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       #Post#: 90465--------------------------------------------------
       Re: Horizon - Failure to pay for full duration of stay
   DIR By: jfollows
       Date: September 18, 2025, 3:20 am
       ---------------------------------------------------------
       They don’t have to prove the identity of the driver if they have
       complied with PoFA 2012, which I thought we had concluded they
       had.
       #Post#: 90489--------------------------------------------------
       Re: Horizon - Failure to pay for full duration of stay
   DIR By: b789
       Date: September 18, 2025, 6:32 am
       ---------------------------------------------------------
       Whilst the NtK may be PoFA compliant, there are other points
       that they can fail PoFA such as para 2(2-3). This is why the
       drivers identity should never be revealed.
       #Post#: 90503--------------------------------------------------
       Re: Horizon - Failure to pay for full duration of stay
   DIR By: bigred247
       Date: September 18, 2025, 7:33 am
       ---------------------------------------------------------
       Thanks folks. I'll go ahead and make the appeal. It'll probably
       be a long drawn out process but will keep you folks aware of the
       outcome.
       #Post#: 93308--------------------------------------------------
       Re: Horizon - Failure to pay for full duration of stay
   DIR By: bigred247
       Date: October 8, 2025, 1:01 am
       ---------------------------------------------------------
       Just received this through the post. It was expected.
       [member=26]b789[/member] you referred to "there are other points
       that they can fail PoFA such as para 2(2-3)", are you referring
       to adequate notice? Before appealing to POPLA, should I visit
       the site and take photos of existing signage?
       --- Quote ---
       >
       > Parking Charge Reference       HP4109103
       > Vehicle Registration Number    LD63ZFM
       > Breach of Terms and Conditions Failure to Pay for Full
       Duration of Stay ANPR
       > Date and Time of Breach        16th August 202505:28 PM
       > Location Name                  Mercury Shopping Centre
       > POPLA Code                     3762745340
       > Date of this Correspondence    1st October 2025
       >
       >
       > 1st October 2025
       >
       >
       > Dear Appellant,
       >
       > Parking Charge:HP4109103
       >
       > Thank you for your recent correspondence concerning the above
       referenced Parking Charge.
       >
       >
       > Review of your Appeal
       >
       > The Parking Charge was issued lawfully and in full and proper
       accordance with the Private Parking Sector Single Code of
       Practice issued by the British Parking Association (the ‘BPA’).
       >
       > There are signs located at the entrance to, and within the car
       park that state the terms and conditions that apply when
       parking.
       >
       > As clearly stipulated on signage within the car park, payment
       for parking must be made for the full duration of the vehicles
       stay.  Our systems do not show any evidence of payment made
       against this vehicle on the incident date.
       >
       > The signs throughout the car park are clear and comply fully
       with the BPA’s prescribed rules and regulations.  When parking
       on private land, it is the driver’s responsibility to ensure
       they adhere to the terms and conditions of the car park
       concerned.
       >
       > As we have not been provided with the name and a serviceable
       address for the driver/hirer, under Schedule 4 of the Protection
       of Freedoms Act 2012, we do have the right, subject to meeting
       the requirements of the Act, to recover from the Registered
       Keeper the amount that remains outstanding. We have obtained the
       name and address of the registered keeper of the vehicle from
       the DVLA for the purposes of enforcing this charge.
       >
       > Given the above, and whilst we have considered your
       representations carefully, on this occasion your appeal has been
       rejected.
       >
       >
       > The Charge Amount and Methods of Payment
       >
       > In good faith, Horizon will hold the charge at the current
       amount of £85.00  for a further 14 days from the date of this
       correspondence to allow you further time to pay.
       >
       > Payment of the outstanding charge can be made using our
       24-hour payment line: 020 8106 0789 or online at
  HTML https://horizonparking.co.uk/pay-parking-charge-notice/
       >
       > Alternatively, payment can be made via cheque made payable to
       Horizon Parking Ltd and posted to Horizon Parking Ltd, Finitor
       House, 2 Hanbury Road Chelmsford, Essex CM1 3AE
       >
       >
       > Additional Types of Appeal
       >
       > If you have no evidence that you wish to submit to us then you
       have now reached the end of our appeals procedure.  Although we
       have rejected your appeal, the Parking On Private Land Appeals
       (POPLA) provides an independent appeals service. To use this
       service, you must appeal to POPLA within 28 days of the date of
       this correspondence.
       >
       > For full instructions of how to appeal to POPLA, please visit
       their website at www.popla.co.uk. If you would rather progress
       this matter by post, please contact our Appeals Office and we
       will send you the necessary paperwork.
       >
       >
       > Your POPLA reference number is 3762745340
       >
       > Please be advised that if you elect  for independent
       arbitration of your case, you will be required  to pay the
       charge at the full amount and as such will no longer qualify for
       payment at the reduced rate. Please also be advised that POPLA
       will not accept an appeal where payment is made against the
       Parking Charge in question.
       >
       > We are required by law  to inform you that Ombudsman Services
       (www.ombudsman-services.org/) provides an alternative dispute
       resolution service that would be competent to deal with your
       appeal;  however ,  Horizon has 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.
