Free Traffic Legal Advice

Hi,
I found this forum and I'm looking for some advice, please!

TL;DR Summary
VCS issued me a “no stopping” PCN at Bristol Airport, but the only reason I stopped was because the VCS patrol vehicle ahead of me stopped in the middle of the road, blocking the carriageway while dealing with another car. Their stills show me stuck behind the van from 05:55:04. They repeatedly claimed the CCTV disproves my account, but refused to release it for months (GDPR excuses, “no software”). Their legal firm Elms Legal has now provided only partial CCTV starting 30 seconds too late, omitting the crucial moment when the van stopped. An ICO complaint is ongoing. Elms Legal are now “reviewing” my request for full footage and have extended the case hold until 13 December 2025. I’m looking for advice on obstruction as a defence, land status at Bristol Airport, VCS evidence issues, DSAR non-compliance, and preparing for potential court action.

FULL CASE DETAILS BELOW
Overview
Hi all, I’d appreciate guidance on a long-running case with Vehicle Control Services (VCS) relating to a “No Stopping” PCN issued at Bristol Airport.
The case has developed into a dispute not only about the incident itself but about VCS’s refusal to disclose key CCTV evidence.

Incident Summary
* Date/time: 04/05/2025 at approx. 05:55
* Location: Bristol Airport access road (approach to terminal)
* Operator: Vehicle Control Services (VCS)
* Allegation: Stopping in a restricted zone
* I was the driver, but not the registered keeper (the RK is my mother)

Key fact:
I stopped only because the VCS patrol vehicle in front of me suddenly stopped in the middle of the road while dealing with another vehicle parked up by the terminal. I had no safe or obvious way to pass without crossing white hatched lines. I waited ~30 seconds before my passenger exited.

Why I Believe the PCN Is Incorrect
1. The patrol vehicle caused the stop
VCS claim the CCTV shows my vehicle “already stationary and dropping off a passenger when first observed”.

However, their own timestamped stills show:
* At 05:55:04, I am already stopped directly behind their patrol van
* The patrol van is stationary, blocking the road
* A car is parked illegally in front of the patrol van, which appears to be the reason the patrol van stopped
* There was minimal safe space to pass without fully mounting the white lines
* This contradicts their assertion that my stop was voluntary.

2. The CCTV provided is incomplete
After months of avoidance (GDPR excuses, “cannot redact video”, “stills are sufficient”), the case was passed to Elms Legal.

Elms Legal then provided only partial CCTV, starting at:
* 05:55:39
* Which is 30+ seconds after the crucial moment when the patrol van initially stopped

This missing segment is the core of the entire dispute. I have asked for:
* The full, unedited footage
* Footage showing the patrol van stopping
* How long it remained stationary
* When it moved again
* Any terminal-side camera footage

A GDPR waiver from the only other person visible was already provided.

3. Conflicting statements from VCS about evidence
VCS repeatedly stated that the CCTV “does not support” my account. But:
* They refused to release the footage
* Their own stills actually support my account
* Elms Legal’s partial footage does not contradict me
* DSAR excuses have shifted several times (GDPR → redaction → “no software” → “stills are enough”)

This pattern raises concerns about whether the withheld footage undermines VCS’s position.

4. Land status / jurisdiction
VCS assert the area is “private land”. However, the road appears to be either:
* An adopted public highway, or
* Land governed by Bristol Airport byelaws

If either applies, enforcing a private contractual charge may be ultra vires. VCS have avoided answering this point despite repeated requests.

Procedural History
* Appeal to VCS → rejected
* Appeal to IAS → dismissed
* DSAR submitted to VCS → refused
* GDPR waiver submitted → ignored
* DSAR refused again (“no software”)
* ICO complaint filed (ongoing)
* Case passed to Elms Legal
* Partial CCTV supplied (beginning 30 seconds too late)
* Case placed on hold (initially to 30 Nov)

Update (Latest Development)
I have now received a further response from Elms Legal. They confirmed that they are “reviewing [my] CCTV request with their client” and have extended the hold on the case until 13 December 2025. This indicates the missing footage does exist and may still be retrievable. I will update this thread if and when the full footage is provided, as this remains the key piece of evidence in dispute.

