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       #Post#: 81955--------------------------------------------------
       Smart Parking Ltd. PCN
   DIR By: hops
       Date: July 21, 2025, 10:26 am
       ---------------------------------------------------------
       As the registered keeper of a car that was issued with a parking
       charge notice from a private parking company, I would welcome
       some advice. The notice alleges an overstay in a car park for
       the Mulberry restaurant in Saundersfoot, SA69 9HG on the 2nd of
       July 2025 between 14:40 and 16:30 hours. This overstay was
       allegedly backed up by CCTV.
       I am advised the driver parked in a car park adjacent to that
       location but to the best of their knowledge the only way of
       accessing the other car park is through a narrow alleyway which
       also allows access to the Mulberry restaurant car park. The car
       park where vehicle was parked is the Sands car park in
       Saundersfoot and this is controlled by a separate company,
       Parkingeye. The driver has a bank statement showing a payment to
       parkingeye and having spoken to their bank the bank confirms
       that that payment was made at 14:42, two minutes after the
       arrival time. The ticket purchased & issued by the machine on
       that site is no longer available.
       The vehicle was never parked in the Mulberry car park and before
       formally contesting the matter I would welcome whether any other
       advice should be taken on board or whether any relevant
       conditions on the parking company issuing the notice have not
       been complied with.
       [attachment deleted by admin]
       #Post#: 81956--------------------------------------------------
       Re: Smart Parking Ltd. PCN
   DIR By: hops
       Date: July 21, 2025, 10:27 am
       ---------------------------------------------------------
       PCN
       [attachment deleted by admin]
       #Post#: 81957--------------------------------------------------
       Re: Smart Parking Ltd. PCN
   DIR By: Dave65
       Date: July 21, 2025, 10:58 am
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       Ymm, contravention 02-07,  issued 15-07, presumed delivery on
       17-07, 1 day out to hold the keeper liable.
       #Post#: 81969--------------------------------------------------
       Re: Smart Parking Ltd. PCN
   DIR By: hops
       Date: July 21, 2025, 11:38 am
       ---------------------------------------------------------
       --- Quote from: Dave65 link ---
       >
       > Ymm, contravention 02-07,  issued 15-07, presumed delivery on
       17-07, 1 day out to hold the keeper liable.
       >
       --- End Quote ---
       It was only delivered today to the R/K address so I am dubious
       as to the claim it was issued on the 15th.
       #Post#: 81977--------------------------------------------------
       Re: Smart Parking Ltd. PCN
   DIR By: b789
       Date: July 21, 2025, 12:18 pm
       ---------------------------------------------------------
       Doesn't matter. I tis the 'deemed' date of delivery that counts.
       (not so) Smart Parking are utterly incompetent when it comes to
       understanding of PoFA.
       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. Smart Parking 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.
       Smart Parking have no hope should you stupidly try to litigate
       this matter, so you are urged to save us both a complete waste
       of time and cancel the PCN.
       --- End Quote ---
       Come back when that is rejected for the IAS kangaroo court
       appeal. That will be rejected too but if you continue to follow
       the advice you receive here, you will not be paying a penny to
       (not so) Smart Parking. However, it will be a protracted process
       and will most likely involve a claim against you which is easily
       defended before they eventually discontinue or it is struck out.
       As they are claiming Keeper liability under PoFA when it is
       impossible to do so due to their failure to give the notice
       within the relevant period, you should submit a formal complaint
       about them to the DVLA and cite their breach of the PPSCoP
       section 8.1.1(d) and therefore  breach of the KADOE contract.
       You can search the forum for examples of these DVLA complaints.
       #Post#: 81981--------------------------------------------------
       Re: Smart Parking Ltd. PCN
   DIR By: DWMB2
       Date: July 21, 2025, 12:36 pm
       ---------------------------------------------------------
       For the IAS appeal when it gets to thay it'd be worth throwing
       in the point about their being no parking event in the first
       place. Where a meritorious defence exists, getting it in play
       alongside any technical arguments slightly increases the chances
       of it being put in the "too much effort" pile.
