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       #Post#: 120630--------------------------------------------------
       Re: NPC- overstay in a car park without ANPR - Watford
   DIR By: pesonkute
       Date: June 3, 2026, 12:48 pm
       ---------------------------------------------------------
       Greeting to all members of this forum
       I have got a PCN rejected by National Parking Control by
       overstaying.
       The carpark does  not has ANPR and the staffs just take the
       pictures and report to parking operator.
       Below is my appeal which was rejected, so this time I am going
       to appeal in theIAS.org.
  HTML https://i.ibb.co/hFBhRhsn/Screenshot-2026-06-03-at-18-31-44.png
       I also have a leg to stand is that my car just come back in an
       hour which is no restriction so there are two event of parking.
       I hope some could give me some idea for the appeal at the IAS
       even I know they will reject anyway.
       Many thanks
       Below is the PCN
  HTML https://i.ibb.co/HLQrd5yc/IMG-9138.jpg
  HTML https://i.ibb.co/N2Pt7R3Q/IMG-9139.jpg
  HTML https://i.ibb.co/pjtzrC6h/conditions.jpg
       #Post#: 120631--------------------------------------------------
       Re: NPC- overstay in a car park without ANPR
   DIR By: jfollows
       Date: June 3, 2026, 12:51 pm
       ---------------------------------------------------------
       There is no need to mention PoFA 2012, simply implementing its
       requirements is sufficient.
       So:
       --- Quote ---
       > (2)The notice must—
       >
       > (a)specify the vehicle, the relevant land on which it was
       parked and the period of parking to which the notice relates;
       >
       > (b)inform the keeper that the driver is required to pay
       parking charges in respect of the specified period of parking
       and that the parking charges have not been paid in full;
       >
       > (c)describe the parking charges due from the driver as at the
       end of that period, the circumstances in which the requirement
       to pay them arose (including the means by which the requirement
       was brought to the attention of drivers) and the other facts
       that made them payable;
       >
       > (d)specify the total amount of those parking charges that are
       unpaid, as at a time which is—
       >
       > (i)specified in the notice; and
       >
       > (ii)no later than the end of the day before the day on which
       the notice is either sent by post or, as the case may be, handed
       to or left at a current address for service for the keeper (see
       sub-paragraph (4));
       >
       > (e)state that the creditor does not know both the name of the
       driver and a current address for service for the driver and
       invite the keeper—
       >
       > (i)to pay the unpaid parking charges; or
       >
       > (ii)if the keeper was not the driver of the vehicle, to notify
       the creditor of the name of the driver and a current address for
       service for the driver and to pass the notice on to the driver;
       >
       > (f)warn the keeper that if, after the period of 28 days
       beginning with the day after that on which the notice is given—
       >
       > (i)the amount of the unpaid parking charges specified under
       paragraph (d) has not been paid in full, and
       >
       > (ii)the creditor does not know both the name of the driver and
       a current address for service for the driver,
       >
       > the creditor will (if all the applicable conditions under this
       Schedule are met) have the right to recover from the keeper so
       much of that amount as remains unpaid;
       > (g)inform the keeper of any discount offered for prompt
       payment and the arrangements for the resolution of disputes or
       complaints that are available;
       >
       > (h)identify the creditor and specify how and to whom payment
       or notification to the creditor may be made;
       >
       > (i)specify the date on which the notice is sent (where it is
       sent by post) or given (in any other case).
       --- End Quote ---
       #Post#: 120636--------------------------------------------------
       Re: NPC- overstay in a car park without ANPR - Watford
   DIR By: pesonkute
       Date: June 3, 2026, 1:03 pm
       ---------------------------------------------------------
       --- Quote from: jfollows link ---
       >
       > There is no need to mention PoFA 2012, simply implementing its
       requirements is sufficient.
