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#Post#: 90621--------------------------------------------------
UKCPS Parking charge - no stopping - Leeds city station
By: Kbr1 Date: September 19, 2025, 6:15 am
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Hi all,
I, the registered keeper has received a Notice to Keeper (NTK)
on the 19th September 2025 for an alleged contravention
described as “stopping in a restricted area” at Leeds City
Station.
According to the NTK, the vehicle stopped for an unspecified
amount of minutes to allow a passenger to be dropped off. The
driver did not see any new signage or road markings indicating
that stopping was prohibited, and this location has previously
been used for drop-offs without issue.
The NTK (image attached) arrived recently. The registered keeper
is currently dealing with redundancy, so any advice on next
steps would be very welcome.
Thanks in advance for any guidance.
HTML https://imgur.com/a/jD6NwFr
[img]
HTML https://imgur.com/a/jD6NwFr[/img]
#Post#: 90623--------------------------------------------------
Re: Parking charge - no stopping - Leeds city station
By: b789 Date: September 19, 2025, 6:22 am
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Easy one to deal with… as long as the unknown drivers identity
is not revealed. 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.
Use the following as your appeal:
[quote]I am the registered keeper. UKCPS cannot hold a
registered keeper liable for any alleged contravention on land
that is under statutory control. As a matter of fact and law,
UKCPS will be well aware that they cannot use the PoFA
provisions because Leeds City Stattion is not 'relevant land'.
If the landowner wanted to hold owners or keepers liable under
Railway Bylaws, that would be within the landowner's gift and
another matter entirely. However, not only is that not pleaded,
it is also not legally possible because UKCPS is not the station
owner and your 'parking charge' is not and never attempts to be
a penalty. It is created for UKCPS’s own profit (as opposed to a
bylaws penalty that goes to the public purse) and UKCPS 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.
UKCPS have no hope should you be so stupid as to litigate, so
you are urged to save us both a complete waste of time and
cancel the PCN.[/quote]
#Post#: 90624--------------------------------------------------
Re: Parking charge - no stopping - Leeds city station
By: jfollows Date: September 19, 2025, 6:22 am
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The PCN is a load of tosh.
The PCN is issued too late to transfer liability from the
unknown driver to you as registered keeper.
The PCN does not specify a period of parking.
The PCN states a lie that you can be pursued under the
assumption that you were the driver.
PLUS it’s not “relevant land”!
#Post#: 90625--------------------------------------------------
Re: IPC Parking charge - no stopping - Leeds city station
By: b789 Date: September 19, 2025, 6:33 am
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They obviously know that they cannot rely on PoFA as the
location is not relevant land as it is under railway byelaws
statute. Even their NtK says very clearly that it is a "Notice
to Keeper (Postal - Non PoFA) Issued on private land". However
they then sate the following within the NtK:
[quote]Please be warned: that if, after the period of 28 days
beginning with the day after that on which the Notice is given
(i) the amount of the unpaid Parking Charge specified in this
Notice has not been paid in full, and (i) we do not know both
the name of the driver and a current address for service for the
driver, we may recover from you, the keeper, on the
[b]assumption that you were the driver[/b], so much of that
Parking Charge as remains unpaid.[/quote]
In law, there can be no "assumption" or inference that the
Keeper was the driver. The burden of proof is on the claimant to
prove that the Keeper was the driver and the only way they would
know that, is if the Keeper blabs it to them, inadvertently or
otherwise. The persuasive appellate case of VCS v Edward (2023)
HTML https://www.dropbox.com/scl/fi/zra61px7l3if53o3bp9c4/VCS-v-EDWARD-Transcript.pdf?rlkey=bv4bba389nau5qpfglqkpjq5l&st=ca6cf7x8&dl=0<br
/>put that one to bed.
#Post#: 90636--------------------------------------------------
Re: UKCPS Parking charge - no stopping - Leeds city station
By: Kbr1 Date: September 19, 2025, 7:21 am
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Thank you, I will appeal with that template
#Post#: 91232--------------------------------------------------
Re: UKCPS Parking charge - no stopping - Leeds city station
By: Leedsgirl94 Date: September 24, 2025, 5:35 am
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[quote author=Kbr1 link=topic=8107.msg90636#msg90636
date=1758284481]
Thank you, I will appeal with that template
[/quote]
Hey, I'm in the same situation- did your appeal work?
#Post#: 91289--------------------------------------------------
Re: UKCPS Parking charge - no stopping - Leeds city station
By: b789 Date: September 24, 2025, 8:46 am
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Doesn't matter whether it "works or not". You are dealing with a
firm of ex-clampers who will do anything to extort money from
you. They are likely to reject any initial appeal, just because
they can and in the hope you are low-hanging fruit on the
gullible tree who can be intimidated into paying out of
ignorance and fear.
They are IPC members which means any secondary appeal to the IAS
is not likely o succeed as the IAS is not "independent" at all.
Ultimately, they are likely to issue a county court claim as a
last ditch effort to try and intimidate you int paying. However,
any claim, defended with our assistance and template will end up
being either struck out or discontinued. No doubt about it.
All you have to do is refuse to identify the driver.
#Post#: 92341--------------------------------------------------
Re: UKCPS Parking charge - no stopping - Leeds city station
By: billybob47 Date: October 1, 2025, 8:43 am
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This seems to be a relatively new thing, as all the threads I've
searched for come back to relatively the same dates.
[br]I've also gotten one of these and just appealed using the
boilerplate, so I'll let you guys know the result.
[br][sup](didn't make a new thread as I'm not really asking for
help)[/sup]
#Post#: 93213--------------------------------------------------
Re: UKCPS Parking charge - no stopping - Leeds city station
By: Kbr1 Date: October 7, 2025, 6:29 am
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Hi just an update, I've received a response from UKCPS.
