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To IPS

Appeal against PCN from UPCPS - Notice to Keeper (Postal - PoFA) issued on private land

Reason for issue: no stopping
Name and address of site: Leeds City Station, LS1 4DY


UKCPS sent me a Parking Charge Notice letter dated 17th December 2025 with photos relating to 5th December 2025.  They had used the vehicle registration number and requested the registered keeper's name and address details from the DVLA.

I am the registered keeper of the vehicle. I have not confirmed to UKCPS who the driver was at that time on that date.

I submitted an appeal to UKCPS on 27/12/2025 via their website.  Here is a copy of my appeal to UKCPS:

APPEAL TO UKCPS:
I am the registered keeper. UKCPS cannot hold a registered keeper liable for any alleged contravention on land that is under statutory control (until 26 December 2025). As a matter of fact and law, UKCPS will be well aware that they cannot use the PoFA provisions because Leeds Station is not 'relevant land'.

If Leeds Station wanted to hold owners or keepers liable under Railway 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 UKCPS is not the station owner and your 'parking charge' is not and never attempts to be a penalty. It is created for UKCPS’s own profit (as opposed to a byelaw's penalty that goes to the public purse) and UKCPS 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 Notice to Keeper can only hold the driver liable. UKCPS have no hope should you try to litigate, so you are urged to save us both a complete waste of time and cancel the PCN.


Your photo evidence showed a stop of 5 seconds only where the vehicle car door remained closed.

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UKCPS replied to me on 20th January 2026 by email saying my appeal to them was unsuccessful in their opinion.

I request that the IPA looks at the photo evidence to recognise the following:

1/ The vehicles was stopped for 5 seconds only.
2/ The vehicle was not purposefully stopped or waiting. 
3/ The car doors remained closed. 
4/ The UKCPS photos show there were no people outside of the vehicle intending to get in.  It is an empty road and pavement.
5/ The first photo shows the engine lights are on. The photo showing it at 5 seconds after shows the engine lights are off. It appears plausible that the vehicle stalled the engine and had to restart the power.
6/ A 5 second stop is not violating any bylaws on private land.

Why have you moved away from your appeal point, which is that it’s irrelevant what the driver did or did not do, you as registered keeper can not be liable for the driver’s actions?
If you give the IAS all these points about the driver, they’ll reject the appeal based on them.

Draft 2 Appeal to the IPS -

thanks for earlier comments to help me do a good appeal.
I don't need to include the last bit about the driver's actions, it just boils my blood, but I could remove those points about the driver...


To IPS

Appeal against PCN from UPCPS - Notice to Keeper (Postal - PoFA) issued on private land

Reason for issue: no stopping
Name and address of site: Leeds City Station, LS1 4DY


UKCPS sent me a Parking Charge Notice letter dated 17th December 2025 with photos relating to 5th December 2025.  They had used the vehicle registration number and requested the registered keeper's name and address details from the DVLA.

I am the registered keeper of the vehicle. I have not confirmed to UKCPS who the driver was at that time on that date.

I submitted an appeal to UKCPS on 27/12/2025 via their website.  Here is a copy of my appeal to UKCPS:

APPEAL TO UKCPS:
I am the registered keeper. UKCPS cannot hold a registered keeper liable for any alleged contravention on land that is under statutory control (until 26 December 2025). As a matter of fact and law, UKCPS will be well aware that they cannot use the PoFA provisions because Leeds Station is not 'relevant land'.

If Leeds Station wanted to hold owners or keepers liable under Railway 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 UKCPS is not the station owner and your 'parking charge' is not and never attempts to be a penalty. It is created for UKCPS’s own profit (as opposed to a byelaw's penalty that goes to the public purse) and UKCPS 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 Notice to Keeper can only hold the driver liable. UKCPS have no hope should you try to litigate, so you are urged to save us both a complete waste of time and cancel the PCN.


Your photo evidence showed a stop of 5 seconds only where the vehicle car door remained closed.

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

UKCPS replied to me on 20th January 2026 by email saying my appeal to them was unsuccessful in their opinion.

I request that the IPS considers this appeal based on the following:

1/ UKCPS cannot hold a registered keeper liable for any alleged contravention on land that is under statutory control (until 26 December 2025).
2/ As a matter of fact and law, UKCPS cannot use the PoFA provisions because Leeds Station is not 'relevant land'.
3/ If Leeds Station wanted to hold owners or keepers liable under Railway 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 UKCPS is not the station owner and the UKCPS 'parking charge' is not and never attempts to be a penalty.
4/ The CPN is created for UKCPS’s own profit (as opposed to a bylaw's penalty that goes to the public purse) and UKCPS has relied on contract law allegations of breach against the driver only.
5/ The registered keeper cannot be presumed or inferred to have been the driver, nor pursued under some twisted interpretation of the law of agency.
6/ The UKCPS Notice to Keeper can only hold the driver liable.
7/ UKCPS has not been notified of the driver's identity.


Noteworthy to show how ridiculous the UKCPS parameters are:

a) The vehicles was stopped for 5 seconds only as shown in the UKCPS photo evidence (4 photos).
b) The vehicle was not purposefully stopped or waiting.
c) The car doors remained closed.
d) The UKCPS photos show there were no people outside of the vehicle intending to get in.  It is an empty road and pavement for the duration of the 5 seconds.
e) The first photo shows the engine lights are on. The photo showing it at 5 seconds after shows the engine lights are off. It appears plausible that the vehicle stalled the engine and had to restart the power.

Thank you jfollows.

I will follow your advice. I want to do the best and keep it to the point.
Thank you for correcting to IPS.
I'm going to send it off now.
I really appreciate your help with this.

Thanks Intercity

I have sent in the appeal now.  From what I understand, whatever I write wont stop the charge but it's good to have your point noted in case it progresses to the SCC. 

If their evidence is all about what the driver did, and does not respond to the PoFA main point, then you should respond to the effect that by not responding they accept the point and therefore the stuff about the driver is irrelevant. But that’s only a guess for now - the common tactic we’ve already seen is to ignore things that go against them.

You’re still trying to make this too complicated.

Your appeal stated that they could not use PoFA to transfer liability to you.

They now confirm to the IAS that you were correct, so should have upheld your appeal initially, and the IAS should also uphold your appeal.

You also need to rubbish their statement “liability is assumed to rest with the registered keeper unless evidence is provided to show that they were not the driver”. Liability rests with the driver, and can only be transferred to the registered keeper if the provisions of PoFA are all followed, which in this case they can not be and UKCPS has admitted this.

When you say “Non-ANPR” is that correct, or did you mean “Non-PoFA”?

PoFA is completely relevant, and since they now admit they’re not using its provisions (as they couldn’t, anyway, but they originally claimed they could) they can’t transfer liability to you, the registered keeper, which is what you said at the start.

The UKCPS finish their evidence by stating:

"The charge was issued correctly in accordance with site regulations and the IPC Code of Practice and remains valid and enforceable."

The UKCPS has not dropped the charge.