Hello, I am seeking advice on how to formally appeal two recent Parking Charge Notices (PCNs) received via post (Notice to Keeper).
PCN 1 21/11/2025 19:59:33 01:33:04 (next day) Failure to pay using the online system
PCN 2 22/11/2025 17:53:53 01:33:04 (next day) Failure to pay using the online system
(more probably on the way)
The charges were issued by UKCPS Ltd for parking at the Crescent Gardens Pay to Park, HG1 2SG, which is private land regulated by ANPR cameras.
Key Facts and Context:
Crucial Signage Defect: The most important factor is the confusing layout of the car park. The brief 'private parking' signage is placed where council-owned parking spaces are RIGHT NEXT to it. Given that there are three connecting roads, the signage fails to clearly and unambiguously identify the boundary where the private land (and its associated terms) begins and where the council-controlled area ends. This confusion prevented the formation of a clear contractual agreement.
Employment and Mitigation: I am a local worker, employed as a doorman (bouncer) in Harrogate, and I rely on local parking when working late shifts.
Reasonable Belief/Night Time: I was under the reasonable, but mistaken, belief that the requirement to pay for parking ceased in the evening, as is the case for council-controlled parking nearby. The signs for 24-hour enforcement and the online payment system were not adequately illuminated or legible at dusk/night to override this reasonable assumption.
Notice Received: I did not receive any ticket on my windscreen; I was made aware of the charges only through the Notice to Keeper letters dated 08/12/2025. I anticipate receiving additional PCNs.
My Plan and Question:
I understand that UKCPS is a litigious IPC member and the advice is not to ignore these charges. I intend to appeal formally, challenging Keeper Liability (PoFA) and arguing that no valid contract was formed due to the fundamentally confusing and ambiguous demarcation of the private land, compounded by the inadequate signage visibility at night.
I would appreciate advice on the following:
How best should I frame the appeal to UKCPS based on the confusing boundary/demarcation with the adjacent council parking?
Should I submit one combined appeal for both tickets, or two separate appeals?
Are there specific legal precedents or IAS decisions I should cite regarding signage failing to clearly delineate the extent of the private land?
Thank you in advance for any guidance.
