URI:
   DIR Return Create A Forum - Home
       ---------------------------------------------------------
       FreeTrafficLegalAdvice
  HTML https://ftla.createaforum.com
       ---------------------------------------------------------
       *****************************************************
   DIR Return to: Private parking tickets
       *****************************************************
       #Post#: 62043--------------------------------------------------
       APCOA Redhill Station AND APCOA Heathrow drop off
   DIR By: olly1234
       Date: March 12, 2025, 4:37 am
       ---------------------------------------------------------
       Hi All,
       In the space of 4 days 2 PCNs received through our leasing
       company. Grouped together as both APCOA.
       The car is leased from a leasing company.
       First PCN - Redhill Station
       The car was parked and parking paid for through the APCOA QR
       Code displayed, but still a PCN from APCOA has been received,
       through the leasing company, for "use of Private Car Park
       without making a valid payment".No receipt of parking/payment
       when parking was paid but there is a bank statement showing the
       payment to APCOA with date & time. Searching the APCOA receipt
       finder the car can't be found.
       Second PCN - Heathrow T4 drop off
       The car drove through the drop off zone - didn't realise they
       had got to the end of it before exiting, and circling back
       around. Second time stopped in the drop off zone for pick-up
       before exiting as usual. Heathrow Terminal Drop Off charge paid
       later that evening for one drop off (as that was all that was
       showing on the website). PCN received for "Use of Drop Off Zone
       without making a valid payment".
       Any help greatly appreciated in appealing both of these.
       TIA
       #Post#: 62045--------------------------------------------------
       Re: APCOA Redhill Station AND APCOA Heathrow drop off
   DIR By: jfollows
       Date: March 12, 2025, 4:49 am
       ---------------------------------------------------------
       Please read
  HTML https://www.ftla.uk/private-parking-tickets/read-this-first-private-parking-charges-forum-guide/
       #Post#: 62046--------------------------------------------------
       Re: APCOA Redhill Station AND APCOA Heathrow drop off
   DIR By: olly1234
       Date: March 12, 2025, 5:07 am
       ---------------------------------------------------------
       PCNs attached.
       Should also add that I believe the leasing company has already
       paid the PCNs
       [attachment deleted by admin]
       #Post#: 62055--------------------------------------------------
       Re: APCOA Redhill Station AND APCOA Heathrow drop off
   DIR By: DWMB2
       Date: March 12, 2025, 5:41 am
       ---------------------------------------------------------
       --- Quote from: olly1234 link ---
       >
       > Should also add that I believe the leasing company has already
       paid the PCNs
       >
       --- End Quote ---
       You need to confirm this as it will entirely change the
       approach.
       If the charges have been paid, then APCOA are out of the
       equation entirely, and it is instead a dispute between you and
       your leasing company.
       #Post#: 62061--------------------------------------------------
       Re: APCOA Redhill Station AND APCOA Heathrow drop off
   DIR By: olly1234
       Date: March 12, 2025, 6:01 am
       ---------------------------------------------------------
       Confirmed that the leasing company has paid the Redhill Station
       PCN:
       We have paid this for one of the following reasons:
       - Legislation requires immediate payment by the registered
       keeper
       - We have been instructed to pay on your behalf by your employer
       - The offence has been escalated back to [Leasing Company]
       - We are unable to transfer liability.
       What do you need to do?
       - If you accept liability no further action is required. Please
       do not make any further payment directly to the issuing
       authority.
       - If you do not accept liability, please appeal directly to the
       authority. Instructions on how to appeal are included on the
       notification. To enable you to speak with the authority we have
       attached a Third-Party Authorisation letter. You will need to
       send this with your appeal.
       Please note, the driver of the vehicle is responsible for appeal
       and as such, we are unable to do this on your behalf.
       For both PCNs, the leasing company has sent Third Party
       Authorisation letters to APCOA putting them in contact with the
       company that leases the car (the Ltd company that the Driver is
       a director of)
       #Post#: 62088--------------------------------------------------
       Re: APCOA Redhill Station AND APCOA Heathrow drop off
   DIR By: b789
       Date: March 12, 2025, 8:22 am
       ---------------------------------------------------------
       If your lease company has paid both the Parking Charge Notice
       (PCN) for the airport drop off and the fake Penalty Notice (PN),
       then, unless the terms of your lease specifically allow them to
       pay invoices from unregulated private parking companies, you
       have been screwed royally.
       What they should have done is simply transfer liability to you
       as the Hirer of the vehicle and that would have been the end of
       the matter for the lease company. Once the liability is
       transferred, APCOA is supposed to then send a Notice to Hirer
       (NtH) in your name and you could have easily dealt with this.
       Nobody who is here receiving advice ever pays a penny to APCOA.
       The PCN is very easily disposed of by informing APCOA that, as
       the Hirer or Keeper, you are under no legal obligation to
       identify the driver to an unregulated private parking company
       and as the alleged contravention was on airport land, it is not
       relevant land and so there can be no Hirer/Keeper liability.
       APCOA would have cancelled the PCN in response.
