Free Traffic Legal Advice

Please read and act on https://www.ftla.uk/private-parking-tickets/read-this-first-private-parking-charges-forum-guide/
For example,

3. Post the notice(s) you have received – as well as providing important context, the notices may contain/omit details that can be used to help you successfully fight the charge. Upload photos of any and all notices you have received from the parking company. You should show us all pages of the notice(s), remove personal details (name/address, PCN reference number, Vehicle Registration Mark), but show us all dates and times. Details that you think are trivial could help you win, so don’t leave anything out.

Ideally you will have sought advice here before taking action, but if you have already responded, show us any correspondence you have sent, and the response(s) you have received in return.

You have obscured too much information.

Show us the back of the PCN.

That Notice to Keeper warrants a formal complaint because it is in breach of the PPSCoP section 8.1.1(d). The location is not relevant land so the Keeper cannot be liable. Only the driver can be liable and they have no idea who that is unless the Keeper blabs it, inadvertently or otherwise.

For now, simply appeal, ONLY as the Keeper, with the following:

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

If Manchester Airport wanted to hold owners or keepers liable under Airport 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 ParkingEye is not the Airport owner and your 'parking charge' is not and never attempts to be a penalty. It is created for ParkingEye’s own profit (as opposed to a bylaws penalty that goes to the public purse) and ParkingEye 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. ParkingEye have no hope at POPLA, so you are urged to save us both a complete waste of time and cancel the PCN.

Parking Eye get 0p from however much you paid for parking.

Their contract allows them to go after and keep the money from people who break their rules. It’s their only source of money.

We always assume that any recipient of a PCN has used common sense and tried Plan A, which is to always get whoever contracts the parking operator to get it cancelled.

Plans B, C and D are what we deal with here.

What you need to understand for future reference is that the recipient of the NtK, the Keeper, should never, ever, EVER identify the driver. Only the driver is ever liable. Unless the operator is able to rely on PoFA 2012 to be able to transfer liability from the unknown driver to the known Keeper, then blabbing the drivers identity, inadvertently or otherwise, is the proverbial shooting oneself in both feet with a single bullet.

In this case, the location is the Radisson Hotel at Manchester Airport which lies within the Manchester Airport boundary and is therefore land that is subject to statutory control (airport byelaws), which means that it is not relevant land for the purposes of PoFA and so, had this continued to appeal and beyond, as long as the driver is not identified, they would eventually have nowhere to go with this PCN.

Luckily for you, your daughter has written confirmation that the hotel has told their agent to cancel the PCN. Don't be surprised though if ParkingEye turn around and say they will not cancel it and they want £20 to cover their costs.

As long as there has been no admittance by the Keeper that they were the driver (whether they were or were not), there is no basis in law for ParkingEye to pursue the Keeper for any money.