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       #Post#: 76619--------------------------------------------------
       Civil Enforcement Ltd. PCN - Payment not made / permit not
       obtained - 1 Devon Street, L38HA
   DIR By: KingJulien
       Date: June 15, 2025, 5:55 pm
       ---------------------------------------------------------
       Hello,
       I recently received a civil enforcement notice (PCN) from Civil
       Enforcement for alleged parking violation / payment not made /
       made permit not obtained in accordance with notified terms.
       The incident took place on 9th May 2025 at Liverpool. The fine
       was issued on the 16th of May and I received the notice to
       keeper by post last Friday on the 23rd of May.
       I tried to make a payment on the app, and the amount was coming
       up as 0£, on the phone and pay app, but it wasn’t going through.
       After receiving the fine, I went back to location and took the
       photo of the sign. My understanding of the signage was that the
       parking charges were in effect from 6 pm to 6am, and not outside
       these hours. However, I still received a fine from this
       location.
       I have put in an appeal using the template on the moneysaving
       expert forum, and the appeal was rejected, but I have received a
       POPLA code on the 6th of June. I have not identified the driver
       on the appeal.
       Is it worth appealing this ticket with the POPLA, or is it
       better to pay off the reduced 60£ rate, before the deadline?
       It did not strike me that the parking outside these hours were
       not allowed from the sign initially when I parked at this
       location, but it seems to say on the fine print on a careful
       look.
       I checked the location code on the phone and pay app again on a
       Friday during day time and I am attaching a screenshot showing
       the amount as 0, but unfortunately I do not have a screenshot
       from the day of alleged parking violation.
       Never had a ticket before and unsure how to go about a POPLA
       appeal.
       Thanks for the help!
       [attachment deleted by admin]
       #Post#: 76635--------------------------------------------------
       Re: Civil Enforcement Ltd. PCN - Payment not made / permit not
       obtained - 1 Devon Street, L38HA
   DIR By: b789
       Date: June 16, 2025, 4:02 am
       ---------------------------------------------------------
       Welcome. Why would you want to pay anything to an unregulated
       private parking firm? Are you tempted by the "mugs discount"?
       That sign does not form a valid parking contract for someone
       parking between 7am and 6pm on a weekday. In the small print, it
       says that the area is for "permit holders only" during those
       hours. It also says that public parking using Phone and Pay is
       only allowed from 6pm to 7am Monday to Friday, and all day on
       weekends.
       This means that during 7am to 6pm on weekdays, public parking is
       not offered at all. The sign does not invite the public to pay
       and park during that time. There is no price shown for that time
       period, and no clear offer is made. Because of this, no contract
       can be formed for a non-permit holder parking there during those
       hours. A driver in that situation would not know if they are
       allowed to park or what rules apply.
       The main restriction—"permit holders only" between 7am and
       6pm—is hidden in small print. A key requirement of the Consumer
       Rights Act 2015 (CRA) is that contract terms must be fair and
       transparent. Section 68 of the Act says that terms must be
       brought to the consumer’s attention clearly and prominently.
       Here, the restriction is not visible enough to meet that
       standard. The average driver could easily miss it.
       Also, under Section 62 of the CRA, any term that causes a
       significant imbalance to the consumer’s disadvantage is unfair
       and therefore not binding. It is unfair to bury the main
       restriction in fine print, then issue a £100 charge when the
       driver had no proper opportunity to read or understand it.
       If the operator issues a £100 parking charge for being on-site
       without a permit during those restricted hours, that also falls
       under the CRA’s list of potentially unfair terms. Schedule 2
       includes terms that require a consumer to pay a
       disproportionately high sum in compensation. Where no clear
       contract is formed and the driver was not properly informed, the
       £100 charge is likely to be considered excessive and unfair.
       In summary, no contract can be formed for public parking between
       7am and 6pm on a weekday. The sign fails to clearly explain the
       restriction, the relevant terms are buried in small print, and
       any charge issued is likely to breach the Consumer Rights Act
       2015. The operator’s signage does not meet the legal standard of
       fairness, transparency, or enforceability.
