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       #Post#: 53767--------------------------------------------------
       Re: VCS @ Bristol Airport
   DIR By: b789
       Date: January 17, 2025, 4:38 am
       ---------------------------------------------------------
       All that article reiterates is that as long as the Keeper or
       Hirer does not blab the drivers identity, VCS cannot transfer
       liability from the unknown driver to the known Keeper.
       Unfortunately for you, you mistakenly assumed that the hire
       company named you, the known Hirer as the unknown driver. They
       didn’t. All they did was name you as the known Hirer and it was
       you who then appealed incorrectly and revealed yourself, the
       known Hirer to also be the, up until then, the unknown driver.
       That was you mistake because you assumed that you had been
       revealed as the driver of the hire vehicle. The hire company
       does not know who the driver is and all they can do is tell VCS
       that you are the Hirer
       There is a legal distinction between the driver and the
       Hirer/Keeper. There can be no inference that the Hirer/Keeper
       must also be the driver. They may be, but the burden of proof is
       on the parking operator. There is no legal obligation on the
       Hirer/Keeper to do their job for them. It is not for the
       Hirer/Keeper to disprove anything.
       However, having blown away the “golden ticket” element of any
       appeal/defence, you still have another point you can rely on.
       However, it will come down to persuading a District Judge that,
       as the driver, you did not enter into any contractual agreement
       with VCS. Why? Have a read of the PCN and see what it is alleged
       the driver has done and what the PCN actually is.
       The PCN is nothing more than a speculative invoice for an
       alleged breach of contract by the driver. What are the main
       elements of a contractual agreement?
       1. An Offer
       2. Acceptance
       3. Consideration
       For a contract to be formed there must first be an ‘offer’ of
       something. Whatever is being ‘offered’ then has to be ‘accepted’
       by the other party. ‘Consideration’ is a form of payment or
       other benefit, and both parties must give consideration to form
       a legally binding contract.
       For example, if a VCS sign said “Parking available for £2 per
       hour. By parking, you agree to our terms.”, that is an ‘offer’.
       If the driver parks their car in the car park, they are
       indicating their agreement to the terms displayed, and that is
       the ‘acceptance’. The driver pays £2 for one hour of parking,
       and VCS provides the space and associated services, which is the
       ‘consideration.
       So, a ‘contractual agreement’ was formed between the driver and
       VCS. Now, if one of the terms was that the vehicle must be
       parked in a marked bay but the driver parked on the line
       dividing two bays, that is a breach of the terms of the contract
       and so VCS can invoice the the driver by way of a PCN for the
       breach of contract.
       Now consider what contract was formed by the signage for the
       alleged contravention you have been accused of. If a sign says
       “No stopping or picking up or dropping off”, what is being
       ‘offered’?
       A prohibitive sign cannot form a contractual agreement. VCS
       cannot simply put up a sign that says “Stopping Prohibited.
       Breaching this term will incur a charge of £100” and expect that
       it forms a contractual agreement with the driver if they do
       stop.
       That would be one of your remaining defence arguments. That and
       the fact that no one has seen an up to date, valid contract
       between Bristol Airport and VCS that permits them to issue PCNs
       in their own name or that they even have any right to do so
       outside of the car parks.
       #Post#: 53768--------------------------------------------------
       Re: VCS @ Bristol Airport
   DIR By: BelfastBoy
       Date: January 17, 2025, 4:53 am
       ---------------------------------------------------------
       The article references the Airports Act 1986. Is the fact that
       motorists are being pursued for alleged contractual breaches on
       lands falling under the authority of airport bylaws not an
       issue? Stopping where you've been told not to stop in an airport
       is, theoretically, a contravention of a clearly identifiable
       bylaw, not some legally dubious contract, surely?
       #Post#: 53776--------------------------------------------------
       Re: VCS @ Bristol Airport
   DIR By: mickR
       Date: January 17, 2025, 5:29 am
       ---------------------------------------------------------
       that is one element of the available defences.
       for that to be successful you would have to check the area of
       the alleged contravention is indeed within the airport land
       boundary for bylaws to be applicable.
       then you need to consider if the scammers parking Co are
       claiming under bylaw contravention or private parking contract.
       the response will be different for each.
       as b789 has detailed for you there also is the issue of signage
       and whether or not a contract has even been offered.