       > So:
       > [quote](2)The notice must—
       >
       > (a)specify the vehicle, the relevant land on which it was
       parked and the period of parking to which the notice relates;
       >
       > (b)inform the keeper that the driver is required to pay
       parking charges in respect of the specified period of parking
       and that the parking charges have not been paid in full;
       >
       > (c)describe the parking charges due from the driver as at the
       end of that period, the circumstances in which the requirement
       to pay them arose (including the means by which the requirement
       was brought to the attention of drivers) and the other facts
       that made them payable;
       >
       > (d)specify the total amount of those parking charges that are
       unpaid, as at a time which is—
       >
       > (i)specified in the notice; and
       >
       > (ii)no later than the end of the day before the day on which
       the notice is either sent by post or, as the case may be, handed
       to or left at a current address for service for the keeper (see
       sub-paragraph (4));
       >
       > (e)state that the creditor does not know both the name of the
       driver and a current address for service for the driver and
       invite the keeper—
       >
       > (i)to pay the unpaid parking charges; or
       >
       > (ii)if the keeper was not the driver of the vehicle, to notify
       the creditor of the name of the driver and a current address for
       service for the driver and to pass the notice on to the driver;
       >
       > (f)warn the keeper that if, after the period of 28 days
       beginning with the day after that on which the notice is given—
       >
       > (i)the amount of the unpaid parking charges specified under
       paragraph (d) has not been paid in full, and
       >
       > (ii)the creditor does not know both the name of the driver and
       a current address for service for the driver,
       >
       > the creditor will (if all the applicable conditions under this
       Schedule are met) have the right to recover from the keeper so
       much of that amount as remains unpaid;
       > (g)inform the keeper of any discount offered for prompt
       payment and the arrangements for the resolution of disputes or
       complaints that are available;
       >
       > (h)identify the creditor and specify how and to whom payment
       or notification to the creditor may be made;
       >
       > (i)specify the date on which the notice is sent (where it is
       sent by post) or given (in any other case).
       --- End Quote ---
       [/quote]
       Thank you for your post.
       In this case, this notice issued does not state the period of
       parking (only mentioned "Observation time"), will it be invalid
       ?
       #Post#: 120640--------------------------------------------------
       Re: NPC- overstay in a car park without ANPR - Watford
   DIR By: jfollows
       Date: June 3, 2026, 1:42 pm
       ---------------------------------------------------------
       I would say that the observation time is clearly a period, so
       it’s grasping at straws to state non-compliance on this point
       alone. And it’s just over 2h30m isn’t it?
       #Post#: 120656--------------------------------------------------
       Re: NPC- overstay in a car park without ANPR - Watford
   DIR By: InterCity125
       Date: June 4, 2026, 1:09 am
       ---------------------------------------------------------
       I agree that a 'period pf parking' is demonstrated by the
       notice.
       However, the notice is missing the required mandatory wording
       required by paragraph 9(2)(e).
       9(2)(e) specifies;
       The notice MUST STATE that the creditor does not know both the
       name of the driver and a current address for service for the
       driver.
       There is no such sentence contained in the NtK.
       The NtK is also missing part of the wording required by 9(2)(f).
       #Post#: 121172--------------------------------------------------
       Re: NPC- overstay in a car park without ANPR - Watford
   DIR By: pesonkute
       Date: June 8, 2026, 12:03 pm
       ---------------------------------------------------------
       --- Quote from: InterCity125 link ---
       >
       > I agree that a 'period pf parking' is demonstrated by the
       notice.
       >
       > However, the notice is missing the required mandatory wording
       required by paragraph 9(2)(e).
       >
       > 9(2)(e) specifies;
       >
       > The notice MUST STATE that the creditor does not know both the
       name of the driver and a current address for service for the
       driver.
       >
       > There is no such sentence contained in the NtK.
       >
       > The NtK is also missing part of the wording required by
       9(2)(f).
       >
       --- End Quote ---
       Thank you for pointing it out.
       So in this case, do I have a leg to stand on when appeal with
       IAS ?
       #Post#: 121191--------------------------------------------------
       Re: NPC- overstay in a car park without ANPR - Watford
   DIR By: jfollows
       Date: June 8, 2026, 1:04 pm
       ---------------------------------------------------------
       --- Quote from: pesonkute link ---
       >
       > [quote author=InterCity125
       link=topic=11035.msg120656#msg120656 date=1780553395]
       > I agree that a 'period pf parking' is demonstrated by the
       notice.
       >
       > However, the notice is missing the required mandatory wording
       required by paragraph 9(2)(e).
       >
       > 9(2)(e) specifies;
       >
       > The notice MUST STATE that the creditor does not know both the
       name of the driver and a current address for service for the
       driver.
       >
       > There is no such sentence contained in the NtK.
       >
       > The NtK is also missing part of the wording required by
       9(2)(f).
       >
       --- End Quote ---
       Thank you for pointing it out.
       So in this case, do I have a leg to stand on when appeal with
       IAS ?
       [/quote]
       No, because the IAS is not “independent” and usually sides with
       its paymasters, the parking companies.