       >
       > Yours sincerely,
       >
       >
       --- End Quote ---
       #Post#: 93314--------------------------------------------------
       Re: Horizon - Failure to pay for full duration of stay
   DIR By: b789
       Date: October 8, 2025, 1:43 am
       ---------------------------------------------------------
       If their signs were not prominent and failed to adequately bring
       to the notice of the drover the charge, then they have failed
       PoFA, irrespective of whether their NtK was PoFA compliant.
       Have a search of the forum for other recent POPLA appeals and
       put something together and show it here before sending.
       #Post#: 94718--------------------------------------------------
       Re: Horizon - Failure to pay for full duration of stay
   DIR By: bigred247
       Date: October 19, 2025, 11:46 am
       ---------------------------------------------------------
       [member=26]b789[/member] I've conjured up the below using some
       other posts on the forum and some further observations at the
       car park entrance. Am i wide of the mark here? Any thoughts?
       --- Quote ---
       >
       >
       > As registered keeper, I challenge this PCN on the following
       grounds:
       >
       > 1: No terms/conditions displayed at entry point:
       > At the main entry point of the car park, there is only a basic
       "car park" sign with no terms, conditions, or parking charges
       displayed. This actively invites drivers to enter while
       providing no notice of the terms they will be bound by. The
       parking charges and terms are only displayed on signage
       positioned further down the entrance path, AFTER a driver has
       already turned in and committed to entering the car park.
       >
       > The BPA Code of Practice Section 19.3 explicitly requires "the
       size and positioning of the sign must take into account the
       expected speed and direction of travel of vehicles approaching
       the entrance and must be visible." By placing only an
       invitational "car park" sign at the entrance with no terms
       displayed, the operator:
       >
       > •
       or conditions
       > •
       enter
       > •
       drivers have already committed to entering private land
       > •
       before parking
       >
       > This creates an unfair catch-22: by the time the driver
       encounters the terms further down the entrance path, they have
       already entered private land. Reading the terms and deciding to
       leave would itself constitute a "breach" under the operator's
       rules. Adequate notice requires charges and key terms to be
       displayed at the decision point to enter, not after entry has
       occurred.|
       >
       > 2: Operator Must Prove Actual Notice Was Given
       > The operator cannot rely on theoretical visibility or generic
       site photos. They must prove actual notice was given to the
       driver at this specific location. The operator must prove the
       driver actually saw and understood the terms, not merely that
       signs existed somewhere on site. Generic site photographs are
       insufficient.
       >
       > I put the operator to strict proof that:
       >
       > - Signage was visible and readable from the vehicle's specific
       parking location on the material date
       > - The driver could reasonably see and read the terms before
       committing to park
       > - The parking charge was displayed prominently and in "large
       lettering" as required
       > - Photographic evidence showing the driver's actual view from
       the parking space
       >
       > 3: No Valid Contract Formed - Keeper Liability Cannot Exist
       > Due to the signage failures detailed above, no valid contract
       was formed between the driver and the operator. Without clear,
       visible, and prominent signage that the driver actually saw and
       understood:
       >
       > - No offer was properly communicated
       > - No acceptance could occur
       > - No enforceable contract exists
       >
       > Under PoFA Schedule 4, keeper liability is conditional upon
       the operator first establishing driver liability through
       adequate notice. Since adequate notice was not provided, the
       operator has failed to satisfy Paragraph 5, and therefore cannot
       pursue the keeper under Schedule 4 regardless of Notice to
       Keeper compliance.
       >
       > I request the operator provide:
       >
       > - Close-up photographs of all signage at the location on the
       material date
       > - Photographs showing sign visibility specifically from the
       parking space in question
       > - Evidence the entrance sign is visible when entering (not
       just when stationary)
       >
       >
       --- End Quote ---
       #Post#: 94722--------------------------------------------------
       Re: Horizon - Failure to pay for full duration of stay
   DIR By: bigred247
       Date: October 19, 2025, 12:41 pm
       ---------------------------------------------------------
       Here are some images of the entrance
  HTML https://i.postimg.cc/s2prStSP/Screenshot-2025-10-19-at-17-37-38.png
  HTML https://i.postimg.cc/Y0LLzrx0/Whats-App-Image-2025-10-19-at-17-26-58-1.jpg
  HTML https://i.postimg.cc/ZnvvxbLR/Whats-App-Image-2025-10-19-at-17-26-58-3.jpg
  HTML https://i.postimg.cc/hvQQ1D0G/Whats-App-Image-2025-10-19-at-17-26-58-2.jpg
  HTML https://i.postimg.cc/rmPt405x/Whats-App-Image-2025-10-19-at-17-26-58.jpg53
       #Post#: 94735--------------------------------------------------
       Re: Horizon - Failure to pay for full duration of stay
   DIR By: b789
       Date: October 19, 2025, 2:08 pm
       ---------------------------------------------------------
       The entrance sign does not have to say what the terms and
       conditions are, only that it has to inform that this is private
       land and that there are Ts&Cs which the driver can then seek out
       in the car park. However, any signs with the Ts&Cs must be
       prominent and clear with any charge for breach of the Ts&Cs,
       adequately brought to the notice of the driver. They don't have
       to be readable from within the vehicle unless an occupant has a
       blue badge and is parked in a disable users bay.
