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       #Post#: 12294--------------------------------------------------
       Civil Enforcement Newly Infested Car Park
   DIR By: DW190
       Date: December 12, 2023, 6:19 pm
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       Grandaughters car got a ticket on this recently infested car
       park by CE.  The access to the car park is from a side street
       and not from the address shown on the PCN.  The PCN also shows a
       charge to be added should it go to Debt Collection Agents.
       Links to the PCN below.  Photos of car park will be added later.
  HTML https://1drv.ms/i/s!AsPjQGVPpU0yxjUvAMr9PphFQR_s?e=J92rF9
  HTML https://1drv.ms/i/s!AsPjQGVPpU0yxjZtP9W03xIOn3ZC?e=tUOyFy
       Thanks for looking.
       #Post#: 12298--------------------------------------------------
       Re: Civil Enforcement Newly Infested Car Park
   DIR By: DWMB2
       Date: December 12, 2023, 6:41 pm
       ---------------------------------------------------------
       We will need to see photos of the car park and in particular the
       signage, its layout and its contents.
       Whilst we're waiting for that - I can't see any obvious
       technical defects with the notice, it would appear to be PoFA
       compliant in order for the Registered Keeper to be held liable.
       Can you tell us a little more about the parking event (i.e. why
       the vehicle was parked there, if they had, or attempted to get,
       the 'permit' that the PCN says was required etc.) to see if that
       offers any meritorious defence?
       #Post#: 12352--------------------------------------------------
       Re: Civil Enforcement Newly Infested Car Park
   DIR By: DW190
       Date: December 13, 2023, 9:49 am
       ---------------------------------------------------------
       Heres a link to the pics of the site.  As you enter from one
       side the entrance signs are not fully visible and the signs
       within the site are minute print.
  HTML https://1drv.ms/f/s!AsPjQGVPpU0yxjgiYyBMW8cmpGb2?e=u2tCkx
       #Post#: 12354--------------------------------------------------
       Re: Civil Enforcement Newly Infested Car Park
   DIR By: DWMB2
       Date: December 13, 2023, 10:13 am
       ---------------------------------------------------------
       --- Quote from: DWMB2 link ---
       >
       > Can you tell us a little more about the parking event (i.e.
       why the vehicle was parked there, if they had, or attempted to
       get, the 'permit' that the PCN says was required etc.) to see if
       that offers any meritorious defence?
       >
       --- End Quote ---
       We could do with the answer to this to see what other avenues
       there are to explore.
       I'm not sure there's much prospect in the argument around the
       location being inaccurate. The Protection of Freedoms Act
       Schedule 4 says that they must 'specify' the relevant land on
       which the parking incident took place, if they want to hold the
       registered keeper liable. I think it might be difficult to argue
       successfully that the location given fails to do that, but see
       if others have differing views.
       From what you've shown us so far, the arguments that your
       granddaughter could use are:
       Signage visibility:
       I can see how the entrance signage could be missed if entering
       the car park from the angle shown in your first image. Although
       it might be difficult to argue that the signage was not there to
       be seen - despite being a small car park, in addition to the
       entrance sign you appear to have shown us another 4 signs. Some
       of those could of course have been obscured by cars, but at
       least one is raised up on a pole.
       Forbidding signage:
       The signage mentions the car park is for Permit Holders Only. It
       is therefore not clear what consideration is being offered to
       non-permit holders. The signage could therefore be argued to be
       forbidding and therefore unable to create a contract. No
       contract = no money owed. The downside of this argument is that
       neither CE nor POPLA would accept it, so your granddaughter
       would need to be prepared for the potential of having to argue
       this to a judge in the county court (small claims track), CE can
       be litigious.
       #Post#: 12372--------------------------------------------------
       Re: Civil Enforcement Newly Infested Car Park
   DIR By: DW190
       Date: December 13, 2023, 1:24 pm
       ---------------------------------------------------------
       --- Quote from: DWMB2 link ---
       >
       >
       > Can you tell us a little more about the parking event (i.e.
       why the vehicle was parked there, if they had, or attempted to
       get, the 'permit' that the PCN says was required etc.) to see if
       that offers any meritorious defence?
