Author Topic: UK Car Park Management (CPM) PCN - 'No Parking Outside Of A Marked Bay' - Queens Road, Nottingham.   (Read 1023 times)

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Hi All, 

Hope this finds you well, I have today (07/11/2025) received a PCN from UK Car Park Management (CPM), which I am in two minds whether to pay or challenge. It has been recommended to me that I share the details in this forum by my Father in Law who is an avid poster in Civil Penalty Charge Forum. 

I am under no illusions that any appeal made directly to CPM will be rejected likely without any consideration and I accept that its likely the case would have to go to the Independent Appeals Service (IAS) for adjudication. I am aware that if I were to take the case to IAS there is a higher probability the appeal would be rejected. I am also aware that in taking it to IAS I am liable for the full £100 charge as opposed to the discounted £60. 

Due to the distance from my home to the contravention location, it is counterproductive and would be costly for me to attend the area to photograph the road markings/any signage. That is unless group consensus makes the assessment there are grounds for appeal to the IAS, in which case I will make the trip. 

I am not opposed to paying the PCN I am just keen to get an honest second opinion. 

Details:
On 04/11/2025 at 20:48hrs, the driver has driven to Nottingham from Cheshire with the intention of collecting a friend stranded at Nottingham Railway Station, which has an entrance on Queens Road. The driver has no local knowledge of Nottingham Railway Station or the wider Nottingham Area. Upon arrival into Nottingham the driver has stopped some distance from the railway station to try and locate a suitable place to park. This has indicated the best place to park is on a Multi Storey Car Park on Queens Road, which as a drop off and pick up facility. 

As the driver was arriving at the Railway Station, the friend has contacted the driver to advise they were stood outside of the station entrance on Queens Road. Consequently, the driver has elected not to enter the Multi Storey Car Park and instead pull into what the driver believed was a small cul-de-sac/dead end junction to turn around believing by which time the friend will have crossed the road and got into the vehicle. This junction is located here on Google Maps (Image is from 2022 on Google Maps): 

https://maps.app.goo.gl/qaqsSiHdHkhYNBSC6
What 3 Words: ///laws.weedy.oath

As the driver has pulled into this junction a large Range Rover has followed and to keep traffic moving the driver has pulled onto and turned around in a small car park located behind the building as shown here: 

https://maps.app.goo.gl/HRXUxwdNELr6Ashs8
What3Words: ///mice.stroke.option

The driver has not stopped in this car park and merely turned around here before returning back to the junction on Queens Road where the driver has come to a stop at the junction with Queens Road (As Shown in PCN Images) as the Range Rover had turned around in the junction and left. At this point the friend has crossed the road and got into the vehicle before both driver and friend had left.  The driver does not recall how long they were stopped at this junction but believes it could not have been more than a few minutes. The driver has only stopped at this junction as it was safe to do and had another vehicle arrived or approached from behind they would have left. 

Drivers Mindset: 
1) The driver did not believe at the time that they were on private land and believed they were at a highway junction, a location to which the public have access. 

2) The driver is aware that there could be other offences in play which could be made subject of there own penalty given the area is a red route etc. 

3) The driver reached the belief they were at a junction based on the road markings albeit accepts that the Red Route solid red line does not stop at the junction and the road markings are faded. 

4) The driver was not aware at the time that land the other side of the Red Route was private land and subject to parking restrictions. 

5) The driver does not recall seeing any clearly visible signage indicating that such restrictions were active and enforceable. 

Questions to Group: 
Are there any apparent grounds to make an appeal to the IAS? 
Do I have grounds to request from CPM disclosure of any other material they have in respect of this case? Such as any video footage of the contravention or High Resolution Stills of the vehicle showing its registration plate? 
Does any one have any local knowledge of the contravention location? 

Attachments:
Copy of PCN
https://drive.google.com/file/d/1lYCkYRBcjP5Dme3Kj4m1MGxw229-xi_A/view?usp=drive_link

Thanks All for your Time. 

Cheers

V

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Why would you even consider paying a vexatious, bottom-dwelling, unregulated private firm of ex-clampers? You appear to be under the impression that you may be liable as the Keeper for an “offence” and liable to a “penalty” or a “fine”,

Quote
2) The driver is aware that there could be other offences in play which could be made subject of there own penalty given the area is a red route etc.

