URI:
   DIR Return Create A Forum - Home
       ---------------------------------------------------------
       FreeTrafficLegalAdvice
  HTML https://ftla.createaforum.com
       ---------------------------------------------------------
       *****************************************************
   DIR Return to: Private parking tickets
       *****************************************************
       #Post#: 27339--------------------------------------------------
       Civil Enforcement - No permit - Sacred Heart Church Wimbledon
       By: Keeper Date: June 24, 2024, 4:03 am
       ---------------------------------------------------------
       Hello everyone,
       I've been slapped with a PCN (as the keeper) for parking without
       a permit on some private land (pdf attached)
       Bit of context:
       1. The driver went to a church hall as they often do for a local
       residents association meeting at about 8pm at night.
       2. While in the meeting the issue of parking / traffic in the
       local area was discussed and it was mentioned that the church
       had applied parking conditions on their site due to parents at
       nearby schools taking all their spaces during pickup / drop-off
       times.
       3. The driver left the meeting and upon leaving, now being
       aware, saw the signs (photo attached).
       4. PCN was received and Plan A commenced. Local residents
       association were helpful, explained that the driver was not the
       only one caught out by the new rules and wrote to the Church. I
       also wrote to the church, asking if they would be able to ask CE
       to cancel the charge.
       6. Church was not very helpful, responding directly to me that
       the only course of action available is to appeal directly to
       Creative Parking (aside: seems like a different company to Civil
       Enforcement?)
       I now think I should make some sort of appeal to CE as directed
       on the notice. Something I noticed, if the appeal is
       unsuccessful, I lose the chance to pay the reduced rate. Is that
       normal?
  HTML https://imgur.com/wqLkhDk
  HTML https://imgur.com/LWCGksP
  HTML https://imgur.com/lImFq5j
       #Post#: 27342--------------------------------------------------
       Re: Civil Enforcement - No permit - Sacred Heart Church Wimbledo
       n
       By: The Rookie Date: June 24, 2024, 4:20 am
       ---------------------------------------------------------
       We need to see the PCN (all of it) please, just personal details
       redacted.
       Creative and Civil are the same 'people' but different legal
       companies, so if the signs are in one name and the PCN or
       contract (with the Church) in another, they can't enforce it
       (but will continue blindly anyway).
       Pretty shitty behaviour by people claiming to be religious!
       #Post#: 27343--------------------------------------------------
       Re: Civil Enforcement - No permit - Sacred Heart Church Wimbledo
       n
       By: Keeper Date: June 24, 2024, 4:24 am
       ---------------------------------------------------------
       [quote author=The Rookie link=topic=2323.msg27342#msg27342
       date=1719220805]
       We need to see the PCN (all of it) please, just personal details
       redacted.
       Creative and Civil are the same 'people' but different legal
       companies, so if the signs are in one name and the PCN or
       contract (with the Church) in another, they can't enforce it
       (but will continue blindly anyway).
       Pretty shitty behaviour by people claiming to be religious!
       [/quote]
       Thought I'd done it in original post but didn't enter correctly,
       done now, thanks for the heads up!
       And yes, don't get me started!
       #Post#: 27368--------------------------------------------------
       Re: Civil Enforcement - No permit - Sacred Heart Church Wimbledo
       n
       By: b789 Date: June 24, 2024, 8:15 am
       ---------------------------------------------------------
       The signs and the NtK (invoice) are in CE’s name.
       If Creative Solutions is a separate registered company and the
       landowner contract is with them and not CE, then it will depend
       on how that contract is worded. You’re not going to get sight of
       that, if you’re lucky, until POPLA and even then they will try
       and get away with only a signed statement that the contract is
       valid.
       It may have to go all the way to court before they are forced to
       reveal the contract with the landowner.
       You may need to be more forceful with the church if they are the
       landowner. Remind them that they are jointly and severally
       liable for the actions of their agent and that should they take
       the matter to court, they can be expected to called as a witness
       and and be could named as a party to a Part 20 counterclaim.
       The landowner should understand their liability and cannot
       simply fob you off back to their agents.
