That appeal should cover the important points, although I'd be tempted to tweak the wording slightly to make it clear that whilst railway land is now relevant land, it wasn't at the time, and also that even if it were relevant land, the notice was issued too late. For example:
I am the registered keeper. UKCPS cannot hold a registered keeper liable for any alleged contravention on land that is under statutory control. As a matter of fact and law, UKCPS will be well aware that they cannot use the PoFA provisions because Leeds Station was not 'relevant land' on the date of the alleged contravention.
Although the definition of 'relevant land' was amended by The Protection of Freedoms Act 2012 (Definition of Relevant Land) (Amendment) Order 2025 to include railway land, this amendment only came into force on 26th December 2025, and is not retrospective. This alleged parking event took place on 21st December 2025, before the amendment came into force.
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 bylaws penalty that goes to the public purse) and UKCPS has relied on contract law allegations of breach against the driver only.
In addition, even if this had been relevant land at the time (which is denied), the notice was issued too late to have been delivered within the 'relevant period' of 14 days, as defined by PoFA.
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. 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.