No “offence” has been committed and the Notice to Keeper (NtK) is definitely not a “fine”. UKCPM are certainly no “authority” that can issue penalties. The NtK is simply a speculative invoice for an alleged breach of contract by the driver.

Only the low-hanging fruit on the gullible tree pay these out of ignorance and fear. Follow the advice you receive here and you will not pay a penny to this scamming firm of vexatious thugs.

They have no case if they were to try and escalate to a county court claim, even though they will do so. The main point is that once defended, they claim will either be struck out or discontinued just before the £27 trial fee has to be paid.

There can be no Keeper liability if the driver is not identified because their NtK does not comply with all the requirements of PoFA. Also, there is no evidence of a consideration period (at least 5 minutes) for a contract to have been formed with the driver.

Forget the 40% mugs discount. Why would you just pay a speculative invoice because it offers a discount? That is just sucker the gullible into thinking they are getting a bargain.

Whilst the IAS is a kangaroo court, we make the operators jump through the hoops because it costs them to challenge an IAS appeal. Not much, but enough for a bit of schadenfreude unless they concede.

We advise and assist every step of the way. For now, simply send the following as your IAS appeal:

 
Quote
I am the registered keeper of the vehicle. I deny any liability for this parking charge and appeal in full.

The parking operator bears the burden of proof. It must establish that a contravention occurred, that a valid contract was formed between the operator and the driver, and that it has lawful authority to operate and issue Parking Charge Notices (PCNs) in its own name. I therefore require the operator to provide the following:

1. Strict proof of clear, prominent, and adequate signage that was in place on the date in question, at the exact location of the alleged contravention. This must include a detailed site plan showing the placement of each sign and legible images of the signs in situ. The operator must demonstrate that signage was visible, legible, and compliant with the IPC Code of Practice that was valid at the time of the alleged contravention, including requirements relating to font size, positioning, and the communication of key terms.

2. Strict proof of a valid, contemporaneous contract or lease flowing from the landowner that authorises the operator to manage parking, issue PCNs, and pursue legal action in its own name. I refer the operator and the IAS assessor to Section 14 of the PPSCoP (Relationship with Landowner), which clearly sets out mandatory minimum requirements that must be evidenced before any parking charge may be issued on controlled land.

In particular, Section 14.1(a)–(j) requires the operator to have in place written confirmation from the landowner which includes:

• the identity of the landowner,
• a boundary map of the land to be managed,
• applicable byelaws,
• the duration and scope of authority granted,
• detailed parking terms and conditions including any specific permissions or exemptions,
• the means of issuing PCNs,
• responsibility for obtaining planning and advertising consents,
• and the operator’s obligations and appeal procedure under the Code.

These requirements are not optional. They are a condition precedent to issuing a PCN and bringing any associated action. Accordingly, I put the operator to strict proof of compliance with the entirety of Section 14 of the PPSCoP. Any document that contains redactions must not obscure the above conditions. The document must also be dated and signed by identifiable persons, with evidence of their authority to act on behalf of the parties to the agreement. The operator must provide an agreement showing clear authorisation from the landowner for this specific site.

3. Strict proof that the enforcement mechanism (e.g. ANPR or manual patrol) is reliable, synchronised, maintained, and calibrated regularly. The operator must prove the vehicle was present for the full duration alleged and not simply momentarily on site, potentially within a permitted consideration or grace period as defined by the PPSCoP.

4. Strict proof that the Notice to Keeper complies with the Protection of Freedoms Act 2012 (PoFA), if the operator is attempting to rely on keeper liability. Any failure to comply with the mandatory wording or timelines in Schedule 4 of PoFA renders keeper liability unenforceable.

5. Strict proof that the NtK was posted in time for it to have been given within the relevant period. The PPSCoP section 8.1.2(d) Note 2 requires that the operator must retain a record of the date of posting of a notice, not simply of that notice having been generated (e.g. the date that any third-party Mail Consolidator actually put it in the postal system.)

6. The IAS claims that its assessors are “qualified solicitors or barristers.” Yet there is no way to verify this. Decisions are unsigned, anonymised, and unpublished. There is no transparency, no register of assessors, and no way for a motorist to assess the legal credibility of the individual supposedly adjudicating their appeal. If the person reading this really is legally qualified, they will know that without strict proof of landowner authority (VCS v HMRC [2013] EWCA Civ 186), no claim can succeed. They will also know that clear and prominent signage is a prerequisite for contract formation (ParkingEye v Beavis [2015] UKSC 67), and that keeper liability under PoFA is only available where strict statutory conditions are met.