       #Post#: 85275--------------------------------------------------
       Re: Smart Parking Ltd. PCN
   DIR By: hops
       Date: August 12, 2025, 4:34 am
       ---------------------------------------------------------
       Perhaps not surprisingly they have declined my initial appeal.
       #Post#: 85277--------------------------------------------------
       Re: Smart Parking Ltd. PCN
   DIR By: jfollows
       Date: August 12, 2025, 4:43 am
       ---------------------------------------------------------
       The normal lie from Smart:
       --- Quote ---
       > We can confirm that the above parking charge was issued under
       Protection of Freedoms Act 2012 (POFA 2012). The parking
       contravention occurred on 02/07/2025, the registered keeper
       details were received on 10/07/2025, after which the PC was
       promptly issued within the 14 days required under POFA 2012.
       --- End Quote ---
       The date on which “the registered keeper details were received”
       is irrelevant.
  HTML https://www.legislation.gov.uk/ukpga/2012/9/schedule/4
       --- Quote ---
       > (4)The notice must be given by—
       >
       > (a)handing it to the keeper, or leaving it at a current
       address for service for the keeper, within the relevant period;
       or
       >
       > (b)sending it by post to a current address for service for the
       keeper so that it is delivered to that address within the
       relevant period.
       >
       > (5)The relevant period for the purposes of sub-paragraph (4)
       is the period of 14 days beginning with the day after that on
       which the specified period of parking ended.
       --- End Quote ---
       --- Quote ---
       > (6)A notice sent by post is to be presumed, unless the
       contrary is proved, to have been delivered (and so “given” for
       the purposes of sub-paragraph (4)) on the second working day
       after the day on which it is posted; and for this purpose
       “working day” means any day other than a Saturday, Sunday or a
       public holiday in England and Wales.
       >
       >
       --- End Quote ---
       Clearly, as @DWMB2 stated above, your IAS appeal could start
       with the fact the driver wasn’t parked in the car park in the
       first place.
       #Post#: 85291--------------------------------------------------
       Re: Smart Parking Ltd. PCN
   DIR By: DWMB2
       Date: August 12, 2025, 6:09 am
       ---------------------------------------------------------
       --- Quote from: jfollows link ---
       >
       > Clearly, as [member=103]DWMB2[/member] stated above, your IAS
       appeal could start with the fact the driver wasn't parked in the
       car park in the first place.
       >
       --- End Quote ---
       Absolutely - technical arguments around PoFA are perfectly valid
       and should certainly be raised, but the fact that the vehicle
       wasn't even in the car park alleged is such an obvious appeal
       point that this should in my view be front and centre.
       #Post#: 85762--------------------------------------------------
       Re: Smart Parking Ltd. PCN
   DIR By: hops
       Date: August 15, 2025, 6:25 am
       ---------------------------------------------------------
       Following the expected rejection of my appeal I contacted the
       restaurant concerned asking for confirmation that they were not
       the landowner nor had any control over the car park where the
       vehicle was parked and also complaining about the actions of
       Smart Parking Limited. In fairness they replied almost straight
       away, asking for a copy of the PCN and a copy of the parking
       ticket that was obtained from the car park where the car
       actually was. Whilst not referring in any way to who the driver
       was those details have been supplied and they have said they
       will contact smart parking and get back to me as soon as
       possible. I also emailed Smart parking asking them for
       confirmation that the Sands car park is not controlled by their
       land owner and of course they said they would not provide that
       information.
       I will leave it a couple of days to see if I hear back from the
       restaurant, but in order that I can prepare for the IAS appeal
       process apart from the anomaly with the notice being served late
       and also the obvious factor that I do not believe the car was
       parked in any of the spaces allocated to the restaurant, is
       there anything else that I should mention? Thank you in
       anticipation.
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