       So, with that knowledge, you should appeal to POPLA. The
       following points should be raised:
       1. No contract was formed
       There was no clear offer of parking during 7am to 6pm on a
       weekday. The sign gives the impression that parking is allowed
       for payment, but then restricts it to permit holders in small
       print. A driver cannot accept terms that are not clearly
       offered, so no contract could be formed.
       2. Signage is misleading and unfair
       The key restriction is hidden in fine print, which fails the
       legal requirement for clear and prominent terms. The sign does
       not make it obvious that daytime parking is banned for
       non-permit holders. That goes against what most people would
       understand from looking at it quickly. POPLA assessors have
       previously cancelled charges where signage is unclear.
       3. Consumer Rights Act 2015 applies
       The hidden restriction breaches the Consumer Rights Act. Section
       62 requires fairness. Section 68 requires transparency. Schedule
       2 says a term may be unfair if it causes a significant
       imbalance, or makes someone pay an excessive penalty. In this
       case, the sign hides key terms, and the £100 charge is out of
       proportion if the person did not know parking was restricted.
       4. App showed zero charge
       You tried to pay using the app, and it showed £0 and didn’t
       allow payment. That confirms there was no option to pay. If the
       system doesn’t let the driver pay, there’s no contract. You’ve
       provided a screenshot from the same location and time of day
       that shows this behaviour.
       5. Driver was not identified
       While the keeper can be held liable under PoFA, this doesn’t
       affect the rest of the appeal. POPLA will still cancel if they
       find the signage and terms are unclear or unfair. POPLA
       decisions are based on evidence and contract law, not just PoFA.
       6. Require Proof of Posting date of the NtK
       You claim that the NtK was not received by post until 23rd May.
       The operator is required to be able to evidence the date the
       notice entered the postal system. Put them to strict proof.
       7. Put the operator to strict proof of a valid contract flowing
       from the landowner
       Put CE to strict proof that they hold a valid contract flowing
       from the landowner. If they only provide a statement, it must
       still evidence the following points as required under the PPSCoP
       section 14:
       [indent]Where controlled land is being managed on behalf of a
       landowner(s), before a parking charge can be issued written
       confirmation must be obtained by the parking operator from the
       landowner(s) covering:
       [indent]a) the identity of the landowner(s)
       b) a boundary map of the land to be managed;
       c) such byelaws as may apply to the land relating to the
       management of parking;
       d) the permission granted to the parking operator by the
       landowner(s) and the duration of that permission
       e) the parking terms and conditions that are to be applied by
       the parking operator, including as appropriate the duration of
       free parking permitted, parking tariffs, and specific
       permissions and exemptions, e.g. for staff, residents or those
       stopping for short periods such as taxi and minicab drivers,
       delivery drivers and couriers;
       f) the means by which parking charges will be issued;
       NOTE 1: For example, to the windscreen or through the post.
       g) responsibility for obtaining relevant consents e.g. planning
       or advertising consents relating to signs
       h) the obligations under which the parking operator is working,
       in compliance with this Code and as a member of an ATA;
       i) notification of the documentation that the parking operator
       may be required to supply on request to authorised bodies
       detailing the relationship with the landowner; and
       j) the parking operator’s approach to the handling of appeals
       against parking charges.[/indent][/indent]
       Conclusion: You have good grounds to appeal to POPLA. The core
       issue is that the sign did not clearly explain that daytime
       parking was banned for non-permit holders. A hidden restriction
       cannot create a valid contract. Add the failed app and CRA
       issues, and your appeal has a real chance of success. Even if it
       doesn't succeed, this is almost certainly never going to get to
       a hearing if they try to litigate it.
