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       #Post#: 83687--------------------------------------------------
       Minster Baywatch NTK at Grosvenor casino Sheffield despite
       ticket being bought
   DIR By: tellyaddicts
       Date: August 1, 2025, 5:52 am
       ---------------------------------------------------------
       I received a NTK on 25th July (dated 18 July) claiming that a
       vehicle for which I am the registered keeper had breached the
       terms and conditions of parking at the location "Sheffield,
       Grosvenor Casino, S2 4BG" on 12th July 2025.
       Specifically that the "Vehicle was not authorised to use the car
       park".
       Looking at other cases here, I think the most pertinent facts
       are:
       - The NTK claims that the vehicle entered the car park at
       14:01:59 and left at 16:09:16.
       - A ticket was bought and displayed in the vehicle at 14:07 and
       was valid for 2 hours.
       - The sign at the paystation in the car park and the paystation
       itself displays the name Bransby Wilson. Other signs in the car
       park show Minster Baywatch - the company that has sent the NPK.
       I have yet to take any action. I'd be grateful for any advice on
       how best to proceed from the fantastic people on this forum.
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       #Post#: 83763--------------------------------------------------
       Re: Minster Baywatch NTK at Grosvenor casino Sheffield despite
       ticket being bought
   DIR By: b789
       Date: August 2, 2025, 2:59 am
       ---------------------------------------------------------
       This situation has been successfully challenged in court in the
       past. The car park signage prominently displays Bransby Wilson
       Parking Solutions as the operator, while the PCN is issued by
       Minster Baywatch.
       These are distinct companies registered separately at Companies
       House. No clear contractual link is shown to justify enforcement
       by Minster Baywatch. Ambiguity in contract terms must be
       interpreted in favor of the consumer. Drivers cannot be expected
       to contract with a party not clearly identified on the signage.
       The signage creates confusion about who the contracting party
       is. No reasonable driver would believe they were entering a
       contract with Minster Baywatch. Minster Baywatch has not
       demonstrated they are authorised to enforce parking at a site
       operated by Bransby Wilson.
       Under CRA 2015, Section 69, any ambiguity must be resolved in
       favour of the consumer. The PCN is therefore legally
       unenforceable.
       Whilst any initial appeal will fail, there is a possibility that
       POPLA would uphold the argument but even if it doesn't, it would
       fail if they ever tried to make claim in court.
       There is another point that has succeeded at POPLA... Is there a
       timestamp on those photos on the Notice to Keeper (NtK)? If not,
       then they have been cropped or altered, which is a breach of the
       PPSCoP section 7.3(b) which states:
       [indent]Photographic evidence must not be used by a parking
       operator as the basis for issuing a
       parking charge unless: the images bear an accurate time and date
       stamp.[/indent]
       Also, section 7.4 applies...
       [indent]Parking operators must not digitally or by other means
       alter images used as photographic
       evidence other than:
       a) to blur faces or the VRMs of other vehicles in the image in
       accordance with their GDPR
       obligations; or
       b) to enhance the image of the VRM for clarity, but not to alter
       the letters and numbers displayed.[/indent]
       The NtK also fails to comply with PoFA paragraph 9(2)(e)(i) as
       there is no invitation for the Keeper to pay the charge. 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 which will be rejected but will
       get you the POPLA code. 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. Minster Baywatch (MB)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.
       MB 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#: 83771--------------------------------------------------
       Re: Minster Baywatch NTK at Grosvenor casino Sheffield despite
       ticket being bought
   DIR By: tellyaddicts
       Date: August 2, 2025, 4:21 am
       ---------------------------------------------------------
       Thanks so much for such a helfpul reply.
       Would i deploy the fact the driver actually bought a ticket if
       it goes to POPLA?
       You are correct, there is no time stamp on the photos provided -
       the time is written underneath.
       #Post#: 83785--------------------------------------------------
       Re: Minster Baywatch NTK at Grosvenor casino Sheffield despite
       ticket being bought
   DIR By: b789
       Date: August 2, 2025, 6:03 am
       ---------------------------------------------------------
       Yes, you can use the fact that a ticket was purchased, but to be
       honest, don't pin too much hope on POPLA either. If it is
       successful, great. If it isn't, it's not binding and you don't
       pay.
       #Post#: 87944--------------------------------------------------
       Re: Minster Baywatch NTK at Grosvenor casino Sheffield despite
       ticket being bought
   DIR By: tellyaddicts
       Date: September 1, 2025, 4:06 am
       ---------------------------------------------------------
       Apologies for the delay in returning to this thread, I have been
       on holiday.
       Whilst away I received the expected rejection of my appeal from
       Minster Baywatch on the 12th August. The text of that response
       is below.
       Any helpful suggestions for how to draft my appeal to POPLA
       gratefully received. I need to submit by 9th September at the
       latest, but hope to get done this week.
       Thanks again for your help.
       
       Further to your appeal received on 05/08/2025 regarding the
       above charge, we note your comments; however, when this charge
       was issued this vehicle was in contravention of the agreed terms
       and conditions for all users of this site.
       Your appeal has been reviewed along with all evidence gathered
       at the time of the breach of the site rules.
