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       #Post#: 50540--------------------------------------------------
       Saba Parking Services - Railway parking site - debt collector
       before initial notice?
   DIR By: Cariboudle
       Date: December 20, 2024, 2:58 am
       ---------------------------------------------------------
       Hello all,
       This might be a long story...
       I received a debt collector's letter dated 21st October 2024 for
       an alleged parking offence at a rail station car park which is
       managed by Saba Parking Services UK Ltd.  This debt collector's
       notice was the first letter I had received, never having had
       anything from Saba.  Not sure if it matters but this only landed
       in my post box on the 26th October.
  HTML https://imgur.com/a/zDe5vaB
       I tried to go through the Saba website to appeal because I'd
       never had any previous correspondence and was thus surprised to
       see a debt collector's letter.  For some reason (possibly
       because they sub this out to paymyparkingcharge which I didn't
       know at the time), I couldn't appeal on their website.  I
       therefore used the SABA parking contact form on their website to
       ask them to cancel the charge as I had never received any
       initial correspondence.  This was on the 28th October 2024.
       Saba parking emailed back on the same day stating that they
       don't issue the notices it is issued by PayMyParkingCharge and I
       should use the paymyparkingcharge.com website to appeal the
       parking notice.
  HTML https://imgur.com/a/tiWOZVU
       Before I had read their email, on the 29th or 30th October 2024,
       I received a notice from Saba dated 25th October 2024 which is
       the initial parking fine notice for the alleged 12th September
       offence.
  HTML https://imgur.com/a/ZYfn1sB
       This notice contains instructions on how to appeal and so I
       appealed through the paymyparkingcharge website.  I sent the
       appeal on 31st October 2024 but the website does not issue a
       copy of the appeal so at this time I can't remember what I said
       or wrote probably something about following procedures and a
       request to cancel the fine.  I should have taken a screenshot.
       The website currently shows that the appeal was received on the
       31st October 2024 but I have no response or reply from them
       either by post or email and there is now no appeal button to
       use.
  HTML https://imgur.com/a/mw0A1Ow
       Then yesterday 19th December 2024 I received another letter from
       the debt collection agency ZZPS
  HTML https://imgur.com/a/VMPtXge
       I have had nothing back from SABA or PayMyParkingCharge since
       sending the appeal on 31st October 2024 although it appears they
       still expect me to pay £170.  I have not contacted the debt
       collectors either.
       Any insight or advice would be appreciated as to what I should
       do now, if anything.
       #Post#: 50541--------------------------------------------------
       Re: Saba Parking Services - Railway parking site - debt
       collector before initial notice?
   DIR By: John U.K.
       Date: December 20, 2024, 3:03 am
       ---------------------------------------------------------
       This is being moved to Private Parking.
       #Post#: 50544--------------------------------------------------
       Re: Saba Parking Services - Railway parking site - debt
       collector before initial notice?
   DIR By: Cariboudle
       Date: December 20, 2024, 3:31 am
       ---------------------------------------------------------
       Coincidentally I got this email from ZZPS today
  HTML https://imgur.com/a/nQmjyRd
       I don't know how they got my email address - I have not
       contacted ZZPS by letter phone or email so I imagine they must
       have received it from PayMyParkingCharge or Saba.
       #Post#: 50612--------------------------------------------------
       Re: Saba Parking Services - Railway parking site - debt
       collector before initial notice?
   DIR By: b789
       Date: December 20, 2024, 1:52 pm
       ---------------------------------------------------------
       What you received from SABA is a fake Penalty Notice. It is a
       fraudulent attempt to extort money from you. SABA have no
       authority to issue a Penalty Notice under Railway Byelaws.
       What they have issued is an "offered contract" under civil law
       and neither you nor anyone else for that matter is under any
       legal obligation to accept an "offered contract". The "contract"
       offers you the opportunity to pay a bribe to SABA for them to
       not prosecute you under Railway Byelaws. The simple fact is that
       they are unable to actually prosecute you under  Railway Byelaws
       because they are not an authority authorised to do so.
       Your appeal is irrelevant. I can guarantee that apart from the
       useless debt collector letters which you must ignore and never
       try and communicate with them, they will eventually give up.
       SABA cannot issue a claim in the county court for an alleged
       criminal matter. If they wanted to issue a charge in the
       magistrate's court under criminal law, they would need the
       authority to prosecute (which they don't have) under the Single
       Justice Procedure (SJP).
       So, if you continue to engage with them, you are falling into
       their scam (fraud) and giving them oxygen to keep trying to
       extort money from you. You are considered by them as low-hanging
       fruit on the gullible tree and ripe for the picking out of
       ignorance of the law and your rights.
       I can say with 100% certainty that you will never be issued with
       a claim in the county court or summonsed for a criminal charge
       in the magistrates court over this fake Penalty Notice. Ignore
       them. They will eventually give up and go off in search of
       lower-hanging fruit.
       You may want to consider reporting them to Action Fraud. They
       are using unlawful language in their "offered contract" to
       extort money from recipients who are under the misapprehension
       that they are liable to criminal proceedings when they aren't.
       If you want to see what a real Penalty Notice is about and how
       we are dealing with it, have a read of this thread:
       Byelaws offence - Taken to magistrates for private parking
       ticket
  HTML https://www.ftla.uk/speeding-and-other-criminal-offences/sjp-for-private-parking-ticket/
       #Post#: 52084--------------------------------------------------
       Re: Saba Parking Services - Railway parking site - debt
       collector before initial notice?
   DIR By: Cariboudle
       Date: January 6, 2025, 4:23 am
       ---------------------------------------------------------
       I know I am not meant to engage with the debt collectors (so I
       won't unless you tell me otherwise?), however they are now
       texting me - received today as follows:
       --- Quote ---
       >
       > Re: 142882414
       >
       > Please contact ZZPS Limited in relation to a personal business
       matter and quote the above reference number.
       >
       > You can reply to this SMS or phone us on +44 1932 918916.
       >
       > ZZPS Customer Services
       --- End Quote ---
       I don't know how they got my phone number or email address -
       presumably from when I submitted the appeal but who knows.  I'm
       usually diligent about unchecking boxes that allow people to
       contact me.
       I'll do nothing unless you all advise something different.
       #Post#: 52088--------------------------------------------------
       Re: Saba Parking Services - Railway parking site - debt
       collector before initial notice?
   DIR By: DWMB2
       Date: January 6, 2025, 4:35 am
       ---------------------------------------------------------
       Just block their number.
       #Post#: 65485--------------------------------------------------
       Re: Saba Parking Services - Railway parking site - debt
       collector before initial notice?
   DIR By: Cariboudle
       Date: April 3, 2025, 2:51 am
       ---------------------------------------------------------
       Hello me again!
       Apologies for resurrecting this old thread, but it appears the
       debt collectors haven't given up yet. I received another debt
       collector's letter yesterday.  This time from Moorside Legal.
  HTML https://imgur.com/a/negg9hQ
       The last correspondence I had was from ZZPS on 30th December
       2024 and text on 6th January 2025.  Saba and PayMyParkingCharge
       have not responded to my appeal that I issued on
       paymyparkingcharge website on 31st October 2024.
       I have not responded to any letters or engaged with any
       messages.  Should I be worried now that they are talking about
       County Court Claims and CCJs?
       Your insight, as always, highly valued.
       #Post#: 65511--------------------------------------------------
       Re: Saba Parking Services - Railway parking site - debt
       collector before initial notice?
   DIR By: b789
       Date: April 3, 2025, 5:46 am
       ---------------------------------------------------------
       Should you be worried? Absolutely not. I have already explained
       to you, this is not a legitimate Parking Charge Notice (PCN) and
       it is not a valid Penalty Notice (PN). It is neither. It is a
       deliberately fabricated hybrid, falsely presented to look like
       an official legal document in order to deceive. It is designed
       to mimic the appearance and tone of statutory enforcement,
       knowing full well that it carries no lawful authority
       whatsoever.
       What makes this even more serious is that the company has now
       repackaged the expired and unlawful Penalty Notice as a civil
       debt—a move that is not only dishonest but legally impossible. A
       genuine Penalty Notice under the railway byelaws is a criminal
       matter, and must be prosecuted in the Magistrates’ Court by a
       public body, within six months of the alleged offence. In this
       case, the alleged offence took place on 12th September 2024,
       meaning the six-month statutory limitation expired on 12th March
       2025. That legal window has closed. The case is dead in law, and
       cannot be revived in any court, criminal or civil.
       However, it is criminal act by SABA and their agents because
       there is an intention to deceive recipients into paying under
       the false belief that this is a criminal or statutory penalty.
       This aligns with the criminal offence of fraud by false
       representation (Fraud Act 2006, s.2) and possibly even blackmail
       (Theft Act 1968, s.21), particularly as there is an explicit
       threat of legal or financial consequences unless payment is
       made.
       Their intention is clear: to frighten, confuse, and coerce
       people—ordinary members of the public—into handing over money
       under false pretences. That is not a civil dispute. It is a
       criminal act.
       To pursue a demand in the civil courts for a penalty that is not
       lawfully due, and which has already timed out under criminal
       law, is not simply an abuse of process—it is a deliberate,
       calculated attempt to obtain money through deception and
       intimidation.
       This is criminal conduct masquerading as legal procedure. It
       must be treated as such, and those involved—particularly
       regulated legal professionals like Moorside Legal—must be held
       fully accountable under both professional and criminal law.
       This should not be reported through Action Fraud. Action Fraud
       is not a police force; it only collects data and passes cases to
       the National Fraud Intelligence Bureau (NFIB), which
       investigates only a small fraction. It does not issue crime
       reference numbers in the way local police do, nor does it
       guarantee that a crime report will be properly recorded or
       pursued.
       Where the suspect is known—as in this case (SABA, or their legal
       representatives such as Moorside Legal)—and the fraud is
       targeted, ongoing, and involves documented threats, the matter
       falls under the jurisdiction of your local police force, who are
       responsible for investigating under the National Crime Recording
       Standard (NCRS). This requires that a crime be recorded when the
       victim reports one, unless there is credible evidence to the
       contrary.
       This is not a generic scam. It involves a deliberate and
       unlawful false representation by a known legal entity. A
       document falsely labelled as a Penalty Notice, with legalistic
       threats and a demand for payment, was issued without any
       statutory authority. Worse still, once the six-month legal
       deadline to prosecute expired, the company repackaged the void
       Penalty Notice as a civil debt and began issuing threats of
       litigation—despite knowing that no such liability exists. That
       is a textbook example of fraud by false representation under the
       Fraud Act 2006, and potentially blackmail/extortion, due to the
       misuse of legal process and threats of financial harm.
       This is a serious and ongoing criminal act, and must be treated
       as such.
       To report to the police, attend or call your local police
       station (via 101) and request to report a crime. Do not accept
       redirection to Action Fraud. Ask for the matter to be recorded
       locally as fraud by false representation and attempted
       blackmail/extortion.
       State that:
       [indent]• The suspect is a known legal entity (e.g. APCOA, SABA,
       Moorside Legal);
       • The notice falsely claims to be a statutory Penalty Notice
       under railway byelaws;
       • The alleged offence occurred more than six months ago, meaning
       it is out of time for prosecution;
       • The company has now attempted to enforce the expired criminal
       notice as a civil debt, through threats of litigation.
       • Provide the notice and supporting documentation showing:
       [indent]• Misleading use of the term “Penalty Notice”;
       • Threats of court action and further enforcement;
       • Payment instructions to a private company, not a public
       authority;
       • No reference to enabling legislation or valid civil
       enforcement grounds;
       • Evidence that the criminal time limit (6 months) has expired;
       • Any correspondence from their solicitors threatening civil
       action.[/indent][/indent]
       When speaking to the officer, you may wish to phrase it like
       this:
       [indent]“I am reporting a crime under the Fraud Act 2006. A
       private parking company has issued a document purporting to be a
       statutory Penalty Notice under railway byelaws. Not only do they
       lack legal authority to issue such notices, but they are now
       attempting to pursue it as a civil debt after the time limit for
       any prosecution expired. This is a clear example of fraud by
       false representation and potentially blackmail, as it involves
       threats of legal action to induce payment under false pretences.
       The identity of the company is known, and I have supporting
       documents. I am asking that this be recorded as a crime and that
       I be issued with a crime reference number.”[/indent]
       If the officer refuses or tries to redirect you to Action Fraud,
       politely but firmly cite the National Crime Recording Standard:
       [indent]If a notifiable offence is reported and the victim
       believes a crime has occurred, the police must record it unless
       there is credible evidence to the contrary.[/indent]
       Fraud by a known suspect is a matter for local police, not
       Action Fraud.
       There has been a systemic failure to treat these fake Penalty
       Notices as the criminal frauds they are. Calling it a “civil
       issue” or “waste of police time” ignores the fact that this is
       an intentional abuse of legal process to obtain money by
       deception. If this is not treated as a crime, then both consumer
       protection and the integrity of criminal law are being
       undermined.
       Getting your MP involved can also be highly effective—especially
       if framed correctly. MPs can raise issues via Parliamentary
       Questions (PQs) or adjournment debates, forcing departments to
       respond. MPs can write directly to Ministers (e.g. the Home
       Secretary, Secretary of State for Justice, or Transport
       Minister) demanding a policy response. They can also refer
       specific cases to the National Crime Agency, Trading Standards,
       or Police and Crime Commissioners, giving them political weight.
       Here's a draft MP briefing letter and accompanying briefing
       document you can use or adapt:
       --- Quote ---
       > [Your Name]
       > [Your Address]
       > [Your Postcode]
       > [Email Address]
       > [Date]
       >
       > [MP’s Name]
       > House of Commons
       > London
       > SW1A 0AA
       >
       > Dear [MP’s Name],
       >
       > Re: Urgent Action Required – Fraudulent Use of Expired Railway
       “Penalty Notice” and Misuse of Legal Process
       >
       > I am writing to you as a constituent to raise a matter of
       serious concern involving the abuse of legal process by a
       private parking company operating on railway land. I recently
       received a document purporting to be a “Penalty Notice” issued
       under railway byelaws by a private operator, SABA Ltd. The
       notice was designed to appear as a statutory criminal penalty,
       yet it had no basis in law and was never enforceable by the
       issuing company.
       >
       > Even if it had been a genuine Penalty Notice (which it was
       not), the alleged offence occurred on 12th September 2024. Under
       the railway byelaws, any prosecution would have had to commence
       by 12th March 2025. That deadline has now passed. The legal
       window for prosecution is closed. The matter is legally defunct.
       >
       > However, rather than abandon the charge, the company has
       repackaged the expired and unlawful Penalty Notice as a civil
       debt and is now issuing threats of court proceedings—despite
       knowing that no valid liability exists. Worse still, these
       threats are being issued through a firm of solicitors, Moorside
       Legal, who appear to be knowingly attempting to enforce a void
       criminal allegation as if it were a civil claim. This is not a
       minor administrative failure. It is a deliberate and systematic
       deception that I believe constitutes fraud by false
       representation, and arguably extortion, under the Fraud Act
       2006.
       >
       > I have enclosed a briefing which sets out the legal position
       in detail, including relevant statutory references and the
       Department for Transport’s position on enforcement under railway
       byelaws. I hope you will agree that this issue requires urgent
       attention—not just in my case, but to prevent others from
       falling victim to similar unlawful tactics.
       >
       > I respectfully ask you to consider the following actions:
       >
       > [indent]1. Submit a Parliamentary Question to the Home
       Secretary and/or Secretary of State for Transport, along the
       following lines:
       >
       > [indent]“To ask the Secretary of State for the Home Department
       what steps are being taken to investigate and prosecute private
       parking companies and their legal representatives who knowingly
       issue or pursue expired or unlawful ‘Penalty Notices’ under
       railway byelaws, and whether such conduct is being treated as
       fraud by false representation and extortion under the Fraud Act
       2006.”[/indent]
       >
       > 2. Refer this matter to the Solicitors Regulation Authority,
       as Moorside Legal is acting in breach of their professional
       obligations by pursuing an unenforceable and misrepresented
       claim.
       >
       > 3. Raise the issue in Parliament or with the relevant
       ministerial departments as a matter of urgent public interest
       and consumer protection.[/indent]
       >
       > This is not a dispute over parking. It is a coordinated
       attempt to misuse the legal system to extract money from the
       public under false pretences. If allowed to continue, it
       undermines the distinction between criminal and civil
       enforcement and erodes confidence in both.
       >
       > Thank you for your time and attention to this matter. I would
       be happy to provide any further documents or evidence you
       require.
       >
       > Yours sincerely,
       >
       > [Your Name]
       --- End Quote ---
       And you can adapt this briefing document (include a copy of both
       sides of the Penalty Notice) to submit with the letter to your
       MP:
       --- Quote ---
       > Briefing Document for MP
       >
       > Subject: Misuse of "Penalty Notices" by Private Parking
       Companies on Statutory Land (e.g. Railway Property)
       >
       > Summary:
       >
       > This briefing relates to a fraudulent and deeply misleading
       practice being carried out by a private parking company, SABA
       Ltd, operating on railway land. This company is issuing
       documents styled as "Penalty Notices" for alleged breaches of
       railway byelaws, despite having no statutory authority to do so.
       These notices are falsely framed to resemble statutory criminal
       penalties and are intended to intimidate recipients into making
       payment.
       >
       > In my case, I received a notice referring to an alleged
       parking contravention on 12th September 2024. The notice was
       styled as a Penalty Notice, implying enforcement under the
       railway byelaws. Under the law, any genuine prosecution for such
       a breach must be brought in the Magistrates’ Court within six
       months—i.e., by 12th March 2025. That time has now passed. The
       legal opportunity to prosecute under Byelaw 24(1) has expired.
       The case is legally dead.
       >
       > Despite this, the company has repackaged the expired and
       unlawful Penalty Notice as a civil debt and is now threatening
       litigation in the civil courts. This is not only dishonest; it
       is legally impossible. A genuine Penalty Notice is a matter of
       criminal law and cannot be transformed into a civil claim once
       the prosecution window has closed. This act represents a blatant
       and deliberate attempt to bypass the law.
       >
       > The original notice is neither a valid Penalty Notice (PN) nor
       a legitimate Parking Charge Notice (PCN). It is a fraudulent
       hybrid, deliberately styled to appear authoritative, with the
       intent of misleading the recipient into believing they face
       criminal liability. The document makes no distinction between
       civil and criminal enforcement and does not clarify the actual
       legal status of the charge. This is a false representation.
       >
       > A copy of the notice is attached to illustrate the concerns
       raised. It demonstrates how private companies are misusing the
       format and language of statutory enforcement to coerce payment
       under false pretences.
       >
       > Key Legal Distinctions:
       >
       > [indent]• Byelaw 14(4)(i) refers to the liability of the
       'owner' of a vehicle for a parking charge in the event of a
       contravention. However, there is no official public register of
       vehicle ownership in the UK. The DVLA's vehicle registration
       document (V5C) states clearly and in bold: "THIS DOCUMENT IS NOT
       PROOF OF OWNERSHIP." Being the registered keeper is not proof,
       nor even strong evidence, of ownership.
       >
       > In civil law, the only parties who can be pursued for a
       parking charge are the driver, or in limited cases, the keeper
       or hirer—but even then, only under clearly defined statutory
       conditions such as those set out in the Protection of Freedoms
       Act 2012 (which does not apply on railway land). The burden of
       proof is on the balance of probabilities, and persuasive
       appellate case law (e.g. VCS v Edward [2023]) has confirmed that
       there can be no presumption that the keeper is the driver, let
       alone the owner.
       >
       > In contrast, criminal enforcement under Byelaw 24(1) requires
       the prosecution to prove the case under the much stricter
       'beyond reasonable doubt'. To impose liability on a person as
       the “owner” in a criminal context would require positive
       evidence of ownership, not an inference based on keeper status.
       Any attempt to rely on DVLA keeper data to infer ownership for
       the purpose of criminal liability is legally flawed and risks
       misapplication of criminal law.
       >
       > • Byelaw 24(1) provides for the criminal prosecution of byelaw
       breaches, but only by a Train Operating Company or a public
       authority with express statutory powers. Private companies have
       no authority under this byelaw to prosecute or issue criminal
       fines.[/indent]
       >
       > The DfT has confirmed that while it accepts the use of PCNs
       for civil enforcement under Byelaw 14, it does not authorise the
       use of "Penalty Notices" implying enforcement under Byelaw
       24(1). To date, no unregulated private parking company, such as
       APCOA or SABA, has demonstrated any agreement or statutory
       delegation authorising them to issue Penalty Notices under the
       authority of a TOC or statutory landowner.
       >
       > This position aligns with broader transport policy. Following
       the introduction of the Road Traffic Act 1991, most parking
       offences were decriminalised and enforcement shifted to civil
       law. In line with this, the DfT stated in a 2018 response to
       POPLA that it does not expect minor parking breaches under
       Byelaw 14 to be prosecuted under Byelaw 24(1), but rather
       addressed contractually by private operators managing railway
       car parks.
       >
       > Why This Matters:
       >
       > False Representation and Coercion:
       >
       > The notice I received implied I had committed a criminal
       offence and demanded payment directly to a private company. This
       is misleading and constitutes a false representation under the
       Fraud Act 2006, and possibly blackmail under the Theft Act 1968.
       >
       > Funds Misappropriated:
       >
       > Any legitimate statutory fine would be payable to the public
       purse. These notices divert payments to a private company,
       undermining proper enforcement and eroding trust in genuine
       statutory penalties.
       >
       > DfT Acknowledgement:
       >
       > The DfT recognises that Byelaw 14 may be enforced through
       civil “ticketing” by agents of TOCs, but it has not provided any
       basis for criminal enforcement powers being delegated to private
       operators.
       >
       > Terminology Confusion:
       >
       > The use of the term “Penalty” in this context is misleading.
       “Penalty” should be reserved for statutory fines. The correct
       terminology for a civil charge is “Parking Charge Notice” (PCN).
       The DfT's own inconsistent use of the word “penalty” in
       correspondence has inadvertently contributed to this confusion.
       >
       > Suggested Actions:
       >
       > I respectfully ask that you:
       >
       > [indent]1. Submit a Parliamentary Question such as:
       >
       > [indent]"To ask the Secretary of State for the Home Department
       what steps are being taken to investigate and prosecute private
       parking companies and their legal representatives who knowingly
       issue or pursue expired or unlawful ‘Penalty Notices’ under
       railway byelaws, and whether such conduct is being treated as
       fraud by false representation and extortion under the Fraud Act
       2006."[/indent]
       >
       > 2. Write to the Justice Secretary and/or Home Secretary to:
       >
       > [indent]• Clarify the legal position of such notices;
       >
       > • Inquire whether this conduct is being treated as potentially
       fraudulent;
       >
       > • Ask whether guidance has been issued to police forces on
       this matter.
       >
       > • Refer the matter to the local Police and Crime Commissioner
       and chief constable to seek confirmation of their approach to
       such practices.
       >
       > • Refer Moorside Legal’s conduct to the Solicitors Regulation
       Authority for investigation.[/indent][/indent]
       >
       > Conclusion:
       >
       > This issue represents a dangerous abuse of public trust.
       Private companies are misusing criminal-style notices to collect
       money unlawfully, and in doing so are targeting ordinary people
       who are unaware of the legal distinctions involved. Their
       behaviour is fraudulent, coercive, and systematically
       misleading.
       >
       > This matter demands urgent parliamentary scrutiny—not just for
       my case, but to protect the public from this growing pattern of
       deception.
       >
       > Thank you for your time and attention.
       --- End Quote ---
       So, as you can see, you have nothing to worry about and you
       should take the actions I have suggested above.
       #Post#: 72125--------------------------------------------------
       Re: Saba Parking Services - Railway parking site - debt
       collector before initial notice?
   DIR By: Cariboudle
       Date: May 19, 2025, 2:29 am
       ---------------------------------------------------------
       Hello me again.
       I confess my life has gone a bit difficult and this all
       completely slipped my mind until another letter arrived last
       week.  I have not written my MP or reported to police but I will
       in due course.
       Moorside Legal have not given up.  I've received 2 further
       letters from them.
       The 16th April 2025 letter offered a payment plan if the £170
       was too much.
  HTML https://imgur.com/a/O7rZFnH
       The 6th May 2025 letter has a calculation of the likely increase
       in fees if court action is taken and a deadline this time, 30
       days for responding.  To enable the response, they have attached
       a form to complete to accept or dispute the debt and provide
       further information etc.
  HTML https://imgur.com/a/NmYEZIj
       Do you guys think I should complete the form using the dispute
       option and supply the information as laid out in this thread
       regarding the validity of the claim?  Or, keep ignoring them
       until they take me to court?
       Best Regards,
       #Post#: 72127--------------------------------------------------
       Re: Saba Parking Services - Railway parking site - debt
       collector before initial notice?
   DIR By: H C Andersen
       Date: May 19, 2025, 3:16 am
       ---------------------------------------------------------
       They (SABA) cannot take you to court.
       If they could and if there was anything in it for them* they
       would have done so ages ago.
       Think laterally.
       They've got their hooks into you because somehow they have your
       SMS and email, they are also inside your head.
       b789 gave you the opportunity to get on the front foot, but it's
       not been taken.
       Do it now. You'll at least have the satisfaction of fighting
       back when otherwise all you can do is respond(by posting here
       for information) to their comms.
       Railway Byelaws
  HTML https://assets.publishing.service.gov.uk/media/5a79c14b40f0b66d161ade8c/railway-byelaws.pdf
       See 14(4)(i), then look at your V5C then look at the
       Interpretation byelaw 25.
       'The owner'.... 14(4)(i);
       'This document is not proof of ownership' ...V5C;
       'Owner' not otherwise defined in the Interpretation and
       therefore the common meaning of the word would be imported into
       the byelaws.
       *- criminal offences = punishment, fines being paid to the
       Crown;
       civil - compensation (e.g. breach of contract etc.) to the
       claimant.
       There is nothing in this war of attrition for them UNLESS they
       think you'll give way. Plenty of people do because the
       correspondence is couched in legal sounding phrases and mystique
       but when stripped of this it's waffle.
       Up to you what you do.
       Have a read of the complete byelaws if you have spare time and
       nothing better to do because whenever you come within their
       jurisdiction they apply (the phrase included in tickets and
       notices displayed at stations: issued subject to Railway
       Byelaws) A right riveting read!
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