard proof of relevance and without line-by-line PoFA compliance, then you’re not applying PoFA—you’re just waving it around.

1) 30-minute site concession + mandatory 10-minute end-of-parking grace (PPSCoP 5.2) = still no breach
Your own numbers now say 37 minutes on site. This location runs a 30-minute drop-off/collection concession. Under PPSCoP 5.2, when a permitted period ends the motorist must be given a minimum 10-minute grace period to leave—unless this is a genuine “short stay area” where parking is never allowed for more than 30 minutes for anyone. It isn’t.

Not a short-stay zone, so Note 2 doesn’t apply. This site’s normal regime allows longer stays via Sippi/e-permit (selecting up to 12 hours for £0.00 has already been documented). A car park that routinely permits multi-hour stays is by definition not a Note-2 “short stay area”. So the 10-minute end-of-parking grace applies.

Concession = permitted time. The 30-minute drop-off/collection is an express permission the site advertises. It’s part of the terms. The grace sits on top of that permitted time. Maths even the IAS can follow: 30 + 10 = 40 minutes before any charge can lawfully be triggered.

Your figure buries your own case. You now claim 37 minutes total. That’s within the 40-minute allowance. End of story: no contravention on your own evidence.

If you want to wriggle out of your own concession, prove it. Produce dated, contemporaneous signage and policy for 18/07/2025 showing (a) the 30-minute concession didn’t apply on that date or (b) this site was operating as a true Note-2 short-stay area with a universal ≤30-minute max stay. If you can’t, you don’t get to pretend the concession vanishes when you fancy issuing a PCN.

Ambiguity = your problem. Any fuzziness in your signs or “policy” about when the concession applies is construed against you. You drafted it; you live with it.

Bottom line: 37 ≤ 40. Your own timing nukes the charge.

This PCN has been issued incorrectly and must be cancelled.
Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain
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Re: PCN - School Car Park Over Stayed without Registering.
« Reply #22 on: »
Hey!

Wow! that response looks epic and should make the other party cry and give up,  I forsee them ignoring any valid reason given (based on my many interactions with councils, I assume these guys would be the same if not worse)

1. I went to the school and took a photo of the signage, see attached.

Image IMG-4091 hosted on ImgBB
ImgBB · ibb.co

Image IMG-4093 hosted on ImgBB
ImgBB · ibb.co


2. I asked the headteacher about ownership of the land/carpark, he wasn't sure but said that the whole transition to the car park being monitored had to go through the redbridge council. The schools job is to ensure the upkeep of the car park as well as use by parents but it is shared by the Fenford clubs next door in the same block.

3. I installed SIPPI to see what it says for that location, but I can't seem to find it each time I try and search, odd - officialy if you are to stay more than 30 minutes (a time we only known by asking the school) you have to register at the Kiosk located in the school office. I see no mention of the timing on the display, other than what they've stated in their IAS reply.

Not sure if the above three points aid or means we can add to the response you've written? Before i send it out


Re: PCN - School Car Park Over Stayed without Registering.
« Reply #23 on: »
You are dealing with an unregulated private firm of ex-clamper thugs. Do not expect anything to do with rational thought.

Just send the appeal as advised.
Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain

Re: PCN - School Car Park Over Stayed without Registering.
« Reply #24 on: »
Just send the appeal as advised.

Appeal sent - it wouldnt let me copy and paste, literally had to retype it all word for word.

1. Aside from me mentioning that there is a 30 minute free wait time as advised to us by the school, was there anywhere else that you were able to see this? as their PCN, prima facie evidence and their signage has no mention of this, yet we've stated or used this in our appeal?

2. I came across the following under 5.2 of the link below, which states that even short-stays have the 10-minute grace period applied.

We have concluded that the Code should require a grace period of at least 10 minutes, in addition to the parking and consideration periods, for all private parking before a parking charge can be issued. This was generally considered to be a reasonable period and aligns with the grace period for local authority parking. It is required for all private parking, including short stay areas, as drivers are equally as likely to experience problems that lead to them overstaying in those circumstances.





Do not expect anything to do with rational thought.