       As for the fake PN, that is part of a huge extortion racket that
       APCOA have going on and should be reported to Action Fraud.
       APCOA cannot issue a Penalty Notice for breach of railway bylaws
       as they are not the authority that has the statutory powers to
       do so. Only the Train Operating Company (TOC) or whoever owns
       the land where the station car park is located, such as Network
       Rail can issue a PN. Any penalty that is properly issued and
       then paid, should go to the public purse, not APCOAs bank
       account.
       Any real PN can only be enforced through the magistrates court
       and that would require the TOC to lay evidence to the court and
       obtain a summons where it could then be challenged. The burden
       of proof in a criminal matter is much, much higher than for a
       civil contractual dispute and must be beyond a reasonable doubt.
       Because APCOA has set a fake PN, it is nothing but an "offered
       contract" that no-one is obliged to accept. Basically, the are
       using unlawful language in their offered contract that if you
       bribe them £100, they will not criminally prosecute you in the
       magistrates court, which they cannot and would not do anyway.
       The language used in the offered contract is unlawful because it
       suggests that they have powers that they do not possess and
       threatens you with criminal liability which simply is not true.
       However, this is all moot if the feckwits at your lease company
       have gone and paid the charges. Your only recourse is to sue
       them for the amount they have unlawfully taken from you. Check
       what your lease says about "parking charges". In most cases,
       they only refer to "fines" or "penalties" from "authorities" or
       the police.
       It really p!sses me off when these companies simple pay
       speculative invoices from the likes of APCOA or any other
       unregulated private parking company and then tell the Hirer that
       it is not their problem anymore. They have breached the CRA 2015
       by denying you any opportunity to appeal.
       If they collect any payments they have made that you dispute you
       should have those payments stopped. If by card, make a
       chargeback. If by direct debit, you dispute it with your bank.
       Edit: I have just read back through your previous post. You
       lease company has been conned into paying the fake PN. You can
       sue them for any charge they have made to you. They have been
       conned by the wording on the fake PN. This can be reported to
       the police for investigation. APCOA have absolutely no authority
       to issue PNs. The DfT even made this clear in a 2018 response to
       POPLA where they said they expect any breach of a railway bylaw
       for a minot parking offence to be dealt with under civil
       contract law and not bylaw 24.1 which is for more serious
       offences. Parking offences were decriminalised back in 1999 with
       the introduction of the Road Traffic Act.
       For the airport PCN, when you receive the NtH, just appeal with
       the following:
       --- Quote ---
       > I am the Hirer. APCOA cannot hold a Hirer liable for any
       alleged contravention on land that is under statutory control.
       As a matter of fact and law, APCOA will be well aware that they
       cannot use the PoFA provisions because Heathrow Airport is not
       'relevant land'.
       >
       > If Heathrow Airport wanted to hold Hirers liable under Airport
       Bylaws, that would be within the landowner's gift and another
       matter entirely. However, not only is that not pleaded, it is
       also not legally possible because APCOA is not the Airport owner
       and your 'parking charge' is not and never attempts to be a
       penalty. It is created for APCOA's own profit (as opposed to a
       bylaws penalty that goes to the public purse) and APCOA has
       relied on contract law allegations of breach against the driver
       only.
       >
       > The Hirer cannot be presumed or inferred to have been the
       driver, nor pursued under some twisted interpretation of the law
       of agency. Your NtH can only hold the driver liable. APCOA 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#: 62092--------------------------------------------------
       Re: APCOA Redhill Station AND APCOA Heathrow drop off
   DIR By: DWMB2
       Date: March 12, 2025, 8:34 am
       ---------------------------------------------------------
       --- Quote from: b789 link ---
       >
       > They have breached the CRA 2015 by denying you any opportunity
       to appeal.
       >
       --- End Quote ---
       We may need to use a different piece of legislation. From my
       reading of the OP's posts, it seems that he is not the hirer of
       the car, but rather, a limited company (of which he is a
       director) is the hirer, and it is this company that has a
       contractual arrangement with the lease company. On that basis,
       the company will not meet the definition of a 'consumer' for the
       purposes of the CRA.
       #Post#: 62096--------------------------------------------------
       Re: APCOA Redhill Station AND APCOA Heathrow drop off
   DIR By: b789
       Date: March 12, 2025, 8:46 am
       ---------------------------------------------------------
       --- Quote from: DWMB2 link ---
       >
       > [quote author=b789 link=topic=5501.msg62088#msg62088
       date=1741785745]
       > They have breached the CRA 2015 by denying you any opportunity
       to appeal.
       >
       --- End Quote ---
       We may need to use a different piece of legislation. From my
       reading of the OP's posts, it seems that he is not the hirer of
       the car, but rather, a limited company (of which he is a
       director) is the hirer, and it is this company that has a
       contractual arrangement with the lease company. On that basis,
       the company will not meet the definition of a 'consumer' for the
       purposes of the CRA.
       [/quote]
       I stand corrected. In my red haze at reading the lease company
       has paid a fraudulent invoice, I did not notice that the Hirer
       is to an individual, which is even more reason to challenge
       this.