If the assessor chooses to overlook these legal requirements and accept vague assertions or redacted documents from the operator, that will speak for itself—and lend further weight to the growing concern that this appeals service is neither independent nor genuinely legally qualified.

In short, I dispute this charge in its entirety and require full evidence of compliance with the law, industry codes of practice, and basic contractual principles.
Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain

Why would you even consider paying a vexatious, bottom-dwelling, unregulated private firm of ex-clampers? You appear to be under the impression that you may be liable as the Keeper for an “offence” and liable to a “penalty” or a “fine”,

Quote
2) The driver is aware that there could be other offences in play which could be made subject of there own penalty given the area is a red route etc.

No “offence” has been committed and the Notice to Keeper (NtK) is definitely not a “fine”. UKCPM are certainly no “authority” that can issue penalties. The NtK is simply a speculative invoice for an alleged breach of contract by the driver.

Only the low-hanging fruit on the gullible tree pay these out of ignorance and fear. Follow the advice you receive here and you will not pay a penny to this scamming firm of vexatious thugs.

They have no case if they were to try and escalate to a county court claim, even though they will do so. The main point is that once defended, they claim will either be struck out or discontinued just before the £27 trial fee has to be paid.

There can be no Keeper liability if the driver is not identified because their NtK does not comply with all the requirements of PoFA. Also, there is no evidence of a consideration period (at least 5 minutes) for a contract to have been formed with the driver.

Forget the 40% mugs discount. Why would you just pay a speculative invoice because it offers a discount? That is just sucker the gullible into thinking they are getting a bargain.

Whilst the IAS is a kangaroo court, we make the operators jump through the hoops because it costs them to challenge an IAS appeal. Not much, but enough for a bit of schadenfreude unless they concede.

We advise and assist every step of the way. For now, simply send the following as your IAS appeal:

Quote
I am the registered keeper of the vehicle. I deny any liability for this parking charge and appeal in full.

The parking operator bears the burden of proof. It must establish that a contravention occurred, that a valid contract was formed between the operator and the driver, and that it has lawful authority to operate and issue Parking Charge Notices (PCNs) in its own name. I therefore require the operator to provide the following:

1. Strict proof of clear, prominent, and adequate signage that was in place on the date in question, at the exact location of the alleged contravention. This must include a detailed site plan showing the placement of each sign and legible images of the signs in situ. The operator must demonstrate that signage was visible, legible, and compliant with the IPC Code of Practice that was valid at the time of the alleged contravention, including requirements relating to font size, positioning, and the communication of key terms.

2. Strict proof of a valid, contemporaneous contract or lease flowing from the landowner that authorises the operator to manage parking, issue PCNs, and pursue legal action in its own name. I refer the operator and the IAS assessor to Section 14 of the PPSCoP (Relationship with Landowner), which clearly sets out mandatory minimum requirements that must be evidenced before any parking charge may be issued on controlled land.

In particular, Section 14.1(a)–(j) requires the operator to have in place written confirmation from the landowner which includes:

• the identity of the landowner,
• a boundary map of the land to be managed,
• applicable byelaws,
• the duration and scope of authority granted,
• detailed parking terms and conditions including any specific permissions or exemptions,
• the means of issuing PCNs,
• responsibility for obtaining planning and advertising consents,
• and the operator’s obligations and appeal procedure under the Code.

These requirements are not optional. They are a condition precedent to issuing a PCN and bringing any associated action. Accordingly, I put the operator to strict proof of compliance with the entirety of Section 14 of the PPSCoP. Any document that contains redactions must not obscure the above conditions. The document must also be dated and signed by identifiable persons, with evidence of their authority to act on behalf of the parties to the agreement. The operator must provide an agreement showing clear authorisation from the landowner for this specific site.

3. Strict proof that the enforcement mechanism (e.g. ANPR or manual patrol) is reliable, synchronised, maintained, and calibrated regularly. The operator must prove the vehicle was present for the full duration alleged and not simply momentarily on site, potentially within a permitted consideration or grace period as defined by the PPSCoP.