What I’m Asking FTLA For:
* Assessment of the obstruction defence
* Views on whether the land is public highway / byelaws
* How courts treat “forced stop” arguments
* Whether VCS’s DSAR non-compliance affects the claim
* Advice on building a court defence if a claim is issued
* Whether similar Bristol Airport VCS cases exist
* Any procedural strategies recommended

Evidence Available to Upload (all redacted)
* PCN + NTK
* VCS still images
* My annotated stills
* Partial CCTV supplied by Elms Legal
* Correspondence with VCS
* Correspondence with Elms Legal
* DSAR emails (including GDPR waiver)
* ICO complaint
* Timeline bundle

Thanks in advance. I’m grateful for any guidance the forum can provide. And a big THANK YOU if you read this far! 🙂

Okay, so read it all. Pretty comprehensive summary.

Can we assume that the driver has been revealed in your various communications with VCS and ELMS? Or have you made all representations as the vehicle keeper?

I've got a good deal of location specific knowledge regarding the scam / fraud / entrapment / misuse of data which VCS perpetrate at the Bristol Airport site.



In the first instance I can tell you that it was the passenger exiting the vehicle which probably lead to the NtK being issued.

In your summary you mention that you received a Parking Charge Notice - could you check that and see if it was in fact a 'charging notice'? I ask this because I strongly suspect that these may have a completely different legal standing as there is no apparent facility for 'charging notices' in relevant legislation. I strongly suspect that VCS were asked (or decided) to stop issuing PCNs for non-parking related breaches for some reason - probably because 'traffic enforcement' didn't fit in with private parking legislation or with their code of conduct.


Secondly, I am totally confident that VCS's charging notices have absolutely no legal standing whatsoever. I say that because there is no legitimate way that VCS can form a contract with a driver who simply drives past a sign.

VCS have previously tried to claim that the contract is formed through action ie by driving past the sign - but what about the offer of contract which must come before that?? Also, isn't contract a choice? The correct legal mechanism simply isn't there for a valid contract to be formed.

At Bristol Airport, all of their charging notices are based on the assumption that a contract is formed with each driver as they enter the airport.

Within that contract is the apparent agreement, "No Stopping". The term is unilateral. Even if you stopped at a drop off area they could still issue a CN because you have stopped. People have been issued with CNs for stopping at a barrier while waiting to enter a car park.

So the term would instantly be regarded as an unfair term because there could be a dozen or more reasons why you might have cause to stop.


It would definitely beneficial if your evidence could be uploaded.

The general consensus is not to communicate with nonsense debt collecting companies as they only get paid if they get the mugs to cough up. ELMS will almost certainly review your situation and then tell you that you still owe the money.

In the current circumstance it may be best to simply wait for the Letter of Claim and take it from there. From that point onwards, we can wipe the floor with them.

Hi all — thanks again for the earlier replies. Apologies for the delayed response; I was expecting to be notified by email, but I wasn't.

A few clarifications:
1. It was indeed a Charging Notice, not a Parking Charge Notice
My mistake — I was confused I had to post this under the 'Civil penalty charge notices (Councils, TFL and so on)'. Very interesting what you say about the significance of “Charging Notices” issued for traffic movements and that they may have no legal basis whatsoever. I’ll upload a redacted copy.

2. Yes, I inadvertently revealed myself as the driver
Mea Cupla. This was entirely my own doing. My 79-year-old mother is the registered keeper, and I wanted to spare her any stress. And in my simple mind, I had nothing to hide. I wrote in good faith, not understanding the PoFA implications. Lesson learned!

3. Regarding Letters Before Claim
I have not received a Letter of Claim. What I’ve received from Elms Legal is titled:
“Urgent: Notification of Instruction” — which, as I understand it, isn’t an LoC.

