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       #Post#: 59391--------------------------------------------------
       Horizon Parking - Parent & Child Parking - Tesco, Windsor
   DIR By: jakey2204
       Date: February 23, 2025, 10:02 am
       ---------------------------------------------------------
       Hello, advice needed please.
       The keeper received this NtK from Horizon for parking in a
       Parent and Child bay in Tesco. The driver holds thier hand-up to
       a possible mistake thinking it was a Disabled bay (driver holds
       a valid Blue Badge) and then forgetting to display thier badge.
       On first impression the images taken do not display the front
       registration plate, however on Horizon's appeal page there are
       further images of the vehicle with the rear plate clearly
       visible and identifiable, however said images do not clearly
       show the vehicle parked in a Parent & Child bay. There is
       neither any indication on the NtK that further evidence may be
       available by means of video or cctv recordings. Can I appeal
       this notice based on this lack of evidence alone.
       Secondly, could the notification itself be non-compliant with
       POFA regulation with regards to liabilty as someone suggested on
       a fb group page?
       Any help much appreciated.
       Kind regards.
       Geoff.
       Google streetview:
  HTML https://www.google.com/maps/@51.4782437,-0.6503339,3a,75y,177.58h,86.04t/data=!3m7!1e1!3m5!1spzMwJCQJ_f49pVU-2EvM-g!2e0!6shttps:%2F%2Fstreetviewpixels-pa.googleapis.com%2Fv1%2Fthumbnail%3Fcb_client%3Dmaps_sv.tactile%26w%3D900%26h%3D600%26pitch%3D3.9586824359241604%26panoid%3DpzMwJCQJ_f49pVU-2EvM-g%26yaw%3D177.57572775896563!7i16384!8i8192?entry=ttu&g_ep=EgoyMDI1MDIxOS4xIKXMDSoJLDEwMjExNDU1SAFQAw%3D%3D
       [attachment deleted by admin]
       #Post#: 59395--------------------------------------------------
       Re: Horizon Parking - Parent & Child Parking - Tesco,
       Windsor
   DIR By: b789
       Date: February 23, 2025, 10:26 am
       ---------------------------------------------------------
       The Notice to Keeper is not PoFA compliant. Keep the fact that
       you or one of the occupants had a blue badge for later, if
       necessary.
       For now, it is an easy one to deal with… as long as the unknown
       drivers identity is not revealed. There is no legal obligation
       on the known keeper (the recipient of the Notice to Keeper
       (NtK)) to reveal the identity of the unknown driver and no
       inference or assumptions can be made.
       The NtK is not compliant with all the requirements of PoFA which
       means that if the unknown driver is not identified, they cannot
       transfer liability for the charge from the unknown driver to the
       known keeper.
       Use the following as your appeal. No need to embellish or remove
       anything from it:
       --- Quote ---
       > 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. Horizon 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.
       Horizon have no hope at POPLA, so you are urged to save us both
       a complete waste of time and cancel the PCN.
       --- End Quote ---
       #Post#: 59403--------------------------------------------------
       Re: Horizon Parking - Parent & Child Parking - Tesco,
       Windsor
   DIR By: jakey2204
       Date: February 23, 2025, 11:04 am
       ---------------------------------------------------------
       Thank you for responding.
       Happy to appeal using the above, but for the record, how does
       the NtK not fully comply with PoFA 2012?
       And shouldnt any of the non-compliance elements be brought to
       the table at this point in order to hammer-down the appeal?
       Thanks again.
       #Post#: 59411--------------------------------------------------
       Re: Horizon Parking - Parent & Child Parking - Tesco,
       Windsor
   DIR By: b789
       Date: February 23, 2025, 12:07 pm
       ---------------------------------------------------------
       Not worth wasting your time on the initial appeal as they are
       not going to accept anything you say. You are not dealing with a
       company that has any ethos of customer service. They are
       ex-clampers whose only reason d'ętre is to scam as much money
       out of motorists as they can. Do not imagine for a moment that
       they really care about parking management.
       When they reject the initial appeal, as they are BPA members,
       you can then appeal to POPLA. Whilst POPLA is supposedly
       independent, just remember that they are a business and they are
       funded by the very companies that you are appealing against.
       Also, some of their assessors are truly incompetent and even
       moronic when it comes to interpreting contract law. However,
       they do have an appellant success rate of around 30%-40%, which
       puts the IPCs IAS appellant success rate of less than 4% to
       shame.
       The NtK is not PoFA compliant with paragraphs 9(2)(a), (b), (c),
       (d), (e), (f) and (h) to name a few. You can check for yourself
       here: PoFA 2012 Schedule 4
  HTML https://www.legislation.gov.uk/ukpga/2012/9/schedule/4/enacted
       The NtK does not specify a "period of parking". It does not
       specify the "relevant land" (there are at least three Tesco
       stores in Windsor). It does not state that the Keeper is liable.
       It does not describe circumstances in which the requirement to
       pay the charge arose or the facts that made it payable. It does
       not specify that the amount due should be paid no later than the
       end of the day before the day on which the notice is sent by
       post. It does not invite the Keeper to pay the charge. It does
       not warn the Keeper that they will become liable for the charge
       if the driver is not identified after the period of 28 days
       beginning with the day after that on which the notice is given.
       It does not identify the creditor.
       I could go on, but you get the gist.
       FYI, these are at lest three Tesco stores I can find in Windsor
       and the relevant one is not identified:
       Tesco Stores Ltd, Dedworth Rd, Windsor SL4 4JT
       Tesco Stores Ltd, 32 Peascod St, Windsor SL4 1EA
       Tesco Stores Ltd, Clarence Rd, Windsor SL4 3QL
       It just confirm that you are dealing with intellectually
       malnourished, incompetent, ex-clampers
       #Post#: 59413--------------------------------------------------
       Re: Horizon Parking - Parent & Child Parking - Tesco,
       Windsor
   DIR By: jakey2204
       Date: February 23, 2025, 12:19 pm
       ---------------------------------------------------------
       Oh my! 👀
       I hadnt even noticed they hadnt narrowed down the
       location...thank god for people like you!
       Ok so I will send the appeal off as you posted, and likely
       expect rejection...and then off to PoFA we go!
       I can already see how this is going to play out so no doubt my
       next reply will be with Horizon's rejection letter.
       Thanks again 👍
       #Post#: 60354--------------------------------------------------
       Re: Horizon Parking - Parent & Child Parking - Tesco,
       Windsor
   DIR By: jakey2204
       Date: March 3, 2025, 8:37 am
       ---------------------------------------------------------
       Well I can not thank-you enough b789... found this email in junk
       folder this morning dated 28th February confirming cancellation
       of the Parking Charge!
       I am sure this wont be the last visit I make to this site, it
       seems everywhere you park you have to have your wits about you.
       Until then, keep up the great work you do and again many thanks
       for your help :-)
       [attachment deleted by admin]
       #Post#: 60361--------------------------------------------------
       Re: Horizon Parking - Parent & Child Parking - Tesco,
       Windsor
   DIR By: Sander333
       Date: March 3, 2025, 9:20 am
       ---------------------------------------------------------
       As always a wealth of knowledge provided to deal with these
       parking companies. However they will never get deterred.
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