Quite scary if the IAS does rejects this appeal, with the reasoning and counter arguments provided, imagine one that doesn't have the assistance and advice like that provided by FTLA and yourself, as many including my self would have replied with basic response using rational thought, what chance would we have, 0!
« Last Edit: October 03, 2025, 09:02:52 pm by LondonTraveller84 »

Re: PCN - School Car Park Over Stayed without Registering.
« Reply #25 on: »
IAS favour less than 1 in 20 appeals.

In particular, IAS hate appeals based around non PoFA compliant NtK's.

If there's one thing they hate more, it's appeals based on the 'not relevant land' argument.

We've all seen appeals to IAS rejected where the alleged contravention has happened smack bang in the middle of an airport (ie clearly not relevant land.)

Some parking companies (who deal with airport parking etc) have deliberately moved from POPLA to IAS as POPLA started to correctly apply the law in said situations.

If your argument is strong then IAS will simply skip over that argument in their response.

Your argument is strong so don't expect it to be correctly addressed - meaning, don't expect IAS to ask the parking company to provide strict proof that the area under control is not under statutory control.

IAS are in fact part of the mechanism which is used to place members of the public under pressure to pay.

It is better that you start to get these facts firmly placed in your mind at this stage rather than hanging out for a 1 in 20 decision from a non-independent appeals company who have no interest in your true legal position.

They just want the money.

Re: PCN - School Car Park Over Stayed without Registering.
« Reply #26 on: »
IAS favour less than 1 in 20 appeals.

If your argument is strong then IAS will simply skip over that argument in their response.

Your argument is strong so don't expect it to be correctly addressed - meaning, don't expect IAS to ask the parking company to provide strict proof that the area under control is not under statutory control.

It is better that you start to get these facts firmly placed in your mind at this stage rather than hanging out for a 1 in 20 decision from a non-independent appeals company who have no interest in your true legal position.

Wow! that's my optimisim and hope changed instantly lol :( A shame, meaning I'll be in this for the long run.. I know you'll hate this, but I think that maybe I should have taken them up on the £20 offer to close the case, and it wouldn't have been me payign £60 or £100 or more. Although I'm baffled as to why they offered such a low reduction, to avoid going down the IAS route, do they get hit with some fees if it goes via IAS?


Re: PCN - School Car Park Over Stayed without Registering.
« Reply #27 on: »
IAS costs them £23 each time, I believe.

It’s completely normal that parking companies, and then the IAS in particular, completely ignore totally valid appeal points. It’s a numbers game. Significant numbers of people then pay up.  Generally people who don’t and play the game with support from people here pay nothing.

Yes, £20 might have been a good deal given the time you will now need to spend on this, but if you don’t believe you should pay a penny then it’s worth sticking with on principle.
« Last Edit: October 04, 2025, 11:43:38 am by jfollows »

Re: PCN - School Car Park Over Stayed without Registering.
« Reply #28 on: »
Yes, £20 might have been a good deal given the time you will now need to spend on this, but if you don’t believe you should pay a penny then it’s worth sticking with on principle.
I'm all for principal, hence why I'm going the long haul on this, as I had started doing with council PCN's and learnt a lot, although this is the first with private PCNs, hence a lot of nervousness as the concepts/rules/regs are above my head - just hope that get through this with £0 payment and not something where I end up having to pay more then the original fine.

The advise on what to put in appeals received so far from this forum has been huge, I can tell the likes of b789, has spent time to knock up the response and that to very quickly, as opposed to a copy and paste, which means a lot.


Re: PCN - School Car Park Over Stayed without Registering.
« Reply #29 on: »
If the IAS reject the appeal, so what? You have been told that this is a kangaroo court.

The Independent Appeals Service (IAS) is not independent in any meaningful sense. “IAS” and the “International Parking Community” (IPC) are trading names of the same company, United Trade and Industry Limited (UNITI). In its own privacy notice the IPC states that it also “uses” the trading names “The Independent Appeals Service (IAS)” and “The Independent Parking Committee (IPC)”. In other words, the trade association that sets the rules (IPC) and the appeal body that judges compliance (IAS) sit inside a single corporate vehicle. That is a textbook structural conflict of interest.