       #Post#: 27444--------------------------------------------------
       Re: Civil Enforcement - No permit - Sacred Heart Church Wimbledo
       n
       By: Keeper Date: June 25, 2024, 5:46 am
       ---------------------------------------------------------
       Thanks for this advice
       Realistically, what grounds could I have for a part 20?
       
       I have a feeling that the Church will just not be interested -
       do I have any course of action available with an appeal to CE?
       Could I use the "Given that it's not paid for parking, the
       driver did not rob you of any income - parking is 'free' anyway"
       Or the "I don't have to tell you who the driver is"
       Failing these, would you suggest that I just pay it, or do
       something else?
       #Post#: 27452--------------------------------------------------
       Re: Civil Enforcement - No permit - Sacred Heart Church Wimbledo
       n
       By: The Rookie Date: June 25, 2024, 6:34 am
       ---------------------------------------------------------
       [quote author=Keeper link=topic=2323.msg27444#msg27444
       date=1719312370]
       Could I use the
       1/ "Given that it's not paid for parking, the driver did not rob
       you of any income - parking is 'free' anyway"
       Or the
       2/ "I don't have to tell you who the driver is"
       3/ Failing these, would you suggest that I just pay it, or do
       something else?
       [/quote]
       Numbered for answering
       1/ No, what matters is whether the charge is commercially
       justified (Ref the Supreme court ruling in Parking Eye v Beavis)
       2/ That is correct, but then you may be liable as the Keeper if
       they have met the requirements of the Protection of Freedoms Act
       2012 (schedule 4). I can't see your PCN through my co. firewall
       so can't tell you if they have or not.
       3/ Lets get all the facts first, was the signage 'there to be
       seen' so the driver should have been aware of them, do they
       create a contract (detailed photo's needed).
       #Post#: 27483--------------------------------------------------
       Re: Civil Enforcement - No permit - Sacred Heart Church Wimbledo
       n
       By: b789 Date: June 25, 2024, 10:44 am
       ---------------------------------------------------------
       For now you need to get a generic appeal in so that you can get
       a POPLA code. You don't have much time left for the appeal.
       A simple appeal along these lines will get your rejection and
       POPLA code:
       [indent]Re PCN number:
       I dispute your 'parking charge', as the keeper of the vehicle. I
       deny any liability or contractual agreement and I will be making
       a complaint about your predatory conduct to your client
       landowner.
       There will be no admissions as to who was driving and no
       assumptions can be drawn. Since your PCN is a vague template, I
       require an explanation of the allegation and your evidence. You
       must include a close up actual photograph of the sign you
       contend was at the location on the material date as well as your
       images of the vehicle.
       If the allegation concerns a PDT machine, the data supplied in
       response to this appeal must include the record of payments made
       - showing partial VRNs - and an explanation of the reason for
       the PCN, because your Notice does not explain it.
       If the allegation involves an alleged overstay of minutes, your
       evidence must include the actual grace period agreed by the
       landowner.[/indent]
       #Post#: 27596--------------------------------------------------
       Re: Civil Enforcement - No permit - Sacred Heart Church Wimbledo
       n
       By: Keeper Date: June 26, 2024, 1:37 pm
       ---------------------------------------------------------
       Thanks, have done this and will report back...
       #Post#: 27607--------------------------------------------------
       Re: Civil Enforcement - No permit - Sacred Heart Church Wimbledo
       n
       By: DWMB2 Date: June 26, 2024, 2:25 pm
       ---------------------------------------------------------
       The chances of them accepting the appeal are close to nil. As
       b789 noted, the main purpose is to get you a code with which you
       can then appeal to POPLA. With that in mind, there's little harm
       in starting to consider your draft now.
       #Post#: 27666--------------------------------------------------
       Re: Civil Enforcement - No permit - Sacred Heart Church Wimbledo
       n
       By: Keeper Date: June 27, 2024, 5:07 am
       ---------------------------------------------------------
       aaaand we're already there!
       Received attached, along with photos of signage (same as mine
       above plus this other one)
  HTML https://imgur.com/twkSJs8
  HTML https://imgur.com/PNJ6AzC
  HTML https://imgur.com/U8TApNw
       *****************************************************
   DIR Next Page