       #Post#: 76707--------------------------------------------------
       Re: Civil Enforcement Ltd. PCN - Payment not made / permit not
       obtained - 1 Devon Street, L38HA
   DIR By: KingJulien
       Date: June 16, 2025, 8:00 am
       ---------------------------------------------------------
       Hello,
       Thank you for your help!
       I have made a draft as below
       1. No Contract Was Formed – Signage Does Not Offer Parking to
       the Public Between 7am–6pm Weekdays
       The signage at the site (Urban Student Life, 1 Devon Street,
       Liverpool) fails to make any clear offer of parking to the
       general public during weekday hours of 7am to 6pm. The sign
       states, in small print, that the area is for “permit holders
       only” during these times. There is no price listed for public
       use during these hours, nor is there any invitation to park or
       pay.
       This means no offer was made, and thus no valid contract could
       be formed for a non-permit holder. A contract cannot be enforced
       if no clear offer is made to the driver at the time of parking.
       This PCN was issued during this exact restricted time window (09
       May 2025, 12:10 to 12:39), when public parking was not available
       or offered by the operator.
       2. Signage is Misleading and Fails Consumer Protection Standards
       The core restriction—permit holders only from 7am to 6pm—is
       buried in small print and not clearly brought to the attention
       of drivers. According to the Consumer Rights Act 2015 (CRA):
       Section 68 requires that any contract term must be “transparent
       and prominent.”
       Section 62 states that unfair terms are not binding on the
       consumer.
       Schedule 2 flags terms as potentially unfair where they impose a
       disproportionate financial burden.
       In this case, a driver entering the site could reasonably
       believe they can pay to park using the app, as per the larger,
       more visible information. But the restriction in the small print
       contradicts this, and a £100 charge is excessive when the driver
       had no fair opportunity to understand they were in breach.
       3. App Confirms That No Payment Option Was Offered
       I attempted to pay using the official app (evidence attached –
       screenshot taken at the same location), and the app showed a
       £0.00 charge, with no option to pay. This supports the position
       that no contract was offered or accepted.
       If the system doesn’t allow a user to pay during those hours,
       this further confirms that no public parking is available, and
       no enforceable contract exists for the public. This strengthens
       the argument that the driver was set up to fail and unfairly
       penalised.
       4. The Operator Has Not Identified the Driver
       This Notice to Keeper has been issued under Schedule 4 of the
       Protection of Freedoms Act 2012 (PoFA), but no evidence has been
       supplied that the operator has identified the driver. I am the
       registered keeper and do not admit to being the driver.
       Liability under PoFA must therefore be established strictly
       according to the requirements of the Act, which have not been
       demonstrated.
       5. Strict Proof of Date of Posting Required
       The NtK was received several days after its issue date (16 May
       2025). I require the operator to provide strict proof of posting
       date, including evidence of postage and a certificate of
       posting, in accordance with Schedule 4 of PoFA. Without this,
       the operator cannot demonstrate compliance with the requirement
       to serve the notice within the prescribed time limits.
       6. Lack of Evidence of Landowner Authority
       The operator is put to strict proof that they have a valid
       contract with the landowner which allows them to issue parking
       charges and enforce them in their own name. The BPA Code of
       Practice (Section 7) requires operators to have written
       authorisation from the landowner to manage and enforce parking.
       This must include:
       The identity of the landowner(s)
       A site boundary plan
       The terms and conditions being enforced
       Duration of agreement
       Details of how and where charges can be issued
       A generic statement will not suffice. The contract must be
       specific to this site and cover the date in question. If the
       operator fails to provide this documentation, the charge must be
       cancelled.
       Is this enough for the appeal or would you recommend adding
       anything else?
       Thanks![left][/left]
       #Post#: 76740--------------------------------------------------
       Re: Civil Enforcement Ltd. PCN - Payment not made / permit not
       obtained - 1 Devon Street, L38HA
   DIR By: b789
       Date: June 16, 2025, 11:55 am
       ---------------------------------------------------------
       --- Quote from: KingJulien link ---
       >
       > 3. App Confirms That No Payment Option Was Offered
       > I attempted to pay using the official app (evidence attached –
       screenshot taken at the same location)...