       #Post#: 53782--------------------------------------------------
       Re: VCS @ Bristol Airport
   DIR By: BelfastBoy
       Date: January 17, 2025, 5:55 am
       ---------------------------------------------------------
       They are almost certainly making their claim according to an
       assumed contract. The issue, however, is whether that's allowed
       on land covered by bylaws. Contraventions of stopping
       restrictions are surely a bylaw issue not a contractual one on
       land so explicitly covered by pretty clear legislation.
       I would repeat that VCS has simply not engaged with the point
       relating to bylaws. It hasn't even said that bylaws don't apply
       in this situation. The Guardian article features a very vague
       statement from the airport and nothing from VCS.
       #Post#: 53790--------------------------------------------------
       Re: VCS @ Bristol Airport
   DIR By: b789
       Date: January 17, 2025, 6:34 am
       ---------------------------------------------------------
       You are absolutely correct to raise the question of whether
       Vehicle Control Services (VCS) can lawfully issue a Parking
       Charge Notice (PCN) or similar demand based on an assumed
       contract when the land is explicitly subject to statutory
       byelaws. This is a fundamental issue when dealing with land
       governed by specific public law instruments, such as airport
       byelaws.
       Land explicitly covered by byelaws, such as Bristol Airport,
       operates under public law. This means any conduct regulated
       under the byelaws (e.g., stopping restrictions, driving
       offences, or parking) is enforceable only through the mechanisms
       provided within the byelaws. Since stopping restrictions are
       governed by the byelaws (e.g., sections 6.13, 6.5), such acts
       would fall under public law and would need to be prosecuted
       through a magistrates' court as a byelaw breach. A private
       company such as VCS cannot bypass this by framing the same
       conduct as a contractual issue.
       When byelaws regulate specific behavior, such as driving or
       stopping, these regulations displace any implied contractual
       framework. This principle arises from the fact that byelaws are
       statutory instruments intended to regulate the land, overriding
       private arrangements. If VCS attempts to enforce stopping
       restrictions using a contractual framework, they are effectively
       circumventing the byelaws, which is unlawful.
       For VCS to enforce a contractual claim, they must demonstrate
       the formation of a valid contract with the driver. However, most
       airport signage for stopping restrictions is prohibitive (e.g.,
       "No Stopping at Any Time"). Courts have consistently ruled that
       prohibitive signage cannot create a contractual relationship
       because it does not offer any terms for a driver to accept.
       Instead, it communicates a prohibition. If the signage specifies
       penalties for breaching byelaws, this would further reinforce
       that the matter is a statutory issue, not a contractual one.
       VCS may argue that by entering the airport's private roads, the
       driver agreed to a set of terms and conditions displayed on
       signage, forming a contract. They might then issue a PCN under
       contract law for breaching those terms (e.g., stopping in a
       restricted area).
       However, on land governed by byelaws, VCS cannot establish a
       contractual framework for conduct already regulated by statutory
       law. If stopping restrictions are enforceable only as byelaw
       breaches, VCS cannot claim a financial penalty as damages under
       contract law because the statutory framework preempts such
       claims. Any signage referencing "fines" or penalties under
       byelaws may misrepresent the nature of the charge, further
       invalidating their claim.
       VCS’s claim based on an assumed contract is certainly invalid on
       land covered by statutory byelaws. The regulation of stopping
       restrictions is exclusively within the scope of the byelaws,
       which can only be enforced via the mechanisms provided—typically
       through magistrates' court for criminal proceedings.
       If VCS attempts to enforce their claim through contract law, you
       should challenge:
       [indent]• Their authority to issue contractual demands on
       byelaw-governed land.
       • The validity of the alleged contract, especially if the
       signage is prohibitive.
       • Any misrepresentation of their role or authority in enforcing
       byelaws.[/indent]
       However, just so you are aware, VCS will claim that the airport
       bylaws are obsolete, proving their mendacious behaviour. Their
       argument that the byelaws are obsolete is an attempt to justify
       their reliance on assumed contracts to issue PCNs.
       The byelaws governing Bristol Airport were made under the
       Airports Act 1986 and approved by the Secretary of State for
       Transport. This gives them statutory authority. Byelaws cannot
       simply become obsolete; they remain enforceable until formally
       revoked, replaced, or invalidated by a court ruling or updated
       legislation.