4. Interaction with Elms Legal
Interestingly, Elms were genuinely helpful when I called them. They explained the process clearly and even assisted in getting me part of the CCTV footage. In complete contrast, the IAS appeal was — as indicated — a complete waste of time.

5. The crucial issue: VCS’s patrol vehicle blocked the road
The still images originally sent to me begin at 05:55:04.
The CCTV clip Elms provided starts at 05:55:39.
In my evidence, you will be able to clearly see that:

• The patrol vehicle stops in the middle of the road
• I stop behind it because I physically cannot pass
• The patrol vehicle remains stationary for over 30 seconds
• Only then do I say to my passenger that they may as well get out, as I cannot proceed

As I said before, this is a forced stop, not a voluntary one. I would have proceeded to the official drop-off zone if the road had not been obstructed by VCS themselves.

6. VCS refuses to provide the full CCTV
Their reasons have changed multiple times. The latest excuse is that they “don’t have the software to redact” footage — despite the fact that only me and my son appear in it, and despite them clearly being able to extract stills. This is now the subject of a GDPR/ICO complaint.

7. Attachment plan
Just as soon as I can figure out how to uploads files! If anyone has any advice on that, I can upload:

• The Charging Notice
• VCS still images
• My annotated stills
• The partial CCTV (or frames from it)
• Timeline summary
• Correspondence between me, VCS, and Elms Legal

Any feedback on which elements are most relevant or how best to structure them would be hugely appreciated.

Thanks again for the guidance so far — I’m very grateful, and I’m keen to get this right before it progresses to a Letter of Claim.

Be warned that contact with debt collectors and so called legal firms can result in them 'fishing' for evidence, especially so with airport and railway PCN's where PoFA doesn't apply - in particular identification of the driver.

This is the group for private parking invoices - what you have received is a speculative invoice for breach of contract - this is nothing to do with traffic law. The wording on their invoices and subsequent letters are designed to dress their invoices up as some kind of 'official' penalty.

Whilst I can see that you have stated your case in a very organised manner, the evidence shown is not going to win the argument.

With the driver identified the normal avenue of defence is unavailable. However, all is not lost because other strong defences are available.

The way to win this will be to challenge the authority of VCS to even issue the CN in the first place.

In fact it is questionable how VCS are even able to access keeper details from the DVLA with regard to so called 'traffic contraventions' on private land - so I would firstly contact the DVLA and ask them to specify the precise reason which VCS gave when they accessed your personal data - if the reason given is a 'parking issue' then you will have gathered further evidence which will show misuse of data.

The CRUX of the issue (as you call it) will be the lack of lawful contract between VCS and the driver. Their claim of contract is weak in the extreme. Their claim of contract arises out of necessity rather than through a recognised legal process. No contract = no right to issue the CNs.


The only reason VCS access your data is so they can play a game of statistical chess with you. This is REALLY how this scam works - I can see from your last post how you are beginning to realise this?

This is why many of the experts on the various consumer sites all suggest the same course of action - which is to play the long game. Yes there will be more begging debt letters. Yes there will be more legal letters trying to project their narrative. But all these letters are powerless. But they are part of the statistical game which the operators play as they try to bully the mugs into paying. It's the unfortunate truth that some people succumb to the perceived pressure and narrative which these letters create.

All you can do now is wait for the letter of claim.

Why do you still insist on calling it a "fine" and that you would have just paid if they hadn't called you a liar?

I dunno, because I'm a simple amateur with some old school values from a bygone era when integrity and honesty meant something who has decided to pick up the gauntlet of the ordinary person and embark on some misguided quest for truth and social justice? 🤷‍♂️

In the interim, I have written to the DVLA and asked...
In the middle of May 2025 I received the attached Charge Notice.  Can you please let me know the precise reason which VCS gave when they contacted the DVLA to access my personal data, please?

I'll let you know what I get back.

Again, thank you all for your support, it's truly amazing.

You use this MIS1065 form to make a SAR to the DVLA. All done electronically.

DVLA subject access request (SAR)