4. Strict proof that the Notice to Keeper complies with the Protection of Freedoms Act 2012 (PoFA), if the operator is attempting to rely on keeper liability. Any failure to comply with the mandatory wording or timelines in Schedule 4 of PoFA renders keeper liability unenforceable.

5. Strict proof that the NtK was posted in time for it to have been given within the relevant period. The PPSCoP section 8.1.2(d) Note 2 requires that the operator must retain a record of the date of posting of a notice, not simply of that notice having been generated (e.g. the date that any third-party Mail Consolidator actually put it in the postal system.)

6. The IAS claims that its assessors are “qualified solicitors or barristers.” Yet there is no way to verify this. Decisions are unsigned, anonymised, and unpublished. There is no transparency, no register of assessors, and no way for a motorist to assess the legal credibility of the individual supposedly adjudicating their appeal. If the person reading this really is legally qualified, they will know that without strict proof of landowner authority (VCS v HMRC [2013] EWCA Civ 186), no claim can succeed. They will also know that clear and prominent signage is a prerequisite for contract formation (ParkingEye v Beavis [2015] UKSC 67), and that keeper liability under PoFA is only available where strict statutory conditions are met.

If the assessor chooses to overlook these legal requirements and accept vague assertions or redacted documents from the operator, that will speak for itself—and lend further weight to the growing concern that this appeals service is neither independent nor genuinely legally qualified.

In short, I dispute this charge in its entirety and require full evidence of compliance with the law, industry codes of practice, and basic contractual principles.

Hello,

Hope this finds you well, I took your advice and I sent the above off.

I've now had an email from UKCPM. Which reads as follows:

Dear REDACTED,

Re: Parking Charge Notice 70130977

We write to acknowledge receipt of your recent online appeal against the issuing of a Parking Charge Notice (PCN) to the vehicle for a breach of the advertised terms and conditions.
                                                                   
However, we must advise that we are unable to process your appeal as we cannot verify the information provided.
                                                                   
In order for us to deal with an appeal we require the full and correct name and serviceable address of the driver of the vehicle at the time of the contravention.

Please provide this information by 16th December 2025 via the appeals contact form at appeals.uk-cpm.com.

If this information is not provided using the correct procedure, by the specified date, our normal collection process will continue.

UK Car Park Management Ltd
Switchboard: 0345 463 5050

---------------------

Do I need to identify the driver to them for them to consider the appeal?

Cheers

V

Reply with the following:

Quote
I am the registered keeper. Your refusal to process my appeal unless I identify the driver is unacceptable, unlawful, and will be treated as evidence of bad faith in any future proceedings.

You have my full and correct name and address. You obtained these details from the DVLA under the KADOE contract. That contract requires you to comply fully with the Private Parking Single Code of Practice.

Your attempt to make identification of the driver a precondition to considering a keeper appeal is a clear breach of both the PPSCoP and the KADOE contract. You are expressly prohibited from using DVLA data to pressure a keeper into naming the driver, and you are required to offer a fair, transparent, and accessible appeals process to the registered keeper, which you are deliberately obstructing.

Your statement that you “cannot verify the information provided” is false. You have already used the same name and address to send the Notice to Keeper. This demonstrates either dishonesty or systemic incompetence. I will rely on this in any defence as evidence of unreasonable conduct.

You will now do one of two things:

1. Cancel the PCN, or
2. Issue a formal rejection that addresses the appeal points properly and provides a valid IAS appeal pathway.

If you continue to block the appeal process, misstate legal obligations, or issue any further misleading or coercive demands, I will escalate the matter without further notice. This includes:

• A formal complaint to the DVLA for breach of the KADOE contract.
• A PPSCoP compliance complaint to your ATA.
• A regulatory complaint to the Competition and Markets Authority under the strengthened DMCC Act 2024 powers, on the basis that your conduct amounts to an unfair, misleading, and aggressive commercial practice.
• A complaint to my MP regarding your misuse of DVLA keeper data.

If you are reckless enough to litigate on the back of behaviour like this, I will place all of this correspondence before the court when seeking strike out and costs for unreasonable conduct.

Your next communication must confirm cancellation or provide a proper rejection with the IAS pathway. Any further procedural obstruction will be treated as harassment. I expect your response within 14 days.
Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain

Sent 📤 thanks for your assistance. Will keep you posted.
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The latest response from these vampires...