       What about putting them to struct proof of a valid and
       contemporaneous contract with the landowner that gives them
       standing to operate and issue PCNs in their own name?
       Is the car park for Asda customers only? Have you approached
       Asda and asked them to get their agent to cancel the PCN?
       #Post#: 94769--------------------------------------------------
       Re: Horizon - Failure to pay for full duration of stay
   DIR By: bigred247
       Date: October 20, 2025, 4:52 am
       ---------------------------------------------------------
       [member=26]b789[/member]
       Thanks for the reply.
       - I will update the draft with your point about a proof of a
       valid contract with the landowner.
       - According to the website,
  HTML https://www.themercurymall.co.uk/parking
       the car park can be
       used by all, but Asda customers can spend £5 in store and obtain
       a voucher for 2 hrs free parking.
  HTML https://i.postimg.cc/Dw7NV7cf/Screenshot-2025-10-20-at-10-48-14.png
  HTML https://i.postimg.cc/SxmP0mGz/Screenshot-2025-10-20-at-10-48-45.png
       #Post#: 94778--------------------------------------------------
       Re: Horizon - Failure to pay for full duration of stay
   DIR By: bigred247
       Date: October 20, 2025, 5:56 am
       ---------------------------------------------------------
       [member=26]b789[/member],
       I've updated my draft to include Ground 4 based on your point
       about Proof of Valid Authority/Landowner. And made some
       modifications based on some more research on the money saving
       expert forum - Please let me know if these are rubbish/worth a
       punt?
       --- Quote ---
       >
       > As registered keeper, I challenge this PCN on the following
       grounds:
       >
       > Ground 1: No Charges Displayed at Entrance
       > Photographic evidence (Exhibits A-D) proves:
       >
       > - Entrance shows "ASDA Welcome" with no charges (Exhibit B)
       > - Street sign shows ASDA branding, no tariff (Exhibit A)
       > - Charges only visible inside car park after entry (Exhibits
       C-D)
       >
       > This violates BPA Code Section 19.3 requiring signs to "take
       into account the expected speed and direction of travel of
       vehicles approaching the entrance." The operator actively
       invited drivers to enter while concealing a complex charging
       structure (different rates by duration, Saturday rates, Sunday
       free, Asda discounts).
       >
       > Drivers cannot be expected to research website tariffs before
       entering - adequate notice must be given at the site. By the
       time charges are visible inside, the driver has already
       committed to entering and would be in "breach" if attempting to
       leave.
       >
       > No valid contract formed.
       >
       > Ground 2: Operator Cannot Prove Actual Notice
       > Vine v Waltham Forest [2000] requires operators prove the
       driver actually saw and understood terms. ParkingEye v Beavis
       [2015] UKSC 67 upheld £85 only because of 20 large, prominent
       noticeboards throughout the site with charges in "largest font
       size."
       >
       > Mercury fails this standard:
       >
       > - no charges at entrance decision point;
       > - signs inside car park too late.
       >
       > I require strict proof that:
       >
       > - Charges were visible at entrance before entry commitment
       > - Signage met Beavis standard
       > - Photographic evidence from entrance on 16th August 2025
       >
       >
       > Ground 3: PoFA Schedule 4 Not Satisfied
       > Protection of Freedoms Act 2012 Schedule 4 Paragraph 5
       requires "the driver must have been given adequate notice of the
       parking charges" - a mandatory condition. Paragraph 4(2): keeper
       liability "applies only if conditions in paragraphs 5, 6, 11 and
       12 are met."
       >
       > Exhibits A-D prove Paragraph 5 not satisfied. Former POPLA
       Lead Adjudicator: "If not complied with then keeper liability
       does not generally pass."
       >
       > The operator cannot pursue the keeper regardless of Notice to
       Keeper compliance.
       >
       > Ground 4: No Proof of Valid Authority
       > The operator must prove valid authority to issue PCNs. The
       prominent ASDA branding creates ambiguity about landowner
       identity.
       >
       > I require strict proof of:
       >
       > - Valid contract with landowner (Mercury Shopping Centre/Asda)
       in force on 16th August 2025
       > - Authorization to issue PCNs in Horizon Parking's own name
       > - Confirmation of landowner identity
       >
       > Without proof of authority, the operator has no standing to
       pursue this charge.
       >
       >
       > Conclusion
       > This PCN should be cancelled because:
       >
       > - No adequate notice - "ASDA Welcome" invitation concealed
       charges until after entry
       > - Operator cannot prove driver saw/understood terms
       (Vine/Beavis standard not met)
       > - PoFA Schedule 4 Paragraph 5 not satisfied - keeper liability
       cannot exist
       > - No proof of valid authority from landowner
       >
       > The photographic evidence proves drivers entering this car
       park see only invitational ASDA-branded signage with no
       indication of charges.
       >
       > I respectfully request this appeal be allowed.
       >
       --- End Quote ---
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