       >
       > 4. The Operator Has Not Identified the Driver
       > This Notice to Keeper has been issued under Schedule 4 of the
       Protection of Freedoms Act 2012 (PoFA), but no evidence has been
       supplied that the operator has identified the driver. I am the
       registered keeper and do not admit to being the driver.
       Liability under PoFA must therefore be established strictly
       according to the requirements of the Act, which have not been
       demonstrated.
       >
       --- End Quote ---
       Can you see what's wrong above? If you are claiming no Keeper
       liability, whilst there is no legal obligation on the Keeper to
       identify the driver to an unregulated private parking firm, it
       is very easy to inadvertently blab the drivers identity if you
       don't refer to the driver in the third person. No "I did this or
       that", only "the driver did this or that".
       #Post#: 76752--------------------------------------------------
       Re: Civil Enforcement Ltd. PCN - Payment not made / permit not
       obtained - 1 Devon Street, L38HA
   DIR By: KingJulien
       Date: June 16, 2025, 12:45 pm
       ---------------------------------------------------------
       --- Quote from: b789 link ---
       >
       > [quote author=KingJulien link=topic=6829.msg76707#msg76707
       date=1750078801]
       > 3. App Confirms That No Payment Option Was Offered
       > I attempted to pay using the official app (evidence attached –
       screenshot taken at the same location)...
       >
       > 4. The Operator Has Not Identified the Driver
       > This Notice to Keeper has been issued under Schedule 4 of the
       Protection of Freedoms Act 2012 (PoFA), but no evidence has been
       supplied that the operator has identified the driver. I am the
       registered keeper and do not admit to being the driver.
       Liability under PoFA must therefore be established strictly
       according to the requirements of the Act, which have not been
       demonstrated.
       >
       --- End Quote ---
       Can you see what's wrong above? If you are claiming no Keeper
       liability, whilst there is no legal obligation on the Keeper to
       identify the driver to an unregulated private parking firm, it
       is very easy to inadvertently blab the drivers identity if you
       don't refer to the driver in the third person. No "I did this or
       that", only "the driver did this or that".
       [/quote]
       That would have been a major mistake. Thanks for pointing it
       out.
       #Post#: 85576--------------------------------------------------
       Re: Civil Enforcement Ltd. PCN - Payment not made / permit not
       obtained - 1 Devon Street, L38HA
   DIR By: KingJulien
       Date: August 13, 2025, 2:10 pm
       ---------------------------------------------------------
       I just had the POPLA appeal outcome. They rejected it.
       Should I just wait to see if they take it to court, or should I
       be doing anything else in the meanwhile?
       Is it worth raising a compliant with the BPA? Or should I just
       wait and see if I receive a LBC?
       Assessor supporting rational for decision
       When entering onto a private car park such as this one, a
       motorist might form a contract with the parking operator by
       remaining on the land for a reasonable period. The signage in
       place sets out the terms and conditions of this contract. The
       contract on site is a pay for parking car park and permit
       holders can register their vehicle registration. The operator
       provided photographic evidence of the vehicle in question
       remaining in the car park for 29 minutes and didn’t register
       their vehicle registration. In relation to point 1: The
       appellant was present on site during hours when public parking
       is not permitted. It is the responsibility of the motorist to
       observe and comply with the clearly displayed signage. The
       operator is under no obligation to offer public parking between
       the hours of 7:00 AM and 6:00 PM. The terms and conditions for
       parking on the site are set by the landowner, not the motorist.