       >
       --- End Quote ---
       The driver has parked there many times before CE were contracted
       and was unaware there had been any change until the RK received
       the PCN.
       I have established that the land is owned by a small investment
       Company and not the business on the notice.  It doesnt show any
       lease on Land Registry, only the title of the Investment Co.
       #Post#: 12437--------------------------------------------------
       Re: Civil Enforcement Newly Infested Car Park
   DIR By: DWMB2
       Date: December 14, 2023, 10:28 am
       ---------------------------------------------------------
       OK - It would seem then that they did not have a 'legitimate'
       reason for parking on the private land, so no avenues in that.
       Looking at ownership, I imagine the Land Registry would not tell
       you if the restaurant are renting the land. Civil Enforcement
       will need a contract with the landholder allowing them to issue
       parking charges. They won't show you a copy, you'd need to
       appeal, be rejected, and then appeal to POPLA putting Civil
       Enforcement to proof that they have such a contract. This is of
       course a risk.
       #Post#: 12445--------------------------------------------------
       Re: Civil Enforcement Newly Infested Car Park
   DIR By: Nosy Parker
       Date: December 14, 2023, 1:13 pm
       ---------------------------------------------------------
       --- Quote from: DW190 link ---
       >
       > The driver has parked there many times before CE were
       contracted and was unaware there had been any change until the
       RK received the PCN.
       >
       --- End Quote ---
       There might be a bit of mileage in this (when coupled with the
       poor signage at the entrance used by the driver). As a member of
       the BPA, the operator is obliged to comply with the BPA AOS Code
       of Practice, section 19.10 of which reads as follows:-
       19.10 Where there is a change in the terms and conditions that
       materially affects the motorist then you must make these terms
       and conditions clear on your signage. Where such changes impose
       liability where none previously existed then you must consider a
       transition to allow regular visitors to the site to adjust and
       familiarise themselves with the changes. Best practice would be
       the installation of additional/temporary signage at the entrance
       and throughout the site making it clear that new terms and
       conditions apply. This will ensure such that regular visitors
       who may be familiar with the previous terms become aware of the
       new ones.
       Can the driver argue that the landowner previously permitted
       unrestricted parking and insufficient notice was given for the
       change?  Just a thought...
       #Post#: 12448--------------------------------------------------
       Re: Civil Enforcement Newly Infested Car Park
   DIR By: DWMB2
       Date: December 14, 2023, 2:01 pm
       ---------------------------------------------------------
       --- Quote ---
       > Can the driver argue that the landowner previously permitted
       unrestricted parking
       --- End Quote ---
       It's an avenue to explore.
       Although I note from Google Street View that before the arrival
       of Civil Enforcement there appeared to be a couple of fairly
       conspicuous signs saying "TURKIS CHARGRILL PRIVATE PARKING".
       This isn't of course a means of enforcement, nor does it
       diminish the requirement to make a change in T&Cs clear, but
       might lead an adjudicator or judge to disagree that the
       landowner previously accepted unrestricted parking.
       #Post#: 12454--------------------------------------------------
       Re: Civil Enforcement Newly Infested Car Park
   DIR By: DW190
       Date: December 14, 2023, 3:51 pm
       ---------------------------------------------------------
       Land Registry Doc attached for the land
       Companies House for the business:
  HTML https://find-and-update.company-information.service.gov.uk/company/14257192/officers
       Somewhere along the line a contract must flow from the land
       owner.  Nothing on Land Reg doc indicates any lease.
       As per the previous signs on street view an estate agent
       appeared to share the car park.  The estate agent is still there
       but their sign have been removed from the car park.
       I may give it a run and put them to strict proof that a contract
       flows from the landowner.
       [attachment deleted by admin]
       #Post#: 12457--------------------------------------------------
       Re: Civil Enforcement Newly Infested Car Park
   DIR By: DWMB2
       Date: December 14, 2023, 4:17 pm
       ---------------------------------------------------------
       --- Quote from: DW190 link ---
       >
       > I may give it a run and put them to strict proof that a
       contract flows from the landowner.
       >
       --- End Quote ---
       Just for the sake of clarity, if the notice is addressed to your
       granddaughter, then any appeal should be in her name, Civil
       Enforcement won't entertain one in your name.
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