The venture was created and fronted by the same small circle. Companies House records show that UNITI was previously called “Independent Parking Committee Ltd”; its officers have included William Kenneth Hurley (current director/secretary) and John Llewellyn Gladstone Davies (director until 28 May 2017). The person with significant control today is Will Hurley Ltd, with ≥75% of shares/votes and the right to appoint/remove directors. This concentration of control over both the trade body and the appeals arm undermines any claim of independence.

Crucially, there is a direct, documented link to Gladstones Solicitors—the bulk-litigation firm widely used by private parking operators. Companies House confirms that John L G Davies is a current director of Gladstones Solicitors Limited and that William K Hurley served as a director there from 23 May 2011 until 28 May 2017. This is the same pair who founded and led the IPC/IAS ecosystem. The IPC itself promotes Gladstones as a partner and headline conference sponsor, describing them as a firm specialising in enforcement and litigation of unpaid private parking charges for both IPC and BPA operators. The practical effect is an ecosystem in which the trade body (IPC) and its appeals badge (IAS) are housed in UNITI, and—when an IAS appeal fails—operators instruct a closely associated law firm (Gladstones) to issue or threaten county court claims. Whatever the formal Chinese walls, the optics are “judge, rule-maker, and prosecutor” rolled together.

Process features amplify the concern: IAS assessors are anonymous; decisions are brief; there is no open body of precedent; motorists have no appeal from a rejection, while operators retain the option to litigate even after a motorist “win”. None of that resembles a balanced, open tribunal. Combined with the ownership and partner links above, it is bleedin’ obvious this is not a fair, arm’s-length arrangement.

Finally, from a consumer-protection lens, the set-up raises clear red flags. The same corporate group brands the rule-setter (IPC) and the adjudicator (IAS), while a partner law firm that has been led by the same principals handles bulk enforcement for the operators. That structure invites scrutiny under modern UK consumer and competition principles (now consolidated in the DMCC regime) as to whether independence claims and fairness representations are potentially misleading. To be clear, the point here is structural: it is the documented cross-ownership, officer history, and commercial partnering that create the conflict.

Yes, £20 might have been a good deal given the time you will now need to spend on this, but if you don’t believe you should pay a penny then it’s worth sticking with on principle.

What time to spend on this? We do the bulk of there work and all you have to do is follow the advice. The vast majority of the advice is template stuff.

I'm all for principal, hence why I'm going the long haul on this, as I had started doing with council PCN's and learnt a lot, although this is the first with private PCNs, hence a lot of nervousness as the concepts/rules/regs are above my head - just hope that get through this with £0 payment and not something where I end up having to pay more then the original fine.

I note you are still referring to this as a "fine". I will give you £50 for every occurrence of that word you can evidence in any of the correspondence you've received over this to date. By calling it a "fine", you are indicating to these skank companies that you are low-hanging fruit on the gullible tree and can likely be intimidated into paying up out of ignorance or fear.

Why would you want to pay a speculative invoice for £20 from an unregulated private parking firm for an alleged breach of contract by the driver? Do you simply pay any old "invoice" just because it offers a discount, even if you don't owe anything in the first place? Of course you don't.

You are the victim an attempted scam to fleece you of anything they can get from you. These private parking firms issue over 40,000 PCNs every single day. Think about how many recipients simply think of them as a "fine" and simply pay up at the mugs discount rate. Most are never challenged and the vast majority that end up being challenged int he small claims court end up as CCJs in default because the recipient has no idea how to deal with this.

Here, we deal with this day in and day out. We are well versed in the tactics used and have a good armoury to challenge them. There are extremely few that are not won and of the those very few, most end up paying far less than the amount being claimed. These firms never really want it to go all the way to a hearing in front of a judge because they know they are more likely to get a spanking. Even when they win, it's usually a pyrrhic victory as it has almost certainly cost them much miore than they can hope to recover.

But you are dealing with a very greedy cabal of incestuous firms whose snouts are well embedding in the trough that is this industry.
Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain