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       #Post#: 50850--------------------------------------------------
       Re: Can a private company initiate a criminal prosecution under
       the SJP?
   DIR By: b789
       Date: December 23, 2024, 10:14 am
       ---------------------------------------------------------
       Of course the BPA would like railway land to become "relevant
       land" for the purposes of PoFA. However, I attach below the
       response I received from POPLA when I queried their right to
       adjudicate on Penalty Notices issued by APCOA and SABA.
       POPLA claim that they queried this with the DfT in 2018 and the
       attached a copy of their communication saying (paraphrasing)
       "The DfT told us we can so we do!"
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       Any highlighting mine. I believe that POPLA have chosen to make
       their own interpretation of the recommendation by the DfT
       because of the misuse of the word "penalty" in this sentence in
       their response:
       --- Quote ---
       > Further, it is stated in by byelaw 14(4)(i) that the owner of
       a vehicle may be liable to pay a penalty if it has been used,
       placed or left in contravention of byelaws 14(1) to (3).
       --- End Quote ---
       In the next sentence, the DfT state:
       --- Quote ---
       > The ability to render a charge under byelaw 14(4)(i) is
       distinct from the general enforcement power in byelaw 24(1),
       under which a person can be prosecuted in the Magistrates
       Courts.
       --- End Quote ---
       The DfT use of the term "penalty" in reference to byelaw
       14(4)(i) appears to be a misnomer. In context, it seems intended
       to refer to a "charge" rather than an actual "penalty" as
       defined under the railway byelaws. This interpretation is
       supported by their subsequent clarification:
       --- Quote ---
       > "The ability to render a charge under byelaw 14(4)(i) is
       distinct from the general enforcement power in byelaw 24(1),
       under which a person can be prosecuted in the Magistrates'
       Court."
       --- End Quote ---
       This statement indicates that while a private parking company,
       if contracted, may issue a "charge" (such as a Parking Charge
       Notice or PCN) for breaches of railway byelaws, this is entirely
       separate from the enforcement of penalties through criminal
       proceedings in the Magistrates' Court. Consequently, the use of
       the term "penalty" in the context of byelaw 14(4)(i) should not
       be conflated with the formal penalties enforceable under byelaw
       24(1). This distinction is critical, as it underscores the
       limited powers of private parking companies and highlights that
       any charges they issue are not equivalent to criminal penalties.
       The term "penalty" is being used in two distinctly different
       contexts, which creates confusion as it is not clearly
       differentiated:
       Under Byelaw 14(4)(i):
       [indent]Here, the word "penalty" is seemingly being used to
       describe a civil charge (e.g., a Parking Charge Notice) that may
       be issued by a private parking company. This usage does not
       imply a criminal sanction but rather an invoice-like demand for
       payment, enforceable only through civil proceedings (e.g., small
       claims track of the county court). This form of "penalty" is
       essentially a contractual mechanism to deter undesirable
       behaviour, such as parking in breach of terms and
       conditions.[/indent]
       Under Byelaw 24(1):
       [indent]In this context, "penalty" refers explicitly to a
       criminal offence, enforceable through prosecution in a
       Magistrates' Court. This type of penalty carries potential legal
       consequences beyond a mere financial charge, such as a criminal
       record or fines imposed by the court.[/indent]
       The distinction lies in the nature of enforcement and
       consequences:
       [indent]• A civil charge is a financial liability imposed
       privately, for breaching terms and conditions, and does not
       carry criminal implications.
       • A criminal penalty involves formal legal proceedings,
       potential prosecution, and the imposition of sanctions by the
       judicial system.[/indent]
       #Post#: 50875--------------------------------------------------
       Re: Can a private company initiate a criminal prosecution under
       the SJP?
   DIR By: NewJudge
       Date: December 23, 2024, 11:40 am
       ---------------------------------------------------------
       All of the above is all fine and dandy - if the motorist agrees
       to arbitration. He has no requirement to do so. Whether or not
       he should depends upon the circumstances he finds himself in.
       If he does and it goes against him (as I believe it might have
       in the case of our friend in the "Live Cases" forum) all he has
       to do is to refuse to pay. He will then be prosecuted where the
       charge will have to be proved to the criminal standard. The
       court will not be interested in any deficiencies in any penalty
       notices as there is no requirement to provide any. It will not
       be able to make assumptions about the owner/registered
       keeper/person in charge. The status of the person charged will
       have to be proved as required.
       All the information you have provided relates to private parking
       companies, their responsibilities to issue the correct
       documentation to levy penalty charges and the arbitration
       services associated with that. None of it has any bearing on
       criminal prosecutions and that's where these cases end up if
       they remain unsettled.
       
       #Post#: 50880--------------------------------------------------
       Re: Can a private company initiate a criminal prosecution under
       the SJP?
   DIR By: andy_foster
       Date: December 23, 2024, 12:18 pm
       ---------------------------------------------------------
       In general, and more apropos the case referred to in the live
       cases forum, where there is seemingly a strong meritorious
       defence on the facts of the case, and a seemingly stronger
       technical defence which would tend to suggest that a provision
       is a dead letter, I would very much be minded not to disregard
       the meritorious defence in pursuit of the loophole defence.
       Courts of all levels have shown a propensity to inflict as much
       violence as necessary to the language of a provision to achieve
       what they consider to be a just outcome. Whilst they often do
       not do this, it is never safe to assume that they won't,
       although if the DC or above has already ruled on the matter
       [with a rational interpretation] such an assumption is somewhat
       safer.
       #Post#: 50881--------------------------------------------------
       Re: Can a private company initiate a criminal prosecution under
       the SJP?
   DIR By: b789
       Date: December 23, 2024, 12:36 pm
       ---------------------------------------------------------
       The point of my question was how can the unregulated private
       parking company (UPPC) "initiate" a private prosecution in the
       magistrates court (under the SJP or otherwise) and that has been
       answered, thank you. They can't.
       If the UPPC wants to enforce the PN, they can only do so by
       referring it to the TOC prosecutor who would then be able to
       prosecute it through the SJP, should they decide to do so and
       they are within the 6 month statute of limitation.
       Based on what has been commented on so far, as I understand it,
       a private company cannot issue a legitimate Penalty Notice (PN)
       under railway bylaw 14 because it lacks the statutory authority
       required to do so. Only the Train Operating Company (TOC) or an
       authorised prosecutor acting on behalf of the TOC has the legal
       authority to enforce railway bylaw breaches through the Single
       Justice Procedure (SJP) or other criminal court proceedings.
       If a private parking company issues a notice purporting to be a
       Penalty Notice under railway byelaws, surely this amounts to
       misrepresentation. Using terms like "Penalty Notice" or implying
       criminal liability (e.g., referring to "prosecution" or
       "Magistrates’ Court") is misleading if the notice is not issued
       by an authorised prosecutor or TOC.
       If the notice implies criminal consequences or statutory
       enforcement powers that the private company does not possess, it
       breaches the Consumer Protection from Unfair Trading Regulations
       2008. Also, it is making a false representation with intent to
       cause loss or gain which is a breach of the Fraud Act 2006
       (Section 2).
       A private company issuing what it claims to be a Penalty Notice
       under railway bylaw 14 is acting beyond its authority. Such a
       notice must be legally invalid, as only the TOC or its
       authorised prosecutor can issue and enforce Penalty Notices
       under railway byelaws. Any such misuse of the term "Penalty
       Notice" by a private company can only be considered as
       misleading or unlawful.
       So, it all comes back to my point that the UPPC, by issuing a
       purported PN, is in fact committing fraud. In other words, it is
       not a real PN but an "offered contract". An offered contract is
       a civil contract law matter and has nothing to do with criminal
       law.
       The criminal extortion element is a serious issue with the
       potential misuse of authority by UPPCs. If a UPPC issues what it
       purports to be a PN for an alleged breach of railway bylaw 14,
       this can only amount to fraudulent or unlawful behaviour.
       The use of language typically reserved for criminal enforcement
       in a notice issued by a private company, when the company lacks
       the authority to prosecute or enforce criminal penalties, surely
       meets the criteria for fraud under the Fraud Act 2006. Fraud by
       false representation occurs when someone dishonestly makes a
       false representation, intending to make a gain for themselves or
       cause a loss to another.
       If the UPPC falsely represents the notice as a legitimate
       Penalty Notice under byelaw 14, this probably qualifies as
       fraud. The notice implies authority (e.g., potential criminal
       prosecution or fines), which the company does not have. The
       intent is to scare the recipient into paying money they do not
       legally owe to the UPPC.
