Free Traffic Legal Advice

Keeper received PCN from UKPS for "contravention of terms: Permit Required" at Eaton House near Coventry Railway Station, see https://imgur.com/a/aXDxnV7

Looking at date/time stamps on images the driver was on site for 34 seconds total.  In this time it appears they drove onto site, possibly dropped a passenger, performed a three point turn, and then left site.

Keeper has not responded to PCN. 

Also in images is sign from car park, and a view from the street entrance.

Appears to be a couple of points:
1) 34 seconds on site is nowhere near long enough to try and read and agree to the terms and conditions.
2) There are no entrance signs to site and the signs within site are not large.
3) PCN does not appear to comply with all aspects of PoFA section 9.

Next step (if any) for keeper?

Thank you, confirms what I suspected.

I'll report on the outcome.

Check to see what evidence they have that the vehicle was at the location for 34 seconds. If they've only a single photo, they can't even even prove that it was there for more than 1 second.

How out of sync are the times?

UKPS internal appeal rejected:

"Thank you for your appeal.
 
Having noted your comments, and checking the evidence gathered when issuing the Parking Charge, we are satisfied that the Parking Charge has been issued correctly and your appeal is rejected.
 
The basis of your appeal is factually incorrect, this parking charge has been issued in line with POFA 2012 and as a result, we will continue to hold the registered keeper liable for this charge unless we are informed that someone, other than the registered keeper was driving. The terms and conditions of this private land state that a permit must be held to park on site. This private land is not a dropping off or picking up area for commuters. Drivers are given a consideration period to read the signage and to make an informed decision as to remain on site or leave, if this consideration period is used in any other way than what it was meant for, the charge is issued.  As the vehicle does not hold a permit, the terms and conditions were breached.
 
Please be advised that all photographic evidence can be viewed by typing: pay.theukps.com in to your top address browser.
 
We now require payment of the parking charge to be made within 28 days of this letter."

This is really interesting, I have also been involved in discussions with UKPS for doing a 80sec manoeuvre in this car park. I have gone through the appeals process which got rejected and today I have received a debt recovery plus letter requesting payment of £160.00 to be paid by the 22/11/2024. I have now contacted Debt Recovery Plus and informed them that I wish to have my day in court. After speaking to a solicitor and the citizen advice bureau I have decided to have my day in court.

This is really interesting, I have also been involved in discussions with UKPS for doing a 80sec manoeuvre in this car park. I have gone through the appeals process which got rejected and today I have received a debt recovery plus letter requesting payment of £160.00 to be paid by the 22/11/2024. I have now contacted Debt Recovery Plus and informed them that I wish to have my day in court. After speaking to a solicitor and the citizen advice bureau I have decided to have my day in court.

Please start your own thread. You should never, ever, ever, EVER communicate with a useless debt collector, especially DRP. The CAB are useless when it comes to Parking Charge Notices (PCN) issued by unregulated private parking companies.

If you want bespoke advice, start your own thread.

Respond with the following by email to info@moorsidelegal.co.uk and CC in yourself:

Subject: Formal Response to Defective Letter of Claim – Your Ref: 4066166

Dear Sirs,

Re: Letter of Claim dated 22 April 2025. Your Ref: 4066166

I refer to your Letter of Claim.

I confirm that my address for service at this time is as follows, and I require you to erase any outdated or incorrect address information from your records to ensure compliance with your obligations under the UK GDPR and the Data Protection Act 2018:

[Insert Correct Address]

Please note that the alleged debt is entirely disputed, and any proceedings issued will be robustly defended.

Your Letter of Claim is defective and fails to comply with several fundamental requirements of the Pre-Action Protocol for Debt Claims (“PAPDC”), as follows:

• It does not clearly explain the legal basis for the alleged debt, nor does it distinguish whether the principal sum is being claimed as damages for breach of contract or as consideration for a purported parking contract, contrary to paragraph 3.1(a) of the PAPDC.
• It fails to enclose copies of key documents which the Claimant intends to rely upon, including the alleged contract (signage), the Notice to Driver or Notice to Keeper, and a proper statement of account setting out any payments, adjustments, or the composition of the debt, as required by paragraph 5.1 of the PAPDC.
• It includes a grossly inflated sum (£170) with no proper explanation or justification for the additional £70 added to the original parking charge. This is in breach of the requirement under paragraph 3.1(b) to set out how any such sums have been calculated. Furthermore, such practices have been condemned by Government as "extorting money from motorists."
• It makes misleading and premature threats of additional costs and fees before a claim has even been issued, which is contrary to the spirit and purpose of the PAPDC.

In addition, under the Pre-Action Protocol for Debt Claims, I require specific answers to the following questions:

1. Does the additional £70 represent what you describe as a “Debt Recovery” fee? If so, is this figure net of or inclusive of VAT? If inclusive, please explain why I, as the alleged debtor, am being asked to cover your client’s VAT liability.
2. Regarding the principal sum of the alleged Parking Charge Notice (PCN), is this being claimed as damages for breach of contract, or pleaded as consideration for a purported contract? Kindly state this clearly and unequivocally.

I caution you against responding with vague or boilerplate language. I am fully aware of the serious implications. It appears that by simultaneously claiming that PCNs are exempt from VAT while inflating the "debt recovery" element, your client — with your assistance — may be facilitating evasion of VAT properly due to HMRC. Such conduct raises significant concerns regarding the legality and ethics of your client's practices.

I strongly advise your client to cease and desist. Should this matter proceed to litigation, you can be assured that these issues will be robustly raised before the court, along with appropriate submissions concerning unreasonable conduct under CPR 27.14(2)(g).

Yours faithfully,

[Your Name]