Dear REDACTED,                         
                                                                                                                                                                                                                                               
Thank you for your appeal against the above Parking Charge Notice.

                                                             
At UK CPM we consider all appeals on a case-by-case basis. We take each appeal very seriously and thoroughly investigate any evidence that has been provided. We appreciate your circumstances and understand this is not a situation anyone would like to find themselves in; however, these parking conditions have been put in place to ensure fair usage for all motorists and support the needs of our client. After careful consideration, it is unfortunate that I am writing to you today to advise that on this occasion, your appeal has been unsuccessful.

The decision to uphold your parking charge notice has been made on the following basis.

Whilst we note your comments and reason for appeal, we can confirm that there is no parking outside of a marked bay. Therefore, as your vehicle was parked in contravention of the terms and conditions as advertised on the signage displayed on site, this PCN has been issued to you correctly.       

 
Either due to the reason for issue and/or the insufficient evidence provided to support the details of your appeal, we have considered this PCN and found that it does not fall under the category of Annex F the Appeals Charter of the Single Code of Practice. Therefore, if no further evidence is provided, we will deem this to be our final decision.

You have now reached the end of our internal appeals procedure and therefore you now have two options; either pay or appeal to the Independent Appeals Service (IAS) - you cannot do both.

To make payment of the total amount due as shown above, please use one of the following payment options;

Online: www.paymyticket.co.uk

Telephone: 0345 463 4040 (24hr)

Post: Payments & Collections, PO Box 3114, Lancing, BN15 5BR

Alternatively, if you do not agree with your internal appeal outcome and you wish to dispute the matter further, as you have complied with our internal appeals procedure you may use, and we will engage with, the IAS Standard Appeals Service providing you lodge an appeal to them within 28 days of this rejection.

The Independent Appeals Service (www.theIAS.org) provides an Alternative Dispute Resolution scheme for disputes of this type. If you decide to appeal to the IAS, you will need to visit their website and use your PCN reference and corresponding vehicle registration. All PCN's will be uploaded to the IAS website by the end of this working day.

If you appeal this charge further then you will lose the ability to pay at the reduced rate (if applicable). In the event that your IAS appeal is unsuccessful, the full amount for the PCN will then be payable. If you lodge an appeal with the IAS and then subsequently pay the charge prior to that appeal being determined, then the appeal will be withdrawn, and you will not be given a further opportunity to contest the charge.

 
If you do not wish to dispute the matter further and payment is not received within 28 days of the date of this correspondence then additional charges may be incurred, for which you may be liable. If the charge continues to remain outstanding, the matter may be later referred for litigation in the County Court which could result in a County Court Judgment being made against you; this may impact on your ability to obtain credit in the future.

UK Car Park Management Ltd
Switchboard: 0345 463 5050
www.uk-cpm.com

You can submit the following as your IAS appeal, for what it's worth. It prompts the IAS assessor to perjure themself if the fail to answer the relevant pint about their claimed legal status as an ADR adjudicator, which will be fun to see in their response and can be used as general evidence to various authorities, if necessary:

Quote
1. I am the registered keeper of vehicle [VRM]. I appeal to the IAS against UK Car Park Management Ltd (“the Operator”) in respect of Parking Charge Notice [PCN NUMBER], issued in relation to an alleged contravention on 04/11/2025 at approximately 20:48. Liability is denied in full. This is a dispute of substance about contract formation, evidential sufficiency, landowner authority, and the Operator’s compliance with mandatory requirements of the Private Parking Single Code of Practice (“PPSCoP”) and the law of contract.

2. The Operator bears the burden of proof. It must prove on the balance of probabilities (i) the precise location and circumstances of the alleged contravention; (ii) that the driver was offered clear contractual terms capable of acceptance; (iii) that the driver accepted those terms; (iv) that the charge is recoverable as a contractual charge rather than an unenforceable penalty or damages dressed up as a contractual sum; and (v) that the Operator has proper standing and landowner authority to contract with motorists and to pursue charges in its own name. A bare assertion is not evidence.

3. The Operator’s handling of the initial appeal is relevant background to credibility and fairness. The Operator initially refused to process the appeal unless the driver’s full name and serviceable address were provided. That position was improper. There is no general legal obligation upon a registered keeper to name the driver in a private parking matter. That the Operator sought to impose this as a condition of considering a keeper appeal demonstrates a procedural approach geared to coercion rather than genuine dispute resolution. Whilst the Operator has now issued a template rejection, it still fails to engage with the substance of the issues raised and remains evidentially deficient.

