Free Traffic Legal Advice

Was the formal complaint sent to PPM? What was their response? Does the Keeper have any contemporaneous photos of that entrance sign either obscured by foliage or in the damaged condition as shown in other photos?

No response from PPM yet.

They have evidence of pictures as shown here along with an independent witness a neighbour who will certify that the signs have been in these manner prior to PCN having been issued.

https://imgur.com/a/A9sUkFg

Does this change anything? My previous post above also shows their initial appeal.

There's your fatal mistake where you admitted being the driver:

This is a neighbour I am helping out. They just filled in the form generically and did not consult me till the form was completed.

Is there any recovery?

Should the RK still write to BW LEGAL as per your suggestion above (querying charges).

There is a clause such as the below,

15 Head Lease 15.1 To comply with the obligations of the Head Lease.

This is the only thing about parking in the tenancy contract.

So, in other words, as the tenant, there is no obligation on you to display any permit and the parking company has no legal right to impose any conditions on your parking, as long as it is in your demised space.

Remind me... was this in your demised space?

...but the driver took the same entry and exit.

But which ones? Your plan marks entrances and exits identically.

One final query from me. Could the appeal for this PCN simply be that the alleged site of contravention is not considered 'Relevant Land' because parking conditions are regulated by the Local Authority under a Traffic Management Order (TMO) and is classified as 'Controlled Parking Zone' for which the RK had a valid permit?

The council TMO map shows it is a permit parking area (green shaded area.ahove is permitnparking TS zone as per Southwark Council).

I can search for a Section 6C agreement to see if the council has taken over management of this area as well.

Is there any argument of TMO map showing it is controlled.parkingas per council which gives them the right to park their with a valid council permit?

@b789 PPM Ltd responded with the below letter. Should we,

(1) correspond directly with BW LEGAL using the email template you previously provided (requoted below)

(2) Should we also write back to PPM Ltd and state that they have not addressed any of the points in our previous email to them and still expect a response; reiterating that they have broken their terms of agreement with PCM to issue a PCN and are additionally going to file a legal complaint to trading standards u else they cease and desist PCN enforcement?

Respond to BW Legal LoC with the following:

Quote

Dear Sirs,

Re: Letter of Claim dated 24th March 2025

I refer to your Letter of Claim.

I confirm that my address for service at this time is as follows, and I request that any outdated address be erased from your records to ensure compliance with data protection obligations:

[YOUR ADDRESS]

Please note that the alleged debt is disputed, and any court proceedings will be robustly defended.

I note that the sum claimed has been increased by an excessive and unjustifiable amount, which appears contrary to the principles established by the Government, who described such practices as “extorting money from motorists.” Please refrain from sending boilerplate responses or justifications regarding this issue.

Under the Pre-Action Protocol for Debt Claims, I require specific answers to the following questions:

1. Does the additional £120 represent what you describe as a “Debt Recovery” fee? If so, is this figure net of or inclusive of VAT? If inclusive, I trust you will explain why I, as the alleged debtor, am being asked to cover your client’s VAT liability.

2. Regarding the principal sum of the alleged Parking Charge Notices (PCNs): Is this being claimed as damages for breach of contract, or will it be pleaded as consideration for a purported parking contract?

I would caution you against simply dismissing these questions with vague or boilerplate responses, as I am fully aware of the implications. By claiming that PCNs are exempt from VAT while simultaneously inflating the debt recovery element, your client – with your assistance – appears to be evading VAT obligations due to HMRC. Such mendacious conduct raises serious questions about the legality and ethics of your practices.

I strongly advise your client to cease and desist. Should this matter proceed to court, you can be assured that these issues will be brought to the court’s attention, alongside a robust defence and potentially a counterclaim for unreasonable conduct.

Yours faithfully,


[YOUR NAME]

Email from PPM Ltd along with the previous appeal tejection attached to the email is below.