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#Post#: 92353--------------------------------------------------
Re: Group nexus-parking charge-never entered any carpark
DIR By: b789
Date: October 1, 2025, 9:11 am
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You can use a single point POPLA appeal for this. Personally, I
would send a snot-o-gram to the intellectually malnourished
morons at GroupNexus as follows:
--- Quote ---
> Dear GroupNexus,
>
> Thank you for your generic rejection letter. I see that, once
again, you have entirely side-stepped the single and fatal issue
I raised.
>
> Your Notice to Keeper does not comply with Schedule 4 of the
Protection of Freedoms Act 2012. You chose not to issue a fully
PoFA-compliant notice and it is now too late for you to do so.
This means you cannot hold me, the registered keeper, liable for
the charge.
>
> You may shout about signage until you are blue in the face,
but the law is quite clear: unless you comply with PoFA, only
the driver can ever be liable. The driver has not been
identified and will not be. Your entire position is therefore
nothing more than a hollow attempt at extortion.
>
> If you genuinely believe in your case, by all means waste your
money at POPLA. My appeal will be very short: No keeper
liability. Driver not identified. End of matter.
>
> Please stop insulting my intelligence with boilerplate waffle
about “BPA compliance.” The BPA Code of Practice does not
override statute.
>
> I await your operator response pack after I submit my POPLA
appeal, so that I can again highlight your incompetence and
inability to comprehend the law, assuming you do not concede at
that point.
>
> Yours sincerely,
>
> [Name]
--- End Quote ---
As for your POPA appeal, you only need to point out to the
assessor two points why there can be no Keeper liability. You
can use the following single point appeal:
--- Quote ---
> PoFA says the notice must clearly tell me who the “creditor”
is. That means the exact legal person who says I owe the money.
>
> This notice uses the GroupNexus brand on top, but the small
print says CP Plus Limited “trading as” GroupNexus. Those are
not the same thing as one clear creditor. They are two different
companies with different numbers at Companies House:
>
> [indent]• GROUPNEXUS LIMITED — company no. 15560549
(incorporated 13 March 2024).
> • CP PLUS LIMITED — company no. 02595379 (incorporated 26
March 1991).[/indent]
>
> By the date of the alleged event (shown on the NtK as
21/08/2025), GroupNexus Limited already existed as a separate
legal entity. Saying “CP Plus Ltd t/a GroupNexus” does not
identify whether the creditor is (a) CP Plus Limited, or (b)
GroupNexus Limited, or (c) some brand name with no legal
personality. PoFA requires one clear creditor, not a brand badge
and a different company in the footer.
>
> Because the notice does not identify the creditor as required
by PoFA 9(2)(h), keeper liability cannot arise. The operator
also still fails PoFA for:
>
> [indent]• No PoFA invitation [9(2)(e)(i)] — it doesn’t state
they don’t know the driver’s name/address for service and invite
the keeper to pay or name the driver.
> • No keeper-liability warning [9(2)(f)] — it doesn’t warn that
after 28 days from the date the notice is 'given', if unpaid and
they still don’t know the driver’s details, they have the right
to recover the charge from the keeper.[/indent]
>
> In the simplest possible terms: the NtK must say exactly who
wants the money and follow every PoFA rule. It doesn’t. The
driver is not identified. So the keeper cannot be made to pay.
The appeal must be allowed.
--- End Quote ---
#Post#: 92384--------------------------------------------------
Re: Group nexus-parking charge-never entered any carpark
DIR By: Mrcoreyd
Date: October 1, 2025, 10:56 am
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Thank you very much, both will be submitted tonight. I'll update
with any responses I get
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