Did you simply send the appeal I suggested as your IAS appeal? If not, please show us what you sent to the IAS.
You must highlight the points that you raised where they have not been responded to or the response given is wrong. For example, point #8 in VCS's response:
8. Vehicle Control Services Ltd is a wholly owned subsidiary of Excel Parking Services Ltd and operates as a group company. Furthermore, the signs clearly advise “By entering and remaining in this private car park you, the driver, are entering into a contract with Vehicle Control Services Ltd and you agree to pay a charge if you fail to comply with the Terms and Conditions”.
You would respond as follows:
The appellant notes with concern the vexatious and misleading behaviour exhibited by Vehicle Control Services Ltd (VCS), a company whose reputation within the parking enforcement industry is well-documented. VCS’s practices often operate on the margins of legality, and their conduct in this case, particularly in Point 8 of their rebuttal, exemplifies this. By asserting that they can enforce a contract under the name of their sister company, Excel Parking Services Ltd—a completely separate legal entity with its own registration number at Companies House—VCS demonstrates a blatant disregard for the principles of contract law and due process.
This approach constitutes a flagrant abuse of process. VCS’s argument is not only legally untenable but also indicative of a broader pattern of vexatious enforcement. It is deeply troubling that a company should present such an argument, which appears either to misunderstand or, more likely to deliberately misrepresent basic legal principles regarding contract formation and the distinction between separate corporate entities.
The appellant also questions the impartiality and legitimacy of the Independent Appeals Service (IAS). The IAS’s well-documented appeal success rate, which reportedly stands at less than 5%, undermines any claims of "independence". The anonymity of IAS adjudicators and the lack of transparency regarding their qualifications or legal training further erode confidence in this process. This “kangaroo court” system serves to prioritise the interests of parking operators—its financial backers—over fair and impartial adjudication.
Despite these systemic flaws, the appellant maintains that this case is so clear-cut that even the IAS should recognise the fundamental legal error in VCS’s arguments. Should the IAS fail to do so, the appellant is prepared to contest this matter in the County Court, where the integrity of the legal process will ensure a fair hearing. The appellant is fully aware that IAS decisions are not binding and will not treat an adverse outcome as the final resolution of this dispute.
Also, in point 14 of VCS's response where they state:
14. A copy of our authority to manage parking on this site was supplied as part of the IPC audit process and is available solely to the Adjudicator for their perusal. As this is a commercially sensitive document, and is irrelevant to the issues at hand, this is not provided as evidence in this appeal, which may be accessed and circulated by the appellant.
You could respond with the following:
In Point 14 of their response, VCS asserts that their authority to manage parking on this site has been supplied as part of the IPC audit process and is available solely to the adjudicator for review. They claim this document is "commercially sensitive" and therefore not provided to the appellant. This stance is a blatant abuse of process and a direct affront to the principles of transparency and fairness.
The appellant maintains that VCS is not the named operator on the contract purportedly flowing from the landowner, and their refusal to evidence this contract is unacceptable. Contract law requires clarity and proof of authority, particularly when a party seeks to enforce terms against another. VCS’s claim that this document is “irrelevant” is not only absurd but also legally unsustainable. The existence and terms of such a contract are central to this dispute. Without it, VCS has no standing to enforce the Parking Charge Notice.
By insisting that the contract is only accessible to the adjudicator, VCS is effectively asking for blind trust while denying the appellant a fair opportunity to challenge their claim. This is not just unfair; it is procedurally improper. Any adjudicator with even a basic understanding of legal principles would recognise that this approach would not stand up to scrutiny in a court of law. Such secrecy would be entirely unacceptable in a legitimate legal process, where both parties are entitled to see and challenge all evidence presented.
Should the IAS accept VCS’s argument on this point, it will only further confirm what many already know: the IAS is not truly independent but operates as a mechanism to protect the interests of parking operators. The appellant is fully aware that the IAS decision is not binding and will not treat it as the final resolution of this matter. Instead, the appellant invites VCS to escalate this to the only truly independent dispute resolution service—the County Court—where a qualified judge will undoubtedly scrutinise and understand the significant contractual and legal failings in VCS’s position.
So, now that you understand how to respond, you can refer to any other posts where VCS have either not responded/rebutted your points or they are making points that are not based on law or their CoP.
