Free Traffic Legal Advice

It matters not whether they know you read the file or not. ZZPS are not a party to any contract alleged breached by the driver. You have been advised to ignore them. They cannot do anything, no Katter what they threaten.

Have a look at what they sent you and then tell or show us, if you think it is relevant to anything.

I am waiting for a response to an FOI request to TfL which asked:

Please confirm whether the North Greenwich Station Car Park (postcode SE10 0PH), currently managed by Saba Park Services UK Ltd on behalf of TTL Properties Limited, remains subject to the TfL Railway Byelaws 2011. If the site was ever subject to those byelaws and they have since been revoked or superseded, please provide details of the revocation or modification.

Have we ever seen the original Notice to Keeper (NtK)? I need to see that to determine who the creditor is in all of this.

The appeal response was sent on behalf of ZZPS Limited, trading as PayMyParkingCharge.com, from the Parking Admin Centre, Addlestone, Surrey.

Stated Client: “Our Client: SABA PARK SERVICES UK LIMITED”

This confirms ZZPS was acting on behalf of SABA, not TTL Properties Ltd.

We need to see the NtK to determine who the stated creditor is on that document. The appeal rejection implies that SABA is the creditor, which contradicts TTL's own authorisation letter that states TTL is the legal landowner and creditor

SABA later stated they were “not reviewing your correspondence as an appeal”, yet ZZPS, acting for SABA, sent this formal appeal rejection with a POPLA code. This is a clear contradiction and suggests a failure in appeal process governance.

A POPLA code was issued. However, it was issued by a debt collection agent, not by the operator directly, which may also breach the BPA's procedural requirements if not properly delegated.

So, please show us the original NtK (both sides).

The NtK clearly states at the top:


This is legally significant because this is a breach of PoFA paragraph 9(2)(h):


Here’s why this NtK fails:

Thanks both, hopefully they're shot themselves in the foot

I've drafted the below to POPLA. I've not Indexed all previous correspondence with Saba or DVLA as I don't want to detract from the main point being false identification of the creditor.  Please let me know if I should.

We also now have a notice the case has been transferred to GCTT dated 19 May 25 attached (before the POPLA code was issued)



POPLA Appeal Submission

I write regarding POPLA Verification Code [  ] concerning Parking Charge To Registered Keeper Reference [  ] dated [   ]. The “NtK”. (Appendix A).

The NtK clearly states at the top:

Creditor: SABA PARK SERVICES UK LIMITED

This is legally significant because this is a breach of PoFA paragraph 9(2)(h):

“The notice must— (h) identify the creditor and specify how and to whom payment or notification to the creditor may be made.”

Here’s why this NtK fails:

• Saba Park Services UK Ltd is not the creditor in law.
• The landowner — TTL Properties Limited — is the actual creditor, as confirmed in their own authorisation document (Page 1 of Appendix D):

“The Landowner is the creditor for all notices of parking charge issued...”

This false identification of the creditor:

• Invalidates keeper liability under PoFA;
• Confirms the position in my original appeal that Saba cannot rely on PoFA to pursue the registered keeper;
• Reinforces the argument that only the driver could ever be liable (under contract law), and only if the land were not under statutory control (which it is).

Important evidence that they have not complied with PoFA:

The NtK fails to comply with Schedule 4 of the Protection of Freedoms Act 2012, paragraph 9(2)(h), because it wrongly names Saba Park Services UK Ltd as the creditor. However, the landowner (TTL Properties Ltd), as confirmed in the landowner authorisation provided by Saba, is the only party legally entitled to be the creditor.

This renders the notice non-compliant and invalidates any keeper liability under PoFA.

Summary of further Breaches:

•A detailed appeal was delivered by recorded post to Saba on 23 March 2025. Saba failed to respond with a rejection or provide a POPLA code within the time period, as required under Clause 8.4.1(b) and Annex C.1.1 of the PPSCoP.
• Saba unlawfully escalated the charge on 22 April 2025 to debt collection (ZZPS) while the appeal process remained unresolved and without offering access to independent adjudication.
• Saba unlawfully transferred the charge on 19 May 2025 to enforcement agents (GCTT) while the appeal process remained unresolved.
• On 27 May 2025 ZZPS (Not Saba) issued a response to the original appeal which included a POPLA code

As Saba have unlawfully escalated the charge to GCTT we request an urgent decision to this appeal


[Name & Address]
[Vehicle registration]
[Parking Charge Reference ]
[Location: North Greenwich Main


Appendix

A – Saba Parking Charge to Registered Keeper 12/03/25
B – Non-compliant escalation to ZZPS 22/04/25 before appeal decision
C – Non-complaint escalation to GCTT 19/05/25 before independent appeal decision
D - TTL Properties Limited authorisation document provided by Saba 21/05/25


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Excuse my ignorance - are you saying I should go back to Saba for strict proof that they have a valid contract before I make the POPLA appeal? If I provide the Landowner Consent with the POPLA appeal there may be a chance this document is superseded by a contract?

thanks

Update: I had a response to my FoI request but they have failed to answer the question in a spectacular fashion. Their response, as you will see, is inadequate:

Dear b789,

Our ref: FOI-0703-2526

Thank you for your request received by Transport for London (TfL) on 21 May 2025 asking for information about North Greenwich Station Car Park.