       It is the motorist’s duty to ensure they are parking in
       accordance with these terms. Failure to do so may result in the
       issuance of a Parking Charge Notice. In relation to point 2:
       This sector Code of Practice has been jointly created by the
       British Parking Association (BPA) and the International Parking
       Community (IPC). It is largely based on the Government’s Private
       Parking Code of Practice, which was published in February 2022,
       and subsequently withdrawn in June 2022. The new Code came into
       force on the 1 October 2024. The Private Parking Sector Single
       Code of Practice (The Code). Section 3.1.1 of the Single Code of
       Practice states that there must be an entrance sign displayed
       and maintained at the entrance to the site, to inform drivers
       whether parking is permitted subject to terms and conditions or
       prohibited. Section 3.1.2 of the Code contains the principles
       the entrance sign must display, including whether public parking
       is available and if a payment is required. Its design must also
       comply with the standard format as described in Annex A. The
       entrance sign must take into account the speed of vehicles
       approaching the car park. The operator's evidence proves clear
       entrance signage. Section 3.1.3 of the Single Code of Practice
       contains the requirements for signs displaying the terms and
       conditions. The signs must be placed throughout the site, so
       that drivers have the opportunity to read them when parking or
       leaving their vehicle. The terms and conditions must be clear
       and unambiguous, using a font and contrast that is be
       conspicuous and legible. I am satisfied that the signage on site
       meets the single code of practice. Furthermore, the signage is
       clear that public parking is Monday to Friday 6pm – 7am. The
       signage does not mislead motorists as the font is large and
       clear when public parking is. The smaller writing tells
       motorists that public parking is only permitted 7am – 6pm,
       Monday to Friday. But is still clear for the motorists to see.
       The obligation lies with the motorist to read the full sign and
       ensure they are fully aware of the terms and conditions.
       Furthermore, the signage does not breach the Consumer Rights Act
       2015 as it is clear, abundant. Additionally, that they app
       payment details are clear and there to advertise the payment
       method only. It does not mislead motorists into thinking the app
       payment is at all times. The responsibility lies with the
       motorist to read the signage carefully. In relation to point 3:
       The reason why the payment appellant showed zero, was because it
       was not possible to pay for parking during the time the driver
       was on site. The time they were parked the car park was for
       permit holders only which was clearly stated in the signage. In
       relation to point 4: In this case, it is not clear who the
       driver of the appellant’s vehicle is, so I must consider the
       Protection of Freedoms Act (PoFA) 2012, as the operator issued
       the Parking Charge Notice (PCN) to the keeper of the vehicle.
       The operator has provided me with a copy of the notice to keeper
       sent to the appellant. I have reviewed the notice to keeper
       against the relevant sections of PoFA 2012 and I am satisfied
       that it is compliant. I will therefore be assessing the
       appellant’s liability as the keeper of the vehicle. I can see
       from the Notice to Keeper (NTK) that it meets POFA and the
       keeper has rightly been pursued for the parking event. In
       relation to point 5: There is not requirement for the posting
       date as the parking event was 09/05/25 and the PCN was issued 7
       days later. It is assumed that the PCN would be delivered 2 days
       after the postage date, which would take the PCN to 19 May as
       the delivery date, which is still only 10 days after the parking
       event and well within the POFA guidelines. In relation to point
       6: Section 14.1 of the Code states that where controlled land is
       being managed on behalf of a landowner, written confirmation
       must be obtained before a parking charge can be issued. In this
       case I can see from the operator's evidence pack that they have
       included an Enforcement Agreement to prove they have authority
       to issue the PCN. POPLA accepts Enforcement Agreements from
       operators to confirm they have landowner authority to operate at
       a site, and we do this because it is only a small part of
       confirming on the balance of probabilities that they have
       landowner authority. The fact that they have signs, camera,
       personnel, etc, at the site also supports that proof. While I
       note the appellant’s comments, from the information provided
       from the operator I am satisfied therefore, that the operator
       had sufficient authority on the date of the contravention.
       Furthermore, if authority had since been removed, it is likely
       that the landowner would remove the signage at the same time.
