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#Post#: 128915--------------------------------------------------
Cranbrook, Ilford - Cranbrook Primary School - BWLegal on behalf
of UKCPM - No permit
DIR By: Megafish7272
Date: August 26, 2026, 5:30 am
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Hi All,
NtK was issued 16/08/25 with the incident occurring 09-10/08/25.
The NtK confirms using ANPR the car arriving at 22:31 and
leaving at 00:14. The first NtK was received 22/08/25.
A NtK/PCN was issued which I appealed using the following:
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I am the keeper of the vehicle and I dispute your 'parking
charge'. I deny any liability or contractual agreement and I
will be making a complaint about your predatory conduct to your
client landowner.
As your Notice to Keeper (NtK) does not fully comply with ALL
the requirements of PoFA 2012, you are unable to hold the keeper
of the vehicle liable for the charge. Partial or even
substantial compliance is not sufficient. There will be no
admission as to who was driving and no inference or assumptions
can be drawn. CPM has relied on contract law allegations of
breach against the driver only.
The registered keeper cannot be presumed or inferred to have
been the driver, nor pursued under some twisted interpretation
of the law of agency. Your NtK can only hold the driver liable.
CPM have no hope should you be so stupid as to try and litigate,
so you are urged to save us both a complete waste of time and
cancel the PCN.
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As expected, the appeal wasn’t accepted and I have ignored all
the debt collection letters.
Just to clarify, at no point in this process has the driver been
identified.
I’ve now received a letter of claim from bwlegal which notes
‘letter of claim-final notice before legal action escalation’.
They expect a reply via a reply form or for me to pay off the
NtK.
Firstly, is this the actual letter of claim or just the
precursor to it? They do use the term ‘may’. Does that imply
they might not carry this forward depending on my response?
The reply form does allow me dispute the debt and can be done
online, which i intend to do, but i was hoping i could get some
advice to avoid making a complete arse out of myself.
There’s a box for disputing the debt (box D) and a box where i
can request more documents or information (box I).
For box D, i plan on writing:
I dispute the debt because under PoFA Sch 4 para 3(1)(b), a
parking place provided or controlled by a traffic authority is
excluded from “relevant land.” Para 3(2) defines a traffic
authority to include a London borough council. Cranbrook Primary
School is a community school on land owned and controlled by the
London Borough of Redbridge. Control therefore rests with a
traffic authority, excluding the site from relevant land. In the
alternative, para 3(1)(c) excludes land where parking is subject
to statutory control; this site is governed under the Education
Acts and controlled by a London borough exercising statutory
powers. PoFA keeper liability cannot arise on this land. As your
Notice to Keeper (NtK) does not fully comply with ALL the
requirements of PoFA 2012, you are unable to hold the keeper of
the vehicle liable for the charge.
For Box I, what would be the best documents to request? Land
ownership details?
I’ve included the letter of claim below, not including any of
the unimportant parts regarding citizens advice and debt payment
plans etc:
HTML https://ibb.co/WWB40T9C
HTML https://ibb.co/Kj68GWPF
HTML https://ibb.co/nMqwPDvZ
HTML https://ibb.co/x8CM8zsV
Would you recommend completely ignoring this portal? Or should i
forward my reply both as a letter and via the portal?
Any advice will be appreciated[react][/react]
#Post#: 128918--------------------------------------------------
Re: Cranbrook, Ilford - Cranbrook Primary School - BWLegal on
behalf of UKCPM - No permit
DIR By: jfollows
Date: August 26, 2026, 5:40 am
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My mistake, ignore. Apologies, I'm not with it this morning!
#Post#: 128956--------------------------------------------------
Re: Cranbrook, Ilford - Cranbrook Primary School - BWLegal on
behalf of UKCPM - No permit
DIR By: Dave65
Date: August 26, 2026, 11:12 am
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Well, where are the details of the claim.
They have not set out any explanation.
Did they supply a crystal ball?
#Post#: 128966--------------------------------------------------
Re: Cranbrook, Ilford - Cranbrook Primary School - BWLegal on
behalf of UKCPM - No permit
DIR By: Megafish7272
Date: August 26, 2026, 12:56 pm
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Details of claim can be found on the final link:
Particulars of Debt
On 10 August 2025, you were granted a limited contractual
licence to enter the land known as Cranbrook Ilford ("Site"),
which is managed and operated by our client. In return, you were
to abide by certain terms and conditions (Terms and Conditions")
which were prominently displayed on the signage erected in situ
by our client. On 10 August 2025, you breached the Terms and
Conditions - reason: Vehicle Not Registered (Anpr) ("Breach").
The Breach resulted in our client issuing a Parking Charge
Notice ( PCN) on 16/08/2025 which, despite our client's attempts
to engage with you and agree a suitable payment arrangement,
remains unpaid.
#Post#: 128986--------------------------------------------------
Re: Cranbrook, Ilford - Cranbrook Primary School - BWLegal on
behalf of UKCPM - No permit
DIR By: InterCity125
Date: August 27, 2026, 2:41 am
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Could you post up the original PCN?
You should note that they don't care what you write in your
reply to a LBC - they will rarely respond and, if they do, it is
highly unlikely that they will actually address any point which
represents a winning argument at Court.
On that basis it is best to keep any reply short and sweet.
We can give more advice once we see the PCN.
#Post#: 129043--------------------------------------------------
Re: Cranbrook, Ilford - Cranbrook Primary School - BWLegal on
behalf of UKCPM - No permit
DIR By: Megafish7272
Date: August 27, 2026, 11:12 am
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Unfortunately i don’t have the original PCN.
I’ve tried accessing it online using the reference number
but since it’s gone to debt recovery, they require that I
contact them for details.
All I have is the photo of the car:
HTML https://ibb.co/nsbtJjkd
#Post#: 129045--------------------------------------------------
Re: Cranbrook, Ilford - Cranbrook Primary School - BWLegal on
behalf of UKCPM - No permit
DIR By: jfollows
Date: August 27, 2026, 11:14 am
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Send a Subject Access Request to UKCPM for all personal
information they hold on you, which will include the original
PCN.
You have not yet received a county court claim. When you do, you
will have 28+5 days from the date of the claim as long as you
file an initial Acknowledgment of Service. By which time you
should have received the original PCN which you can use as a
basis for your defence.
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