       There is a contract to enter this site, as stipulated by signage
       located around the car park, signage which clearly states that
       the fee for the duration of parking must be covered or a vehicle
       driver must record their details at any provisioned vehicle
       registration system within the Grosvenor Casino on use of the
       venue as a customer on each visit. Your vehicle was observed to
       contravene this condition. After having thoroughly examined the
       payment records and authorised list for the date and time in
       question, we can find no payment nor authorised listing having
       been made for your vehicle or a vehicle with a similar
       registration.
       We are therefore unable to cancel the charge as it was issued
       correctly. You have now reached the end of our internal appeals
       procedure and must choose to do one of the following: Pay the
       charge at the prevailing rate of £60.00 within 14 days. Please
       note that after this time the discounted rate will no longer
       apply and the Charge will rise to £100.00.
       MINSTER BAYWATCH LIMITED
       P.O. Box 731 York YO31 7WP Website: www.minsterbaywatch.co.uk
       Registered Address Minster Baywatch Ltd Popeshead Court Offices,
       Peter Lane, York YO1 8SU Registered in England and Wales,
       Company Registration Number 07517434
       You can submit a further appeal to the Independent Appeals
       Service, POPLA (Parking on Private Land Appeals) using the POPLA
       code provided above, any appeal to POPLA must be made within 28
       days. Please note that where a charge has been issued in
       Scotland or Northern Ireland, only the driver may appeal to
       POPLA. If you appeal to POPLA and you withdraw your appeal or
       your appeal is rejected, the option to pay at the discounted
       amount of £60.00 will no longer apply and the full amount of
       £100.00 will be due. Further details on how to appeal to POPLA
       can be found on their website, www.popla.co.uk.
       If you choose to do nothing, after 35 days we will seek to
       recover the monies owed to us via our debt recovery procedures
       and may proceed with Court action against you. By law we are
       also required to inform you that Ombudsman Services
       (www.ombudsman-services.org/) provide an alternative dispute
       resolution service that would be competent to deal with your
       appeal. However, we have not chosen to participate in their
       alternative dispute resolution service. As such should you wish
       to appeal then you must do so to POPLA, as explained above.
       To support our eligibility to pursue this Parking Charge Notice,
       we would like to draw your attention to the fact that on 4th
       November 2015 there was a landmark Court decision that saw a
       motorist challenge a Parking Charge Notice through the Court
       system of England and Wales with the final appeal to the Supreme
       Court. Where, in a final decision made by the Supreme Court
       Judges, a Judgement was handed down supporting the view that a
       parking charge should be viewed as an effective deterrent. The
       judgment confirmed the parking charge was lawful and motorists
       parking on private land must comply with the advertised terms
       and conditions. Further information regarding this judgement can
       be found at www.supremecourt.uk/cases/uksc-2015-0116.html
       Payments can be made online 24-hours a day at
       www.minsterbaywatch.co.uk or via our automated phone payment
       system on 03330 230973. Alternative payment methods are
       available - please refer to your original charge for details.
       Yours sincerely,
       Appeals Department
       Minster Baywatch Ltd
       #Post#: 88771--------------------------------------------------
       Re: Minster Baywatch NTK at Grosvenor casino Sheffield despite
       ticket being bought
   DIR By: tellyaddicts
       Date: September 7, 2025, 8:09 am
       ---------------------------------------------------------
       My POPLA deadline is Tuesday so I'm going to have to put my
       appeal together in the next 24 hours. If anyone does have any
       advice on what to include I would very much appreciate it.
       #Post#: 88846--------------------------------------------------
       Re: Minster Baywatch NTK at Grosvenor casino Sheffield despite
       ticket being bought
   DIR By: b789
       Date: September 7, 2025, 2:40 pm
       ---------------------------------------------------------
       Your POPLA appeal code is valid for 33 days from the date of the
       initial appeal rejection. Count 33 days from that date.
       They allow 5mdsysmfor service of the POPLA code plus 28 days.
       #Post#: 88862--------------------------------------------------
       Re: Minster Baywatch NTK at Grosvenor casino Sheffield despite
       ticket being bought
   DIR By: tellyaddicts
       Date: September 7, 2025, 3:57 pm
       ---------------------------------------------------------
       Thanks, that's good to know. Should I put together a POPLA
       appeal based on:
       1. Non-compliance of the NtK (with the reasons you posted above
       - Confusion over who contract is with (CRA 2015, Section 69); No
       time stamp on photograph (PPSCoP section 7.3(b)); Cropping the
       image (section 7.4); No invitation for the Keeper to pay the
       charge. (PoFA paragraph 9(2)(e)(i)).
       2. Evidence that a ticket was bought (but mindful not to
       identify the driver)
       Anything else I should include or other things to note when
       drafting? Should I post that back here for any comments before
       submitting?
       Thanks again for help- It is really appreciated.
       #Post#: 88865--------------------------------------------------
       Re: Minster Baywatch NTK at Grosvenor casino Sheffield despite
       ticket being bought
   DIR By: ixxy
       Date: September 7, 2025, 4:11 pm
       ---------------------------------------------------------
       Should there not be a 10 minute grace period? That's a major
       breach of the joint code.
       #Post#: 88866--------------------------------------------------
       Re: Minster Baywatch NTK at Grosvenor casino Sheffield despite
       ticket being bought
   DIR By: tellyaddicts
       Date: September 7, 2025, 4:16 pm
       ---------------------------------------------------------
       They are saying no record of the payment for the registration
       rather than overstaying - so could be an error on their part or
       the registration keyed incorrectly - but I agree any overstaying
       is very minimal.
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