4. Procedural fairness and the asserted legal competence of the IAS assessor. The IAS states that appeals are determined by legally qualified assessors, typically solicitors or barristers. Decisions are anonymous, unsigned, and provide no verifiable indication of the assessor’s qualification, practising status, or independence. Where an ADR scheme relies on claimed legal expertise as a marker of credibility, it is reasonable to expect decisions to demonstrate that expertise through structured legal analysis rather than assertion.

5. I therefore invite the IAS to confirm in its decision, without disclosing personal data, whether the assessor determining this appeal is a practising solicitor of England and Wales, a barrister holding a practising certificate, or another legally qualified person, and to confirm that no conflict of interest exists. If the IAS declines to provide even this minimal confirmation, I request that it explains how that position is compatible with transparency and consumer confidence in ADR.

6. This request is directly relevant. The present dispute involves core legal issues: contract formation, the distinction between prohibition and contractual offer, evidential proof of parking as opposed to momentary presence, locus and landowner authority, and compliance with mandatory Code requirements. A legally trained decision-maker will recognise that these are determinative questions and will address them by reasoned analysis. If the IAS intends to dismiss the appeal, I request that it does so by engaging with those legal elements rather than by conclusory statements such as “signage was present” or that the charge was “issued correctly”.

7. The rejection letter asserts that “there is no parking outside of a marked bay” and that the vehicle was “parked in contravention of the terms and conditions as advertised on the signage displayed on site.” That is an unparticularised conclusion. It does not identify (a) the exact boundary of the land the Operator contends is “the site”; (b) the exact position of the vehicle; (c) the wording of the alleged contractual term; (d) the specific sign relied upon and its location relative to the vehicle; (e) how the sign could have been read, understood and accepted at the material time, at night; or (f) evidence of duration showing “parking” as opposed to a brief stop.

8. Failure to prove “parking” as opposed to a momentary stop. The Operator has not proven that the vehicle was parked at all. The circumstances were consistent with a brief stop for passenger collection, in a turning area or junction environment, after manoeuvring. A short stop while a passenger enters a vehicle is not necessarily “parking” in the ordinary meaning of the word and is materially different from leaving a vehicle parked as contemplated by typical private parking terms. The Operator’s evidence must show a meaningful period of parking. If the Operator relies on timestamped photographs, it is put to strict proof that those timestamps evidence a period of presence that is more than momentary and that they show the vehicle stationary in a manner that meets any alleged definition of “parking”. A single instant in time does not prove a contravention of a “no parking” term.

9. Failure to prove the exact location and that it is controlled land within the Operator’s remit. The Operator has not provided a boundary map or a clear site plan showing where the controlled land begins and ends, what parts are said to be roadway, access road, car park or marked bays, or that the alleged location falls within land over which it has authority. This is not a technicality. If the vehicle was on or adjacent to highway land, or on land outside the Operator’s remit, there is no cause of action. The Operator’s rejection ignores this entirely.

10. Failure to prove adequate signage and therefore failure of contract formation. A parking charge can only be recovered as a contractual term if the terms were clearly brought to the driver’s attention before any alleged acceptance. This requires prominent, legible signage positioned so that a driver can read it in time to decide whether to enter or stop. The material time was after 20:48 in early November, in darkness. The Operator has produced no evidence of illumination, reflective material, sign orientation, font size, or readability from a driver’s perspective, nor photographs showing what the driver would have seen on approach or at the stopping position. A generic assertion that “signage is displayed on site” is not evidence of communication of terms.

11. In particular, the Operator must prove the charge term was prominent. The Supreme Court decision in ParkingEye v Beavis turned on unusually prominent signage and a specific commercial justification. It does not permit operators to impose £100 charges on the basis of obscure, unreadable, or unseen terms. Absent strict proof that the charge itself was prominently displayed and legible at the material time, the appeal must be allowed.

12. Forbidding or prohibitory signage and absence of contractual offer. UKCPM commonly uses signage stating “No parking”, “No stopping” or “No parking outside marked bays” on roadways or access roads. Such wording is prohibitory and incapable of forming a contractual offer to park for a fee. A prohibition cannot be accepted; at most it alleges trespass, which only a landholder may pursue and only for nominal damages. The Operator must therefore prove that the signage relied upon constituted a contractual offer capable of acceptance rather than a bare prohibition. If the case is “you must not park here”, no contract exists and the charge is unrecoverable.