       #Post#: 62104--------------------------------------------------
       Re: APCOA Redhill Station AND APCOA Heathrow drop off
   DIR By: olly1234
       Date: March 12, 2025, 9:30 am
       ---------------------------------------------------------
       Thank you all so much for your detailed responses (which
       admittedly has caused significant red haze for me as well!).
       Super clear on the airport PCN, will await the PCN NtH sent
       directly to me as opposed to the one forwarded on by the leasing
       company, and then use the wording below - very much appreciated.
       On the fake PN:
       The wording in my lease agreement is: "Except only for vehicle
       excise duty fees (see Clause 3), it is your responsibility to
       pay all parking fines, speeding fines, congestion charges and
       all other fines, charges, fees, duties and tolls that become
       payable to any authority or other organisation in respect of the
       use of the Vehicle, including any fines payable by us in respect
       of any failure by you to continuously insure the Vehicle
       ("Vehicle Charge"). If we receive a notice of intended
       prosecution or a private parking charge notice relating to the
       Vehicle  we will, where reasonably possible, transfer liability
       by providing your details to the issuing authority/relevant
       operator so that you can deal with the matter directly.  We will
       charge you an administration fee of £12 plus VAT for this
       service.  For all other fines, penalties, charges and notices,
       or if we need to do so to avoid us incurring a liability on your
       behalf, we will make payment without giving you prior notice,
       and recharge it to you."
       --- Quote ---
       > you can sue them for any charge they have made to you. They
       have been conned by the wording on the fake PN. This can be
       reported to the police for investigation. APCOA have absolutely
       no authority to issue PNs. The DfT even made this clear in a
       2018 response to POPLA where they said they expect any breach of
       a railway bylaw for a minot parking offence to be dealt with
       under civil contract law and not bylaw 24.1 which is for more
       serious offences. Parking offences were decriminalised back in
       1999 with the introduction of the Road Traffic Act.
       --- End Quote ---
       I'm going in hard then against the leasing company to get them
       to reimburse me with the threat of legal action
       #Post#: 62122--------------------------------------------------
       Re: APCOA Redhill Station AND APCOA Heathrow drop off
   DIR By: olly1234
       Date: March 12, 2025, 10:51 am
       ---------------------------------------------------------
       With the help of ChatGPT have drafted the following for the car
       leasing company. This not being my forte, is there anything you
       would call out?
       Subject: Urgent Complaint – Unlawful Payment of Penalty Notice
       to APCOA
       Dear [Leasing Company],
       I am writing to formally raise a strong objection regarding your
       decision to pay a so-called "Penalty Notice" issued by APCOA. It
       is deeply concerning that [Leasing Company], as a responsible
       leasing company, has failed to recognise that APCOA has
       absolutely no legal authority to issue Penalty Notices for
       breach of railway bylaws.
       To be absolutely clear: APCOA is not a statutory authority and
       does not possess the legal power to enforce railway bylaw
       penalties. Only the Train Operating Company (TOC) or the
       landowner, such as Network Rail, has the statutory power to
       issue a legitimate Penalty Notice. Furthermore, any properly
       issued penalty would be payable to the public purse, not to a
       private entity like APCOA.
       The Department for Transport (DfT) made this explicitly clear in
       a 2018 response to POPLA, stating that they expect any minor
       parking breach at a railway station to be dealt with under civil
       contract law, not under railway bylaw 24.1, which is reserved
       for more serious offences. In addition, parking offences were
       decriminalised in 1999 with the introduction of the Road Traffic
       Act. This reinforces the fact that APCOA’s so-called “Penalty
       Notice” is not a legally enforceable fine, but rather an offered
       contract that no one is legally obliged to accept.
       APCOA’s use of misleading and unlawful language – implying that
       payment is necessary to avoid criminal prosecution – is wholly
       deceptive and legally baseless. Any genuine bylaw offence would
       require a TOC to lay evidence before a magistrates’ court, where
       the burden of proof is beyond a reasonable doubt. APCOA,
       however, has no authority to issue, enforce, or prosecute any
       Penalty Notice. They are deliberately misrepresenting their
       powers to mislead the public into paying charges they are not
       legally obligated to pay.
       By paying this invalid demand, [Leasing Company] has effectively
       legitimised an unlawful claim and encouraged APCOA’s deceptive
       practices. Furthermore, if you have made any charge to me as a
       result of this improper payment, I reserve the right to take
       legal action against [Leasing Company] for unlawfully charging
       me for a bogus penalty that should never have been paid in the
       first place.
       I expect an immediate response from [Leasing Company]
       confirming:
       1.
       the notice.
       2.
       from APCOA.
       3.
       face legal action.
       This matter is one of legal principle and fairness. APCOA’s
       actions are misleading, unlawful, and deceptive. Your compliance
       with their baseless demands only emboldens them to continue such
       practices.
       I strongly urge you to rectify this situation immediately.
       I look forward to your prompt response.
       *****************************************************
       Page 1 of 3
   DIR Next Page