       Not many landowners would look on quietly while someone operates
       on their land without their permission. In relation to point 7:
       I note the appellant's comments, however, the operator's only
       responsibility is to ensure the third party payment provider’s
       details are correct on the signage. The operator has no
       authority over what information the third party payment provider
       presents on its app. Any complaints about the third party
       payment provider would need to be raised with them directly
       outside of this appeals service. I note the appellant's
       comments. As POPLA is an independent body we are unable to
       become involved with anything to do with the costs, collections,
       or payments of the PCN. Any questions regarding payment would
       need to be addressed with the operator directly. POFA does not
       state a requirements for payment time frames - it only states
       the time frames in which the keeper will become liable, which is
       the warning - and this warning has been correctly given. They
       can contact the operator for further payment issues or queries.
       I acknowledge the appellant states the charge is
       disproportionate and does not reflect the loss to the landowner.
       The appeal reasons raised have led me to consider the relevant
       case law of ParkingEye v Beavis. The Supreme Court considered
       private parking charges in a high-profile case, ParkingEye v
       Beavis. The Court recognised that parking charges have all the
       characteristics of a contractual penalty, but nevertheless were
       enforceable because there were legitimate interests in the
       charging of overstaying motorists. It concluded that a charge in
       the region of £85 was proportionate, and it attached importance
       to the fact that the charge was prominently displayed in large
       lettering on the signage itself. While the specific facts of the
       case concerned a free-stay car park where the motorist had
       overstayed, I consider the principles that lie behind the
       decision remain the same. Taking these principles into account,
       I am not going to consider whether the loss is a genuine
       pre-estimate of loss or whether it reflects a correct loss to
       the landowner. Rather, I am going to consider the charge amount
       in the appellant’s case, as well as the legibility of the
       signage. After reviewing the signage provided by the operator, I
       am satisfied that the signage is legible, and the charge amount
       is in the region of £85 and therefore allowable. Ultimately, the
       crux of this case is that the driver entered the car park during
       a time when the car park was a permit holders only car park and
       public paid parking was not permitted. The signage was clear and
       told motorists public paid parking is only available Monday to
       Friday 6pm – 7am. The appellant should have left the car park as
       soon as they read the signage, rather than trying to pay for
       parking when payment was not possible. it is the motorist’s
       responsibility to comply with the terms and conditions of the
       car park. The car park had clear signage to advise the driver of
       the terms and conditions. Upon consideration of the evidence
       provided, the driver parked during a time when they were not
       permitted to park or should have registered their vehicle
       registration and therefore did not comply with the terms and
       conditions. This PCN was issued correctly. Accordingly, I have
       refused this appeal.
       #Post#: 85579--------------------------------------------------
       Re: Civil Enforcement Ltd. PCN - Payment not made / permit not
       obtained - 1 Devon Street, L38HA
   DIR By: ixxy
       Date: August 13, 2025, 2:24 pm
       ---------------------------------------------------------
       Nothing else you can do now other than ignore all correspondence
       from debt collectors but keep an eye out for a letter of claim,
       then come back here for further advice.
       #Post#: 85628--------------------------------------------------
       Re: Civil Enforcement Ltd. PCN - Payment not made / permit not
       obtained - 1 Devon Street, L38HA
   DIR By: b789
       Date: August 14, 2025, 3:16 am
       ---------------------------------------------------------
       What was the name of this moronic POPLA assessor? Quite clearly,
       they have had the BPA chip fully inserted and activated.
       --- Quote ---
       > The terms and conditions must be clear and unambiguous, using
       a font and contrast that is be conspicuous and legible. I am
       satisfied that the signage on site meets the single code of
       practice. Furthermore, the signage is clear that public parking
       is Monday to Friday 6pm – 7am. The signage does not mislead
       motorists as the font is large and clear when public parking is.
       The smaller writing tells motorists that public parking is only
       permitted 7am – 6pm, Monday to Friday. But is still clear for
       the motorists to see. The obligation lies with the motorist to
       read the full sign and ensure they are fully aware of the terms
       and conditions. Furthermore, the signage does not breach the
       Consumer Rights Act 2015 as it is clear, abundant. Additionally,
       that they app payment details are clear and there to advertise
       the payment method only. It does not mislead motorists into
       thinking the app payment is at all times. The responsibility
       lies with the motorist to read the signage carefully.