They've denied my initial appeal, and I'm unsure what steps
forward I should take. Should I continue to appeal or ignore
this?
"Thank you for your appeal submitted on 19th September 2025.
After reviewing your comments, and carefully
considering the evidence collected at the time the Parking
Charge was issued, we regret to inform you that your
appeal has been unsuccessful. The reasons for our decision are
detailed below:
The area where the vehicle stopped is designated as private land
where parking, stopping, or waiting is strictly
prohibited at all times.
At the time of the event, the vehicle was parked, stopped or
waiting in this area, and as a result, the driver
contractually agrees to pay a parking charge. As you have not
provided driver details, we are unable to transfer
the liability. The circumstances outlined in your appeal do not
negate you from the terms and conditions in place
on the site. As the vehicle has stopped in a no stopping area,
the terms and conditions have been breached and
therefore the PCN has been issued correctly.
Attached, you will find photographic evidence showing the
vehicle parked at the location mentioned above.
We have extended the opportunity for you to pay the reduced
amount of, Ł60.00, until 23/10/2025, after this date,
the full amount of Ł100.00 will be due.
Regards,
Appeals Team"
#Post#: 93220--------------------------------------------------
Re: UKCPS Parking charge - no stopping - Leeds city station
By: b789 Date: October 7, 2025, 6:47 am
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Totally as expected. However, they are utter morons and will
hope that you are low-hanging fruit on the gullible tree who can
be intimidated into paying up out of ignorance and fear.
You should send the following as your IAS appeal. Not much
chance of that being successful either, but worth a try and it
will cost them to challenges it unless they concede.
[quote]I am the registered keeper of the vehicle. I deny any
liability for this parking charge and appeal in full.
The parking operator bears the burden of proof. It must
establish that a contravention occurred, that a valid contract
was formed between the operator and the driver, and that it has
lawful authority to operate and issue Parking Charge Notices
(PCNs) in its own name. I therefore require the operator to
provide the following:
[indent]1. Strict proof of clear, prominent, and adequate
signage that was in place on the date in question, at the exact
location of the alleged contravention. This must include a
detailed site plan showing the placement of each sign and
legible images of the signs in situ. The operator must
demonstrate that signage was visible, legible, and compliant
with the IPC Code of Practice that was valid at the time of the
alleged contravention, including requirements relating to font
size, positioning, and the communication of key terms.
2. Strict proof of a valid, contemporaneous contract or lease
flowing from the landowner that authorises the operator to
manage parking, issue PCNs, and pursue legal action in its own
name. I refer the operator and the IAS assessor to Section 14 of
the PPSCoP (Relationship with Landowner), which clearly sets out
mandatory minimum requirements that must be evidenced before any
parking charge may be issued on controlled land.
In particular, Section 14.1(a)–(j) requires the operator to have
in place written confirmation from the landowner which includes:
[indent]• the identity of the landowner,
• a boundary map of the land to be managed,
• applicable byelaws,
• the duration and scope of authority granted,
• detailed parking terms and conditions including any specific
permissions or exemptions,
• the means of issuing PCNs,
• responsibility for obtaining planning and advertising
consents,
• and the operator’s obligations and appeal procedure under the
Code.[/indent]
These requirements are not optional. They are a condition
precedent to issuing a PCN and bringing any associated action.
Accordingly, I put the operator to strict proof of compliance
with the entirety of Section 14 of the PPSCoP. Any document that
contains redactions must not obscure the above conditions. The
document must also be dated and signed by identifiable persons,
with evidence of their authority to act on behalf of the parties
to the agreement. The operator must provide an agreement showing
clear authorisation from the landowner for this specific site.
3. Strict proof that the enforcement mechanism (e.g. ANPR or
manual patrol) is reliable, synchronised, maintained, and
calibrated regularly. The operator must prove the vehicle was
present for the full duration alleged and not simply momentarily
on site, potentially within a permitted consideration or grace
period as defined by the PPSCoP.
4. Strict proof that the Notice to Keeper complies with the
Protection of Freedoms Act 2012 (PoFA), if the operator is
attempting to rely on keeper liability. Any failure to comply
with the mandatory wording or timelines in Schedule 4 of PoFA
renders keeper liability unenforceable.
5. Strict proof that the NtK was posted in time for it to have
been given within the relevant period. The PPSCoP section
8.1.2(d) Note 2 requires that the operator must retain a record
of the date of posting of a notice, not simply of that notice
having been generated (e.g. the date that any third-party Mail
Consolidator actually put it in the postal system.)
6. The IAS claims that its assessors are “qualified solicitors
or barristers.” Yet there is no way to verify this. Decisions
are unsigned, anonymised, and unpublished. There is no
transparency, no register of assessors, and no way for a
motorist to assess the legal credibility of the individual
supposedly adjudicating their appeal. If the person reading this
really is legally qualified, they will know that without strict
proof of landowner authority (VCS v HMRC [2013] EWCA Civ 186),
no claim can succeed. They will also know that clear and
prominent signage is a prerequisite for contract formation
(ParkingEye v Beavis [2015] UKSC 67), and that keeper liability
under PoFA is only available where strict statutory conditions
are met.[/indent]
If the assessor chooses to overlook these legal requirements and
accept vague assertions or redacted documents from the operator,
that will speak for itself—and lend further weight to the
growing concern that this appeals service is neither independent
nor genuinely legally qualified.
In short, I dispute this charge in its entirety and require full
evidence of compliance with the law, industry codes of practice,
and basic contractual principles.[/quote]
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