13. Failure to evidence landowner authority. The Operator was expressly put to strict proof of landowner authority and compliance with PPSCoP Section 14. The rejection letter does not engage with this point at all. The Operator must produce contemporaneous written authorisation defining the land, the scope of enforcement, any permissions or exemptions, and authority to issue charges and pursue recovery in its own name, together with a boundary map. Without this, the Operator lacks standing and the appeal must be allowed.

14. Failure to engage with the substance of the appeal. The rejection is boilerplate. It does not answer the questions posed about signage adequacy, boundary definition, landowner authority, night-time visibility, the distinction between parking and a brief stop, or the legal nature of the signage. A statement that a PCN was “issued correctly” is not a reasoned determination.

15. Evidence quality and reliability. The Operator is put to strict proof that its evidence is accurate, contemporaneous, correctly timestamped, and contextual. Any photographs must show the vehicle’s position relative to bays or markings, the presence and location of signage, the route of approach, and that signage was readable at night. Close-ups without context do not discharge the burden of proof.

16. Keeper liability under the Protection of Freedoms Act 2012. If the Operator seeks to rely on keeper liability, it must demonstrate strict compliance with Schedule 4 of PoFA. If it does not, then it has no lawful route to pursue the keeper. The Operator’s earlier attempt to compel driver identification strongly indicates it cannot or will not rely on PoFA, a point the IAS is invited to consider.

17. PPSCoP consideration and grace periods. The PPSCoP treats consideration and grace as distinct concepts. Where an alleged contravention involves a very brief presence, the Operator must show it considered whether the event fell within a permitted consideration period. The Operator has produced no evidence of such consideration and has merely asserted a prohibition.

18. Consumer fairness and transparency. The Operator’s references to additional charges and credit impact are noted. Any credit impact can only arise following a court judgment that remains unpaid beyond the statutory period. Template wording implying otherwise is misleading and relevant to credibility.

19. Remedy sought. The Operator has failed to prove contract formation, failed to prove standing or landowner authority, failed to prove that the vehicle was parked rather than briefly stopped, and failed to rebut the substantive points raised. The IAS is invited to allow the appeal and direct cancellation of the PCN. In the alternative, the IAS is invited to require production of the landowner contract and boundary map, a full site plan with sign locations, contemporaneous legible photographs of the signage relied upon, and contextual photographs showing the vehicle’s position in night-time conditions. In the absence of that evidence, the appeal must be allowed.
Never argue with stupid people. They will drag you down to their level and then beat you with experience” - Mark Twain

Sorry for the delay in replying, I was not able to submit my response to the IAS until 06/01/2026. I had the following Operator Prime Facie case come through yesterday.....
-------------------------------------------------------
The operator made their Prima Facie Case on 12/01/2026 13:11:37.

The operator reported that...
The appellant was the keeper.
The operator is seeking keeper liability in accordance with PoFA..
The Notice to Keeper (Non-ANPR) was sent on 04/11/2025.
The ticket was issued on 30/10/2025.
The charge is based in Contract.

The operator made the following comments...
The driver has parked outside of a marked bay.

The appellant has parked within clear view of our sign and there is clear signage throughout the car park. This can be seen in the attached document ‘70130977'.

Signage clearly states "YOU MUST PARK WHOLLY WITHIN A MARKED BAY. NO PARKING ON ROADWAYS / YELLOW LINES / PAVED / HATCHED OR LANDSCAPED AREAS".

It is the driver's responsibility to ensure the vehicle is parked wholly within a designated parking area/bay, prior to parking within a restricted area.

The Registered Keeper did not name the Driver, therefore, as we have fully complied with Schedule 4 of PoFA 2012, we are holding the Registered Keeper liable for this PCN.

The site in question has been audited and approved by our governing body; therefore, it meets the requirements of their Code of Practice. Our signage on site is at industry standard and contains full and legible terms and conditions of parking; these are also clearly positioned so that they are obvious to the motorist. The Code clearly states, "The IPC will audit signage to ensure that the Terms and Conditions are suitable to form the basis of a contract and to make certain that they are clear, concise, unambiguous, and not misleading".