       --- End Quote ---
       That sign is in no way, shape or form unambiguous. The critical
       information about permit holders only between 7am and 6pm is
       hidden in tiny font and certainly wouldn't pass Lord Dennings'
       Red Hand Rule. The ambiguity is also present because it says a
       permit can be purchased.
       I could go on but it is a waste of effort. DO NOT pay a penny.
       The POPLA decision is not binding on you. Should this ever reach
       a court room, they would not stand a chance trying to convince a
       really independent arbiter that the sign does not fail the CRA.
       For now, you can safely ignore all useless debt recovery
       letters. Debt collectors are powerless to actually do anything
       except to try and persuade the low-hanging fruit on the gullible
       tree to pay up out of ignorance and fear.
       Come back when you receive a Letter of Claim (LoC) and this is
       easily fought with the advice we provide.
       Edited to add: I just asked a judge about this signage and he
       agreed and couldn't see a judge finding for the claimant on this
       one.
       #Post#: 92019--------------------------------------------------
       Re: Civil Enforcement Ltd. PCN - Payment not made / permit not
       obtained - 1 Devon Street, L38HA
   DIR By: KingJulien
       Date: September 29, 2025, 10:08 am
       ---------------------------------------------------------
       --- Quote from: b789 link ---
       >
       > What was the name of this moronic POPLA assessor? Quite
       clearly, they have had the BPA chip fully inserted and
       activated.
       >
       > [quote]The terms and conditions must be clear and unambiguous,
       using a font and contrast that is be conspicuous and legible. I
       am satisfied that the signage on site meets the single code of
       practice. Furthermore, the signage is clear that public parking
       is Monday to Friday 6pm – 7am. The signage does not mislead
       motorists as the font is large and clear when public parking is.
       The smaller writing tells motorists that public parking is only
       permitted 7am – 6pm, Monday to Friday. But is still clear for
       the motorists to see. The obligation lies with the motorist to
       read the full sign and ensure they are fully aware of the terms
       and conditions. Furthermore, the signage does not breach the
       Consumer Rights Act 2015 as it is clear, abundant. Additionally,
       that they app payment details are clear and there to advertise
       the payment method only. It does not mislead motorists into
       thinking the app payment is at all times. The responsibility
       lies with the motorist to read the signage carefully.
       --- End Quote ---
       That sign is in no way, shape or form unambiguous. The critical
       information about permit holders only between 7am and 6pm is
       hidden in tiny font and certainly wouldn't pass Lord Dennings'
       Red Hand Rule. The ambiguity is also present because it says a
       permit can be purchased.
       I could go on but it is a waste of effort. DO NOT pay a penny.
       The POPLA decision is not binding on you. Should this ever reach
       a court room, they would not stand a chance trying to convince a
       really independent arbiter that the sign does not fail the CRA.
       For now, you can safely ignore all useless debt recovery
       letters. Debt collectors are powerless to actually do anything
       except to try and persuade the low-hanging fruit on the gullible
       tree to pay up out of ignorance and fear.
       Come back when you receive a Letter of Claim (LoC) and this is
       easily fought with the advice we provide.
       Edited to add: I just asked a judge about this signage and he
       agreed and couldn't see a judge finding for the claimant on this
       one.
       [/quote]
       Unfortunately I do not recollect the name of the assessor, and I
       am unable to access the appeal outcome anymore on the POPLA
       website.
       Thank you for the clarification regarding the signage.
       I have now received a Letter before Action directly from Civil
       enforcement. It has given me a 30 day period to respond to the
       letter, and it looks like they have skipped the debt collector
       letter stage on this.
       I am attaching the letter I received and would appreciate any
       advice.
