Free Traffic Legal Advice

Just use this:

I am the registered keeper. SABA cannot hold a registered keeper liable for any alleged contravention on land that is under statutory control. As a matter of fact and law, SABA will be well aware that they cannot use the PoFA provisions because the car park at Hayes and Harlington station is not 'relevant land'.

If the station owners wanted to hold owners or keepers liable under Railway Bylaws, that would be within the landowner's gift and another matter entirely. However, not only is that not pleaded, it is also not legally possible because SABA is not the station owner and your 'parking charge' is not and never attempts to be a penalty. It is created for SABA's own profit (as opposed to a bylaws penalty that goes to the public purse) and SABA 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. SABA have no hope at POPLA, so you are urged to save us both a complete waste of time and cancel the PCN.

Are SABA litigious?

Not at all, in our experience.

The 'loopholes' will be as above. Show us the letter when it arrives, just to make sure SABA haven't gone off-piste and done something they don't normally, but the above suggested appeal will almost certainly be fine to use.