The signage on site complies with current regulations and is sufficient to have brought the terms of parking to the driver's attention. The signage is neither misleading nor unclear and exists in the immediate vicinity of the Appellant's vehicle.

All signage is visible during night time hours. Illumination from street lighting and vehicle headlights ensures that the signage remains clearly legible.

The courts have interpreted parking as including stopping, so long as the vehicle is stationary and in a fixed position for a period of time, no matter how short or whether the vehicle remains occupied or vacant. The photographs demonstrate the Appellant's vehicle was stationary for at least 6 minutes; therefore, the vehicle is parked.

By parking and remaining on the site, the Driver has entered into a contract as outlined by the signage and agreed to comply with its terms. The signage clearly states the terms and conditions of parking, and this Parking Charge Notice (PCN) has been issued under Contract Law. Given the clarity of the signage, the driver had ample opportunity to decide not to park and exit the site, thereby avoiding liability for a PCN.

By the appellant parking at the restricted area, they have contractually agreed to pay the parking charge notice.
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As part of the response they have provided the following documents:
Case Pack
https://drive.google.com/file/d/1sC-QdAUA311J45BeOUtRYewLxE_yWaBK/view?usp=sharing

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Google's AI is suggesting the following response:

Appellant’s Rebuttal to Operator’s Prima Facie Case

1. Failure to Observe Mandatory Consideration Period

The Operator’s evidence confirms a total observation period of only six minutes. Under Section 5.1 and Annex B (Table B.1) of the Single Code of Practice (June 2024), a mandatory Consideration Period must be granted. Section 2.9 defines this as the time needed for a driver to "read and understand the applicable terms and conditions and decide whether to accept them."

Given the darkness at 20:48 on 30th October 2025, six minutes is objectively insufficient to navigate the site, locate the sign, and digest the terms. By their own admission, the Operator issued this charge before the mandatory minimum period had elapsed.

2. Failure of Proof: Vehicle Location vs. Site Boundaries

The Operator has provided in evidence a site map entitled 'Dot Map' , 'Queens Road - Dot Map' showing a red-line boundary. However, Exhibit 1 (the PCN) fails to provide a contextual, wide-angle photograph showing the vehicle’s position relative to these specific boundaries. The images provided are tight, low-resolution crops that do not distinguish between the private land and the immediately adjacent public highway.

I put the Operator to strict proof that the vehicle was entirely within the red-line boundary. In the absence of such evidence, the burden of proof is not met.

3. Distinction Between "Stopping" and "Parking"

The Operator incorrectly asserts that "stopping... no matter how short" constitutes parking. I draw the Assessor's attention to the persuasive appeal court judgment in Jopson v Homeguard [2016] B9GF0A9E (Attached).

HHJ Harris QC ruled (Para 20) that "merely to stop a vehicle cannot be to park it." * A six-minute stop for passenger collection is a "stop" in the course of driving (Section 2.35 of the Code) and not "parking" as defined in Section 2.19.

4. Prohibitory Signage and Lack of Standing
The Operator’s signage included in it's evidence as 'Revised CCTV A Sign 2022' explicitly states: “NO PARKING ON ROADWAYS / YELLOW LINES.” * Under PCM-UK v Bull et al [2016], it was established that "forbidding" signage cannot form a contractual offer. One cannot contract to do that which is forbidden.

This is a matter of Trespass, not Contract Law. As the Operator is not the Landowner and has provided no unredacted evidence of a deed specifically granting them the right to sue for trespass in their own name, they have no standing to bring this claim.

5. Inadequate Illumination and "Camera Vision"

The Operator relies on images from high-sensitivity CCTV/ANPR cameras (referenced in Section 2.26 of the Code).
These systems use digital enhancement and infrared sensors to "see" in the dark. This does not replicate human visibility.

Section 3.1.6 requires signs to be legible in all lighting conditions. The Operator has produced no non-enhanced evidence proving the terms were prominent and readable to a human motorist at 20:48, failing the test of prominence in ParkingEye v Beavis [2015].

Conclusion
The Operator has admitted to a timeframe that breaches the mandatory Consideration Period, failed to prove the vehicle was within the contractual boundary, and relied on prohibitory signage for which they lack standing to enforce. I invite the Assessor to allow the appeal.

Thoughts?  ;D Thanks in advance?