       By using intimidating language such as "fine," "offence," or
       "criminal prosecution," the UPPC exploits the recipient’s likely
       misunderstanding of the legal distinction between civil and
       criminal liability. This tactic can only be viewed as a form of
       extortion, as it pressures individuals into paying under the
       false pretence of avoiding criminal consequences. Such behaviour
       not only violates consumer protection laws but also constitute
       criminal misconduct.
       Under railway bylaw 14, only the TOC prosecutor or an authorised
       agent can initiate criminal enforcement. If a breach of bylaw 14
       occurs, the TOC decides whether to prosecute. If prosecution
       proceeds, it must be under the Single Justice Procedure (SJP) in
       the Magistrates’ Court.
       Any fine imposed by the court is paid into the public purse, not
       retained by the TOC or any private contractor. A UPPC issuing a
       "Penalty Notice" bypasses this legal framework and improperly
       seeks to profit directly from the alleged breach, which subverts
       the intention of the byelaws (to regulate conduct on railway
       land, not to generate private revenue) and deprives the public
       purse of funds that should rightfully flow through the judicial
       process.
       The language used in a real Penalty Notice issued under criminal
       law must reflect the statutory framework, including the nature
       of the offence and potential court proceedings. A private
       company issuing a notice for what is, at best, an "offered
       contract" cannot lawfully use terms such as "Fine" which is
       reserved for criminal penalties, "Offence" which implies
       criminal wrongdoing or "Criminal prosecution" which suggests the
       involvement of criminal courts, which a UPPC cannot initiate. In
       a civil contract dispute, the private company must use neutral
       language (e.g., "Parking Charge Notice" or "charge"), clearly
       explaining the basis of the claim without implying criminal
       liability.
       Another key distinction in railway bylaw enforcement is that any
       fines resulting from criminal prosecutions go to the public
       purse. If a UPPC issues a notice and retains the funds, it
       misrepresents the nature of the enforcement, redirects funds
       from their intended destination (public coffers) into private
       profits which clear abuse of the byelaw framework, undermining
       the public interest and the legal integrity of the railway bylaw
       enforcement system.
       In conclusion, an unregulated private parking company issuing a
       purported "Penalty Notice" under railway bylaw 14 is acting
       unlawfully. Such notices are inherently fake, as only a TOC
       prosecutor has the authority to issue them and initiate
       proceedings under the SJP. Any language implying criminal
       liability or penalties is misleading and constitutes fraud or
       extortion. Furthermore, since fines under the byelaws are
       intended for the public purse, the UPPC’s actions divert funds
       improperly for private gain.
       This conduct must be legally challengeable, and recipients of
       such notices would be justified in treating them as invalid and
       reporting the matter to the relevant authorities.
       What I would like to know, is how could I initiate the necessary
       action to get the appropriate authorities alerted to this
       fraudulent and extortionate behaviour? I would like to do so as
       I have the time and some resources available but short of going
       out and deliberately getting one of these fake PNs issued to me
       personally, I am at a loss.
       #Post#: 50884--------------------------------------------------
       Re: Can a private company initiate a criminal prosecution under
       the SJP?
   DIR By: andy_foster
       Date: December 23, 2024, 12:45 pm
       ---------------------------------------------------------
       Playing Devil's Advocate - PPCs often issue Penalty Charge
       Notices on behalf of LAs. Is this any different?
       #Post#: 50886--------------------------------------------------
       Re: Can a private company initiate a criminal prosecution under
       the SJP?
   DIR By: b789
       Date: December 23, 2024, 12:56 pm
       ---------------------------------------------------------
       --- Quote from: andy_foster link ---
       >
       > Playing Devil's Advocate - PPCs often issue Penalty Charge
       Notices on behalf of LAs. Is this any different?
       >
       --- End Quote ---
       Yes, there is a significant difference between Penalty Charge
       Notices (PCNs) issued by private parking companies (PPCs) on
       behalf of Local Authorities (LAs) and purported Penalty Notices
       issued by PPCs under other circumstances, such as for railway
       byelaw breaches or private land parking enforcement.
       When PPCs issue Penalty Charge Notices on behalf of Local
       Authorities, they are acting under the statutory powers
       delegated to the LA, typically under the Traffic Management Act
       2004 (TMA 2004) in England and Wales or Road Traffic Regulation
       Act 1984 or other legislation applicable to the relevant area.
       These notices are lawful because they are issued under the
       authority of public law and relate to enforceable statutory
       regulations (e.g., parking restrictions, controlled zones).