       That doesn’t mean you shouldn’t appeal on this basis, because it
       sets out your stall and shows the court in due course that you
       were trying to avoid court. If they go on to take you to court,
       you have a defence which will be the same point.
       The only thing I’d suggest with the IAS appeal is to keep it
       short, and to the point, and only appeal on one or - at worst -
       two points only. 9(2)e and possibly 9(2)f. The reason I say this
       is that if you appeal on lots of points they will pick off the
       easy ones and ignore the hard ones.
       #Post#: 121201--------------------------------------------------
       Re: NPC- overstay in a car park without ANPR - Watford
   DIR By: pesonkute
       Date: June 8, 2026, 1:52 pm
       ---------------------------------------------------------
       --- Quote from: jfollows link ---
       >
       > [quote author=pesonkute link=topic=11035.msg121172#msg121172
       date=1780938180]
       > [quote author=InterCity125
       link=topic=11035.msg120656#msg120656 date=1780553395]
       > I agree that a 'period pf parking' is demonstrated by the
       notice.
       >
       > However, the notice is missing the required mandatory wording
       required by paragraph 9(2)(e).
       >
       > 9(2)(e) specifies;
       >
       > The notice MUST STATE that the creditor does not know both the
       name of the driver and a current address for service for the
       driver.
       >
       > There is no such sentence contained in the NtK.
       >
       > The NtK is also missing part of the wording required by
       9(2)(f).
       >
       --- End Quote ---
       Thank you for pointing it out.
       So in this case, do I have a leg to stand on when appeal with
       IAS ?
       [/quote]
       No, because the IAS is not “independent” and usually sides with
       its paymasters, the parking companies.
       That doesn’t mean you shouldn’t appeal on this basis, because it
       sets out your stall and shows the court in due course that you
       were trying to avoid court. If they go on to take you to court,
       you have a defence which will be the same point.
       The only thing I’d suggest with the IAS appeal is to keep it
       short, and to the point, and only appeal on one or - at worst -
       two points only. 9(2)e and possibly 9(2)f. The reason I say this
       is that if you appeal on lots of points they will pick off the
       easy ones and ignore the hard ones.
       [/quote]
       Totally got it. I am not afraid go to court. Many thanks for
       your advice.
       #Post#: 124781--------------------------------------------------
       Re: NPC- overstay in a car park without ANPR - Watford
   DIR By: pesonkute
       Date: July 15, 2026, 8:00 am
       ---------------------------------------------------------
       --- Quote from: jfollows link ---
       >
       > [quote author=pesonkute link=topic=11035.msg121172#msg121172
       date=1780938180]
       > [quote author=InterCity125
       link=topic=11035.msg120656#msg120656 date=1780553395]
       > I agree that a 'period pf parking' is demonstrated by the
       notice.
       >
       > However, the notice is missing the required mandatory wording
       required by paragraph 9(2)(e).
       >
       > 9(2)(e) specifies;
       >
       > The notice MUST STATE that the creditor does not know both the
       name of the driver and a current address for service for the
       driver.
       >
       > There is no such sentence contained in the NtK.
       >
       > The NtK is also missing part of the wording required by
       9(2)(f).
       >
       --- End Quote ---
       Thank you for pointing it out.
       So in this case, do I have a leg to stand on when appeal with
       IAS ?
       [/quote]
       No, because the IAS is not “independent” and usually sides with
       its paymasters, the parking companies.
       That doesn’t mean you shouldn’t appeal on this basis, because it
       sets out your stall and shows the court in due course that you
       were trying to avoid court. If they go on to take you to court,
       you have a defence which will be the same point.
       The only thing I’d suggest with the IAS appeal is to keep it
       short, and to the point, and only appeal on one or - at worst -
       two points only. 9(2)e and possibly 9(2)f. The reason I say this
       is that if you appeal on lots of points they will pick off the
       easy ones and ignore the hard ones.
       [/quote]
       Hi there. I got the response from IAS with no luck as planned.
       --- Quote ---
       > The Appellant should understand that the Adjudicator is not in
       a position to give legal advice to either of the parties, but
       they are entitled to seek their own independent legal advice.
       The Adjudicator's role is to consider whether or not the parking
       charge has a basis in law and was properly issued in the
       circumstances of each individual case. In all Appeals the
       Adjudicator is bound by the relevant law applicable at the time
       and is only able to consider legal challenges and not factual
       mistakes nor extenuating or mitigating circumstances. Throughout
       this appeal the Operator has had the opportunity to consider all
       points raised and could have conceded the appeal at any stage.
       The Adjudicator who deals with this Appeal is legally qualified
       and each case is dealt with according to their understanding of
       the law as it applies, and the legal principles involved. A
       decision by an Adjudicator is not legally binding on an
       Appellant who is entitled to seek their own legal advice if they
       so wish.
       >
       > In all Appeals the burden of proof is the civil one whereby
       the party asserting a fact or submission has to establish that
       matter on the balance of probabilities. If the parking operator
       fails to establish that a Parking Charge Notice was properly
       issued in accordance with the law, then it is likely that an
       Appeal will be allowed. If the parking operator does establish
       that a Parking Charge Notice was properly and legally issued,
       then the burden shifts to the Appellant to establish that the
       notice was improperly or unlawfully issued and if the Appellant
       proves those matters on the balance of probabilities, then it is
       likely that the Appeal will be allowed. However, the Appeal will
       be dismissed if the Appellant fails to establish those matters
       on the balance of probabilities. The responsibility is at all
       times on the parties to provide the Adjudicator with the
       evidential basis upon which to make a decision.
       >
       > The signs offer the terms for parking. By remaining parked on
       land managed by the Operator, having had notice of the terms,
       the driver agrees to them. In consideration for entering the
       site they agree not to park beyond the maximum permitted time or
       pay the charge. In this way they have entered into a contract
       with the Operator and agreed to be bound by the advertised
       terms.
       >
       > I am satisfied that the signs are clear, numerous and
       unequivocal. This is evidenced by the Operators site map,
       exhibits and images.
       >
       > The Appellant's does not dispute the facts related to the
       contravention, I am unable to allow the appeal on this basis.
       The terms are clear. If the driver stays beyond the maximum
       permitted time they have few options. They could contact the
       Operator and request temporary permission to park.
       Alternatively, they could park elsewhere. Otherwise they could
       remain parked and agree to pay the charge.
       >
       > The Appellant raises as an issue the Protection of Freedoms
       Act 2012 and purports that the Operator has failed to comply
       with the requirements therein. I must point out that whilst the
       Act does need to be complied with in cases where the Operator
       wishes to avail themselves of the keeper liability provisions
       under Schedule 4, they are not obliged to do so where they do
       not. Instead, the operator is entitled to rely either on the
       legal presumption that the keeper of the vehicle was also the
       driver (which they are entitled to do in the absence of credible
       evidence to the contrary) or on an acceptance that they were
       driving at the material time.
       >
       > Turning to the identity of the driver, POFA 2012 and case law
       permits the Operator to hold the registered keeper liable for an
       unpaid parking charge regardless as to whether they are the
       driver or not. The Appellant accepts that they were the keeper
       of this vehicle but denies that at the time of the incident they
       were the driver. In the case of ELLIOTT v LOAKE in 1982 the
       principle was established that in the absence of sufficient
       evidence to the contrary the keeper of a vehicle is assumed to
       be the driver of that vehicle at the time of an incident such as
       arises in this Appeal. The burden of proof is then on the keeper
       of the vehicle to prove on the balance of probabilities that
       they were not the driver at the time of the incident. In this
       case such evidence has not been provided by the Appellant to
       establish that they were not the driver and therefore this
       Appeal is dismissed.
       >
       > The Notice to Keeper is considered in time unless there is
       evidence beyond the Appellant's mere assertion that it was
       received after the second working day. In the absence of such
       evidence I cannot consider the matter further.
       >
       > The Appellant has my sympathy, but the guidance to the appeal
       is clear that I may only consider legal issues not extenuating
       circumstances. The Operator has this discretion, and they
       exercised it in the Appellant's favour, by offering the reduced
       payment. Having rejected this offer the Appellant is now liable
       to pay the full charge.
       --- End Quote ---
       #Post#: 124798--------------------------------------------------
       Re: NPC- overstay in a car park without ANPR - Watford
   DIR By: InterCity125
       Date: July 15, 2026, 9:56 am
       ---------------------------------------------------------
       The Elliot v Loake reference is complete pie in the sky and is
       not relevant because it was a criminal case which turned on the
       facts of the case and not any presumption - IAS continue to
       quote this tosh which therefore confirms that these cases are
       not being assessed by qualified professionals - there's no SRA
       registered individual who would spout this nonsense - they'd
       risk being struck off.
       Elliot v Loake was cited (by a Parking Operator Claimant) in a
       recent court case and the Judge laughed it out describing its
       inclusion in the evidence as inexplicable. Even the parking
       operator's own legal rep agreed with the Judge in that respect.
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