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       #Post#: 85620--------------------------------------------------
       Parkingeye PCN - Non-payment - Cockhedge Shopping Centre
   DIR By: txl08
       Date: August 13, 2025, 10:45 pm
       ---------------------------------------------------------
       Can somebody help with this situation, the registered keeper is
       elderly and this is causing a lot of stress.
       The vehicle was parked in a disabled bay for around 4 hours,
       apparently 2 hours are free after which charges apply. The car
       park is pay on exit, the driver did not see any signage or pay
       machines in the vicinity of the parking space and left without
       paying. You need to input the vehicle registration at the
       machine, and there are no barriers.
       The car park is very large, the PCN states it's the ‘rear
       visitor’ car park (oo er mrs). I’m trying to track down the
       exact location of the bay on streetview, in relation to the
       payment terminal ‘in reception’, and where the signs are and
       what they say. The registered keeper did not receive the initial
       PCN but received a PCN ‘reminder’, dated 25 June (attached).
       I have emailed the retail park and intend to appeal Parking Eye
       with the MSE template, adding mention of an occupant being a
       blue badge holder and unable to walk round searching for
       signs/pay stations late at night.
       The wording on the back of the PCN refers to staying “within the
       car park for longer than the 0 hours 0 minutes max stay time”.
       This seems nonsensical to me, how can the maximum time allowed
       be zero?
       #Post#: 85643--------------------------------------------------
       Re: Parkingeye PCN - Non-payment - Cockhedge Shopping Centre
   DIR By: b789
       Date: August 14, 2025, 5:17 am
       ---------------------------------------------------------
       You need to send a formal complaint to ParkingEye, which they
       are obliged to also treat as an appeal, user section 11.2 of the
       PPSCoP.
       --- Quote ---
       > Subject: FORMAL COMPLAINT AND APPEAL – Parking Charge [PCN
       number]
       >
       > To: Complaints Department, ParkingEye Ltd
       >
       > Dear Sir/Madam,
       >
       > This is a formal complaint about the above Parking Charge
       Notice, issued to me as the registered keeper of vehicle [VRM].
       > Under Section 11.2 of the Private Parking Single Code of
       Practice (PPSCoP), any complaint that could also be considered
       an appeal must be treated as both a complaint and an appeal. If
       it is treated as an appeal, it must be handled in accordance
       with the timescales set out in Clause 8.4.
       >
       > If Clause 8.4 applies, you are also required to issue a POPLA
       verification code should you reject the appeal, and you are on
       notice that I will require that code without delay or
       obstruction.
       >
       > 1. Failure to Serve the Original Notice to Keeper – PoFA
       Schedule 4 Breach
       >
       > I did not receive the original Notice to Keeper (NtK). The
       only correspondence received was a “Reminder” dated 25 June.
       >
       > Under PoFA Schedule 4 paragraph 9(5), you must serve a
       compliant NtK within 14 days of the alleged contravention if you
       wish to transfer liability from the driver to the keeper. You
       are put to strict proof that the NtK was:
       >
       > [indent]• Generated in compliance with PoFA; and
       > • Actually posted within the statutory timeframe.[/indent]
       >
       > The presumption of service under the Interpretation Act 1978
       applies only where the sender can prove actual posting. It is a
       rebuttable presumption, not an automatic shield against
       challenge.
       >
       > For clarity:
       >
       > [indent]• Proof of posting is not the same as producing a copy
       of the NtK from your system.
       > • Acceptable evidence includes a Royal Mail certificate of
       posting, a franked mail manifest, or equivalent independent
       evidence showing the date the item entered the postal system.
       > • Without such evidence, the presumption of delivery is
       rebutted and the court must accept that the NtK was not served.
       > • Any attempt to rely on the tired line “we are not
       responsible for the postal service” will be rejected
       outright.[/indent]
       >
       > Responsibility for evidencing service lies entirely with you,
       as the party asserting that service occurred.
       >
       > 2. Disability Discrimination and Breach of PPSCoP Sections 4.1
       & 4.2
       >
       > The driver of the vehicle is a disabled person. You have
       statutory duties under the Equality Act 2010 to make reasonable
       adjustments, and you also have binding obligations under PPSCoP
       sections 4.1 and 4.2 to:
       >
       > [indent]• Ensure at least one sign containing the full parking
       terms can be viewed without the driver leaving the vehicle.
       > • Ensure obligations for disabled motorists are prominent,
       low-placed, and readily visible from disabled bays, with clear
       guidance on any steps they must take to benefit from additional
       time or concessions.[/indent]
       >
       > From the driver’s account, no terms signage or payment
       machines were visible or accessible in the vicinity of the bay
       used. This placed the disabled motorist at a clear disadvantage,
       constituting both a breach of the Code and unlawful indirect
       discrimination under the Equality Act 2010.
       >
       > You are now required to produce strict proof of compliance,
       including:
       >
       > [indent]• A dated, scaled site plan showing all signage and
       payment machines in relation to the disabled bay used.
       > • Dated photographs showing exactly what is visible from that
       bay and on the approach to it.
       > • Specific evidence of reasonable adjustments in place to
       ensure disabled motorists are not disadvantaged in accessing or
       understanding the terms.[/indent]
       >
       > 3. Vague, Incoherent and Unenforceable Allegation – “0 hours 0
       minutes”
       >
       > Your reminder states that a Parking Charge is payable if the
       vehicle “remains within the car park for longer than the 0 hours
       0 minutes max stay time”.
       >
       > This is patently absurd. A term stating that the maximum
       permitted stay is zero minutes is meaningless in contract law
       and in plain English. It is incapable of acceptance by any
       reasonable motorist and fails to convey any intelligible
       contractual obligation.
       >
       > Further, your own notice lists three entirely different and
       mutually exclusive possible reasons for issuing the charge:
       >
       > [indent]• No valid pay and display ticket purchased;
       > • Remaining at the car park for longer than permitted;
       > • Not entering the vehicle registration into a terminal in
       reception.[/indent]
       >
       > You have failed to identify which of these you allege applies
       in this case, let alone point to the specific contractual term
       said to have been breached. Such ambiguity is fatal to any
       claim, as a motorist cannot be expected to guess which
       obligation is alleged to have been breached.
       >
       > If the signage genuinely states “0 hours 0 minutes” as the
       maximum stay, then it is void for uncertainty. If it does not,
       then your Notice misrepresents the terms and is misleading. In
       either case, the allegation is unenforceable under the Consumer
       Rights Act 2015 (sections 62 and 68) due to lack of transparency
       and failure to bring a key term to the attention of the motorist
       in a clear and intelligible way.
       >
       > 4. Misuse of ParkingEye v Beavis [2015] UKSC 67
       >
       > Your reliance on Beavis is wholly misplaced and misleading.
       The Beavis judgment concerned a retail car park offering a
       clearly advertised free period, with prominent signage at the
       entrance and throughout, where the motorist had knowingly
       overstayed that free period.
       >
       > This case does not involve a clearly advertised free parking
       period, and your own paperwork suggests that no such free period
       exists. The facts are therefore materially different. To cite
       Beavis as if it applies wholesale here is at best sloppy, and at
       worst a deliberate attempt to mislead the recipient into
       believing the charge has been judicially approved in
       circumstances where it plainly has not. Any repetition of that
       position in litigation will be challenged in open court.
       >
       > 5. Litigation Warning
       >
       > For the avoidance of doubt, I am fully aware of my rights and
       the relevant legal framework. If ParkingEye is under the
       illusion that I can be influenced by veiled threats of possible
       future litigation, you are mistaken.
       >
       > If you choose to escalate this matter beyond the appeals
       process, I am already prepared and committed to defending any
       claim robustly. In that event, I will:
       >
       > [indent]• Rely on your breaches of the Equality Act 2010,
       PPSCoP, Consumer Rights Act 2015, and PoFA 2012.
       > • Place before the court any failure to address this
       complaint/appeal properly and any refusal to provide the
       evidence requested.
       > • Seek appropriate sanctions and costs for unreasonable
       behaviour under CPR 27.14(2)(g).
       > • Escalate complaints to the DVLA, BPA, and Information
       Commissioner’s Office for misuse of my personal data and failure
       to comply with statutory and Code obligations.[/indent]
       >
       > If you reject this appeal and are so sure of your position,
       you are obliged under the BPA’s AOS membership rules to issue a
       valid POPLA code to allow escalation. I will expect that code to
       be supplied without delay or obstruction. While I hold POPLA in
       little regard due to its clear lack of true independence — given
       its financial reliance on the very industry it is meant to
       assess — you remain contractually bound to provide that route of
       escalation.
       >
       > Any attempt to issue a claim without first addressing the
       substantive issues and evidence requests set out in this
       complaint will be treated as unreasonable behaviour and will be
       brought to the court’s attention in full.
       >
       > Yours faithfully,
       >
       > [Name of Registered Keeper]
       > [Address]
       > [Email]
       --- End Quote ---
       #Post#: 85662--------------------------------------------------
       Re: Parkingeye PCN - Non-payment - Cockhedge Shopping Centre
   DIR By: txl08
       Date: August 14, 2025, 6:40 am
       ---------------------------------------------------------
       Thank you so much for that, I will do as advised. Can I just
       check, should it be signed as if written by the registered
       keeper, or can (should?) they authorise me to correspond on
       their behalf, as I said they have health issues and do not need
       the stress.
       I have some more information about the location and signage
       which I will add in a following post.
       #Post#: 85666--------------------------------------------------
       Re: Parkingeye PCN - Non-payment - Cockhedge Shopping Centre
   DIR By: b789
       Date: August 14, 2025, 6:49 am
       ---------------------------------------------------------
       Unless you have power of attorney or a letter of authority from
       them to act on their behalf, then just sign it as them.
       For ParkingEye, it’s safest and cleanest if this first formal
       complaint/appeal goes in the registered keeper’s name, signed by
       them, because:
       [indent]• They are the one the PCN was issued to.
       • PoFA liability (or lack of it) attaches to them, not you.
       • ParkingEye is far less likely to try to dodge on “data
       protection” grounds if it’s from the actual addressee.[/indent]
       If they want you to handle all correspondence going forward —
       which sounds sensible given their health — then you can add a
       very short line at the end, like:
       [indent]“I authorise [Your Name] to act on my behalf in relation
       to this matter and to correspond with ParkingEye in my
       place.”[/indent]
       You would still sign it by typing in their name underneath that
       line.
       That way:
       [indent]The keeper is clearly the complainant/appellant.
       You’re formally authorised from the outset, so you can respond
       to any follow-up without ParkingEye stonewalling.[/indent]
       #Post#: 85671--------------------------------------------------
       Re: Parkingeye PCN - Non-payment - Cockhedge Shopping Centre
   DIR By: txl08
       Date: August 14, 2025, 7:10 am
       ---------------------------------------------------------
       Further information about the location and signage:
       I have been informed by the general manager of the shopping
       centre that "after 6pm this car park is for the use of Buzz
       Bingo Patrons only" and "there are a number of signs in and on
       the entry to this car park". Images of signs provided have been
       attached. 3 hours free for bingo patrons, (maybe this explains
       zero time for non-bingo?)
       The location of these signs appears to be as highlighted
       (yellow) in the plan map view attached. The vehicle was parked
       in the disabled bays outside the bingo entrance, highlighted
       (red) in plan and streetview attached. There does not appear to
       be any signage there, though streetview could be out of date. I
       have asked the centre manager to send pictures of any signs in
       this area if he has them.
       Streetview of the entrance (yellow arrow) shows a hut, which
       isn't there now, nor does it appear to be on the plan view, so
       don't know what signage is there.
       #Post#: 85677--------------------------------------------------
       Re: Parkingeye PCN - Non-payment - Cockhedge Shopping Centre
   DIR By: b789
       Date: August 14, 2025, 7:51 am
       ---------------------------------------------------------
       I wouldn't worry about it for now. According to GSV, the images
       from September 2024 show that there were no signs that conform
       to the requirements of the PPSCoP section 4.1 and 4.2.
       Send the complaint to ParkingEye as advised and wait for a
       response.
       #Post#: 85695--------------------------------------------------
       Re: Parkingeye PCN - Non-payment - Cockhedge Shopping Centre
   DIR By: txl08
       Date: August 14, 2025, 11:11 am
       ---------------------------------------------------------
       I've had a response from the centre showing signs on the red
       fencing behind the parking spaces, which I've attached for
       completeness.
       Lastly before I complain can I ask is it likely that this will
       end up in court? Am I right to presume PE/Popla will reject any
       complaint/appeal and take me to court? The reason I ask is with
       the registered keepers health issues taking up enough of my
       time, I also have ADHD and anxiety which means keeping track of
       paperwork and meeting deadlines is not my strong point, I'm
       worried I won't be able to keep on top of it all and end up
       paying additional costs.
       #Post#: 85697--------------------------------------------------
       Re: Parkingeye PCN - Non-payment - Cockhedge Shopping Centre
   DIR By: b789
       Date: August 14, 2025, 11:35 am
       ---------------------------------------------------------
       The sign needs to readable from the drivers position. That sign
       is too far away and behind the expected position of the car.
       The odds of that ever actually seeing the inside of a courtroom
       are less than 1%. If it did, the odds of winning are greater
       than 90%. If you follow the advice, you won't be paying a penny.
       You will also get a very valuable life lesson on how to stand up
       for your (or the drivers) rights and win.
       #Post#: 85699--------------------------------------------------
       Re: Parkingeye PCN - Non-payment - Cockhedge Shopping Centre
   DIR By: DWMB2
       Date: August 14, 2025, 12:02 pm
       ---------------------------------------------------------
       To emphasise the point it might be wise to take a photo from the
       perspective of a driver who has driving into the space forwards,
       showing that there isn't a sign directly in front of the space
       (which would be good practice in a disabled bay).
       Whilst nobody can provide reliable odds, I'd agree with b789
       that this is more likely to be one of the ones ParkingEye farm
       out to DCB Legal, in which case the odds of a hearing are very
       small. They usually only take legal action "in house" when they
       fancy their chances, which ones imagines they won't in this
       case.
       #Post#: 85818--------------------------------------------------
       Re: Parkingeye PCN - Non-payment - Cockhedge Shopping Centre
   DIR By: txl08
       Date: August 15, 2025, 10:53 am
       ---------------------------------------------------------
       Thanks for the continued advice. I have now submitted the
       complaint.
       Does the fact they sent the 'reminder' so soon - 9 days after
       date of 'issue' - suggest they never sent the original PCN in
       the first place? The 14 days allowed to pay the reduced rate
       hadn't even passed. It definitely wasn't received and the post
       here is usually pretty reliable.
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