       PCNs issued by or on behalf of LAs are part of the civil
       enforcement system, but they carry statutory backing. Recipients
       who wish to contest the notice can appeal to the Traffic Penalty
       Tribunal (TPT) in England and Wales or the Parking and Bus Lane
       Tribunal for Scotland in Scotland.
       If the notice is upheld and the charge remains unpaid, it can be
       enforced through the Traffic Enforcement Centre (TEC) or
       equivalent, leading to debt recovery action. Any penalty
       collected from a PCN issued under LA authority goes to the Local
       Authority and is reinvested in public infrastructure,
       transportation improvements, or other community benefits. PPCs
       issuing these notices do not retain the fines as profit but are
       paid a fee by the LA for their management services.
       The process for handling Penalty Charge Notices (PCNs) issued by
       Local Authorities (LAs) is firmly rooted in civil law, not
       criminal law, and any disputes or enforcement related to PCNs
       are managed through the County Court system rather than the
       Magistrates' Court.
       If the recipient neither pays the penalty nor appeals
       successfully, the enforcement process moves forward as a civil
       matter:
       [indent]a. Charge Certificate
       If no payment is made after the PCN becomes enforceable, the LA
       issues a Charge Certificate, increasing the penalty amount
       (typically by 50%).
       b. Registration as a Civil Debt
       If payment is still not made, the LA can register the debt at
       the Traffic Enforcement Centre (TEC), which operates as part of
       the County Court system (not the Magistrates' Court).
       Once registered, the PCN is treated as a civil debt, similar to
       any unpaid invoice or financial liability.
       c. Enforcement via County Court
       The LA can apply for a warrant of control to enforce the debt
       through civil means, such as instructing bailiffs (enforcement
       agents) to recover the outstanding amount.[/indent]
       Importantly, this is a civil enforcement action. No criminal
       record or criminal penalties are involved.
       #Post#: 50887--------------------------------------------------
       Re: Can a private company initiate a criminal prosecution under
       the SJP?
   DIR By: andy_foster
       Date: December 23, 2024, 1:19 pm
       ---------------------------------------------------------
       So, in a nutshell, LAs can delegate issuing of penalty notices
       to PPCs because DPE operates under civil law and there is an
       appeals process, but TOCs can't delegate issuing of penalty
       notices to PPCs because the bylaws operate under criminal law?
       But using a lot more words.
       #Post#: 50891--------------------------------------------------
       Re: Can a private company initiate a criminal prosecution under
       the SJP?
   DIR By: b789
       Date: December 23, 2024, 1:43 pm
       ---------------------------------------------------------
       Yes, but it's -15 outside and snowing so I have time to kill.
       I still want to give APCOA/SABA the BPA and POPLA their
       comeuppance for their unlawful actions and extortion though.
       #Post#: 50901--------------------------------------------------
       Re: Can a private company initiate a criminal prosecution under
       the SJP?
   DIR By: NewJudge
       Date: December 23, 2024, 2:24 pm
       ---------------------------------------------------------
       Then the best thing that TOCs can do is to simply cease the
       nonsense with their "Penalty Charges" (or whatever they call
       them), employ somebody to patrol their car parks to tell them
       when somebody has broken their rules and simply move straight to
       prosecution with all the people who break their parking bylaws.
       Because if they'd done that with the "live" case, we would not
       be having this discussion.
       The complication arises because they kindly give the miscreants
       the chance to pay a bribe so as to avoid prosecution. They have
       no need to do this but all the alleged miscreants have to do if
       they don't like the look of it is to simply ignore it.
       Quite why some of them complicate it even further by introducing
       a civil arbitration process to resolve an allegation of a
       criminal offence is a complete mystery.
       Of course the simplest way to resolve this is to remove from the
       TOCs their recourse to criminal proceedings for something which,
       virtually everywhere else, is a civil matter.
       As for bribery and corruption, as Andy often tells us, the
       police in England & Wales operate a very profitable scheme
       offering those accused of some minor traffic offences the chance
       to avoid prosecution by paying for an educational course from
       which they receive a very generous cut.
       #Post#: 50912--------------------------------------------------
       Re: Can a private company initiate a criminal prosecution under
       the SJP?
   DIR By: roythebus
       Date: December 23, 2024, 5:45 pm
       ---------------------------------------------------------
       Yes. Councils are not railway land covered by railway byelaws.
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