Your request has been considered under the requirements of the Freedom of Information Act 2000 and our information access policy.

I can confirm that we do hold the information you require. You asked:

”Please confirm whether the North Greenwich Station Car Park (postcode SE10 0PH), currently managed by Saba Park Services UK Ltd on behalf of TTL Properties Limited, remains subject to the TfL Railway Byelaws 2011. If the site was ever subject to those byelaws and they have since been revoked or superseded, please provide details of the revocation or modification.”

No, Saba UK are not subject to TfL Byelaws, as Saba UK operate under private land enforcement and under the Protection of Freedoms Act 2012.

If you are not satisfied with this response please see the attached information sheet for details of your right to appeal.

Yours sincerely,

 
Tahsin Prima

FOI Case Officer

General Counsel

I have responded with the following:

Subject: Request for Internal Review – FOI-0703-2526 (North Greenwich Station Car Park)

Dear FOI Team,

I am writing to request an internal review of your response to my FOI request (reference FOI-0703-2526), regarding the status of North Greenwich Station Car Park and whether it remains subject to the TfL Railway Byelaws 2011.

Your response states:

“No, Saba UK are not subject to TfL Byelaws, as Saba UK operate under private land enforcement and under the Protection of Freedoms Act 2012.”

This is an evasive and legally inadequate answer that does not address the substance of the request. The question was not whether Saba UK chooses to enforce parking under PoFA, but whether the land itself at North Greenwich Station remains subject to TfL Railway Byelaws 2011, as made under the Greater London Authority Act 1999.

My request was specific and factual. It sought:

• Confirmation of whether byelaws currently apply to the land at SE10 0PH;

• If they do not apply, whether and when they were formally revoked or superseded, and by what legal or administrative mechanism.

Your answer did not provide this. It simply restated the operator’s current enforcement choice, which is legally irrelevantto the land’s status under PoFA 2012 Schedule 4.

For the record, unless and until TfL formally revokes its byelaws over a specific site, or unless the site is reclassified through a published legal instrument, that land remains subject to statutory control. A contractor’s self-declared reliance on civil enforcement does not alter the legal classification of the land.

I therefore request the following as part of this internal review:

• A proper response confirming the legal status of the land, not the practices of the contractor;

• Copies or references to any documents or orders showing revocation, disapplication or amendment of the TfL Railway Byelaws 2011 as they apply to North Greenwich Station Car Park;

• An explanation of why my original question was not properly addressed.

If you cannot provide evidence of revocation or reclassification, you must confirm that the land remains subject to the 2011 Byelaws.

Yours sincerely,

B789

However I expect further obfuscation as their “councel” tries to protect their agent, SABA, from the fact that the land is indeed still under byelaws and therefore not relevant for the purposes of PoFA.

Part 2

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No response received to the request for the review of the FoI response given. I have asked for a follow up.

For the response to the operators evidence, go through everything you raised in the appeal that they either have not answered or answered incorrectly. Go through any points raised in their response that you can rebut.

I don't see a copy of their contract with the landowner in their evidence pack Whilst we may have seen something earlier, if it is not in their evidence pack, then they have not "evidenced" it to POPLA and therefore have not proved that they had a valid contract at the time of the alleged contravention.

You need to reiterate that their NtK is not PoFA compliant because it has failed specify a "period of parking" as required by paragraph 9(2)(a). A single observation of a stationary vehicle is not a "period of parking." Even if multiple photos show the same timestamp or a short sequence, that still does not constitute a proper period. The courts have made it clear that there must be evidence of actual parking activity over a meaningful interval. This was confirmed in Brennan v Premier Parking Solutions (2023) [H6DP632H], where the judge ruled that a single timestamp or momentary observation is not sufficient and therefore the creditor cannot rely on PoFA to hold the Keeper liable.

Put together a response and show it to us before you send anything. You have 7 days in which to respond. You can only use plain text and there is a 10,000 character limit so don't try and format anything. you will be copying and pasting the response into the POPLA webform.