       VCSs claim the byelaws are obsolete to justify enforcement under
       contract law, amounts to misrepresentation and an unfair
       business practice, as it falsely implies that byelaw
       restrictions do not apply. Such a claim should be challenged
       under the Consumer Protection from Unfair Trading Regulations
       2008 (CPUTRs), especially as VCS misleads drivers about the
       legal framework governing the land.
       I have not even covered how VCS can or cannot issue and
       prosecute a Penalty Notice even they had statutory authority to
       do so. They do not!
       #Post#: 53811--------------------------------------------------
       Re: VCS @ Bristol Airport
   DIR By: BelfastBoy
       Date: January 17, 2025, 8:26 am
       ---------------------------------------------------------
       Thank you very much. This is what I'm getting at.
       Bristol Airport cannot have bylaws in place governing things
       like stopping and parking but choose not to enforce them through
       the criminal courts, allowing instead a private contractor to
       issue demands for payment in the wake of alleged contractual
       breaches relating to the very behaviour that the bylaws cover.
       There cannot be two parallel regimes, one statutory and the
       other contractual, covering the same acts on the same land.
       To be clear again, VCS has made no comment whatsoever about the
       bylaws. They said nothing to me (in spite of the fact that I
       challenged them on this very issue) and clearly wanted to
       contribute nothing to The Guardian on the topic. If the land was
       not covered by the bylaws, why would VCS be shy about saying so?
       The same goes for Bristol Airport itself. If the bylaws don't
       apply, then roads directly adjacent to the airport, which it
       clearly owns, do not fall within the scope of the 'the Airport',
       as referenced on page 4 of those bylaws
  HTML https://www.bristolairport.co.uk/media/4vqbdkcf/bristol-airport-byelaws-11062018.pdf.<br
       />No plan is attached to that document; however, page 11 of this
       document
  HTML https://www.bristolairport.co.uk/media/2g3l4hjb/bristol-airport-master-plan-2006.pdf<br
       />shows the boundaries of the airport in 2006. The area at issue
       in my case is very much inside this boundary, even if the
       footprint has changed slightly in the years since.
       #Post#: 53818--------------------------------------------------
       Re: VCS @ Bristol Airport
   DIR By: mickR
       Date: January 17, 2025, 8:55 am
       ---------------------------------------------------------
       Are you looking for meaningful advice on your situation? or just
       expressing your opinion as you seem to be fixated on the
       argument you've gained from the Gary Rycroft article.
       as I said before b789 has given you excellent advice. up to you
       if you don't want to use it.
       #Post#: 53820--------------------------------------------------
       Re: VCS @ Bristol Airport
   DIR By: BelfastBoy
       Date: January 17, 2025, 9:00 am
       ---------------------------------------------------------
       --- Quote from: mickR link ---
       >
       >
       >
       > Are you looking for meaningful advice on your situation? or
       just expressing your opinion as you seem to be fixated on the
       argument you've gained from the Gary Rycroft article.
       >
       > as I said before b789 has given you excellent advice. up to
       you if you don't want to use it.
       >
       --- End Quote ---
       I know what you said before. I'm clearly looking for meaningful
       advice on my situation. b789 has now provided me with extra
       information around the bylaws question, which very much looks
       like the information contained in the article I'm 'fixated on'.
       #Post#: 53831--------------------------------------------------
       Re: VCS @ Bristol Airport
   DIR By: b789
       Date: January 17, 2025, 10:08 am
       ---------------------------------------------------------
       Obviously you intend to challenge the PCNs. As I mentioned,
       despite throwing away a perfectly good defence, you still have
       other arguments, as discussed.
       Please remind me where you are at as I simply do not have enough
       time to go back and re-read everything from the beginning. Once
       I know where you are at in the process I am more than happy to
       assist and advise on the next steps, based on your desired
       outcome.
       You won't be paying a penny to VCS and, if processed correctly,
       you could inflict some financial damage on them. I'd suggest
       that dome Schadenfreude is always a welcome tidbit.
       #Post#: 53836--------------------------------------------------
       Re: VCS @ Bristol Airport
   DIR By: BelfastBoy
       Date: January 17, 2025, 10:14 am
       ---------------------------------------------------------
       Many thanks. My appeal to the IAS has just been dismissed.
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