       On a related note, I had parked in the same car park, the day
       before, and the app allowed me to park, and I managed to find a
       receipt for this on Phone and Pay app, and I have previously
       paid for parking at this location as well. Should I mention this
       going forward if this goes to court?
       Payment receipts
  HTML https://i.ibb.co/WWj5SjfG/Screenshot-2025-09-29-155120.png
  HTML https://i.ibb.co/PGDhSLkd/Screenshot-2025-09-29-155042.png
       Letter Before Claim
  HTML https://i.ibb.co/ym4JnXzv/CE-LBC.jpg
       Is there any need to respond to this letter at this stage?
       Thanks!
       #Post#: 92023--------------------------------------------------
       Re: Civil Enforcement Ltd. PCN - Payment not made / permit not
       obtained - 1 Devon Street, L38HA
   DIR By: b789
       Date: September 29, 2025, 10:25 am
       ---------------------------------------------------------
       You can respond to that LBC (LoC) as follows:
       --- Quote ---
       > Subject: Response to your Letter Before Claim Ref: [reference
       number]
       >
       > Dear Sirs,
       >
       > Your Letter Before Claim contains insufficient detail of the
       claim and fails to provide copies of the evidence you place
       reliance upon, putting it in clear breach of the Pre-Action
       Protocol for Debt Claims.
       >
       > As a serial litigator, one would expect you to comply with
       paragraphs 3.1(a)–(d), 5.1 and 5.2 of the Protocol, and
       paragraphs 6(a) and 6(c) of the Practice Direction. These
       provisions exist to facilitate informed discussion and
       proportionate resolution. You may wish to reacquaint yourselves
       with them.
       >
       > The Civil Procedure Rules 1998, Pre-Action Conduct and
       Protocols (Part 3), require the exchange of sufficient
       information to understand each other’s position. Part 6
       clarifies that this includes disclosure of key documents
       relevant to the issues in dispute.
       >
       > Your template letter refers to a “contract” yet encloses none.
       That omission undermines the only foundation upon which your
       claim allegedly rests. It is not possible to engage in
       meaningful pre-litigation dialogue while you decline to furnish
       the very document you purport to enforce.
       >
       > I confirm that, once I am in receipt of a Letter Before Claim
       that complies with para 3.1(a), I shall seek advice and submit a
       formal response within 30 days, as required. Accordingly, please
       provide:
       >
       > [indent]1. A copy of the original Notice to Keeper (NtK) and
       any notice chain relied upon to assert PoFA 2012
       liability.

       > 2. A copy of the contract you allege exists between you and
       the driver, being an actual photograph of the sign(s) in place
       on the material date (not a stock image), together with a site
       plan showing the sign locations.

       > 3. The precise wording of the clause(s) allegedly breached.
       > 
4. The written agreement between you and the landowner
       evidencing standing/authority to enforce and to litigate.

       > 5. A breakdown of the sums claimed, identifying whether the
       principal sum is claimed as consideration or damages, and
       whether the £70 “debt recovery” add-on includes
       VAT.
[/indent]
       >
       > I am entitled to this information under paragraphs 6(a) and
       6(c) of the Practice Direction, and I require it to meet my own
       obligation under paragraph 6(b).
       >
       > If you fail to provide the above, I will treat that as
       non-compliance with the PAPDC and Pre-Action Conduct. I reserve
       the right to place this correspondence before the Court and to
       seek appropriate sanctions and costs (including, where
       appropriate, a stay and/or other case management orders).
       >
       > Until you comply and provide the requested material, I am
       unable to respond properly to the alleged claim or to consider
       my position. It would be premature and a waste of costs and
       court time to issue proceedings. Should you do so, I will seek
       immediate case management relief pursuant to paragraph 15(b) of
       the Practice Direction and an order compelling provision of the
       above.
       >
       > Please note, I will not engage with any web portal; I will
       only respond by email or post.
       >
       > Yours faithfully,
       >
       > [Your name]
       --- End Quote ---
       *****************************************************
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