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       #Post#: 93224--------------------------------------------------
       Re: UKCPS Parking charge - no stopping  - Leeds city station
       By: DWMB2 Date: October 7, 2025, 7:28 am
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       In this case I'd be more tempted to lead with, and make more of
       a point of, #4
       UKCPS have openly said they are not using PoFA, it even says
       that explicitly on the Notice. We've seen a few successful
       appeals at the IAS recently on similar points, so I'd say it's
       potentially worth making the point a bit more explicitly.
       #Post#: 93228--------------------------------------------------
       Re: UKCPS Parking charge - no stopping  - Leeds city station
       By: Kbr1 Date: October 7, 2025, 7:41 am
       ---------------------------------------------------------
       Thank you for your help, I'll proceed to make an IAS appeal!
       #Post#: 95522--------------------------------------------------
       Re: UKCPS Parking charge - no stopping  - Leeds city station
       By: Kbr1 Date: October 25, 2025, 8:15 am
       ---------------------------------------------------------
       Hello, I've made an appeal to the IAS and I've received a
       response
       The operator made their Prima Facie Case on 22/10/2025 11:18:03.
       The operator reported that...
       The appellant was the keeper.
       The Notice to Keeper (Non-ANPR) was sent on 15/09/2025.
       The ticket was issued on 31/08/2025.
       The charge is based in Contract.
       The operator made the following comments...
       The Parking Charge Notice was issued as a result of the vehicle
       stopping in an area where stopping is clearly prohibited at all
       times. The site in question, located at Leeds City Station, is
       under active enforcement due to safety and congestion concerns.
       This location is designated as a strict “No Stopping” zone, and
       enforcement is permitted in accordance with the IPC Code of
       Practice, which recognises that such restrictions may be
       necessary in areas with high pedestrian footfall or complex
       traffic flow.
       The signage on site meets the requirements set out in the IPC
       Code of Practice in terms of visibility, positioning, and
       clarity of terms. The photographic evidence provided by the
       operator shows that multiple warning signs are placed at
       prominent positions throughout the location, clearly stating
       that stopping is not permitted and that a Parking Charge Notice
       will be issued to vehicles found to be in breach. The signs are
       legible, in plain language, and displayed in a manner that would
       be visible to a reasonable driver. Signage does not need to be
       read in full for a contract to be formed; it is sufficient that
       the signs are prominent and convey the essential terms clearly.
       This is consistent with the findings in ParkingEye v Beavis
       [2015] UKSC 67, which established that clear signage displaying
       a contractual term is enforceable, even in the context of
       private land.
       Your assertion that the operator must provide strict proof of
       signage location, calibration records, and a detailed landowner
       contract is noted. However, the IPC appeals process is designed
       to assess whether, on the balance of probabilities, a
       contravention occurred and the Parking Charge Notice was issued
       correctly. Operators who are members of the IPC are required to
       hold and maintain valid landowner authority and to adhere to the
       obligations set out in Section 14 of the Code of Practice. The
       operator has confirmed, as part of their accreditation, that
       such authority is in place and that enforcement at this location
       is properly authorised. The Appeals Service is satisfied that
       the operator has the legal standing to issue Parking Charge
       Notices and pursue them in its own name.
       In relation to the duration of the stop, it is important to
       clarify that grace periods or consideration periods do not apply
       in no-stopping zones. These are specifically excluded under the
       IPC Code of Practice for locations where stopping is never
       permitted. Whether the stop lasted seconds or minutes is not
       relevant—the act of stopping in breach of clearly displayed
       signage is itself sufficient to constitute a contravention of
       the advertised terms.
       If the operator is not seeking to rely on the Protection of
       Freedoms Act 2012 to establish keeper liability, compliance with
       the timelines and wording in Schedule 4 is not necessary. The
       operator may instead pursue the keeper on the balance of
       probabilities if no driver is named, a position that has been
       upheld in numerous appeal cases. If PoFA is being relied upon,
       then the timing of the Notice to Keeper and its content would be
       assessed for compliance. In this case, there is no indication
       that PoFA is the basis for liability.
       I need to respond by the 29/10/2025 but I'm unsure if I need to
       submit a response or refer case to arbitration
       Thank you
       #Post#: 95527--------------------------------------------------
       Re: UKCPS Parking charge - no stopping  - Leeds city station
       By: jfollows Date: October 25, 2025, 9:06 am
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       [quote]The operator may instead pursue the keeper on the balance
       of probabilities if no driver is named, a position that has been
       upheld in numerous appeal cases[/quote]
       is a lie.
       [quote] 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]
       Be happy that your appeal cost UKCPS something like £23.
       You will now get useless letters from debt collectors, which you
       should ignore.
       Come back here when you receive a Letter of Claim.
       This is a well-trodden path which will result in you paying £0.
       In the meantime, UKCPS will try and frighten you into paying
       them.
       #Post#: 95567--------------------------------------------------
       Re: UKCPS Parking charge - no stopping  - Leeds city station
       By: b789 Date: October 25, 2025, 2:17 pm
       ---------------------------------------------------------
       Typical IAS kangaroo court, male bovine excrement. I advise you
       to respond with the following, verbatim:
       [quote]If the IAS assessor is legally trained (questionable),
       they would know liability is the threshold issue: this is
       railway land governed by byelaws, not “relevant land” under
       PoFA, the driver is unidentified, and the operator expressly
       disavows PoFA, therefore there is no lawful route to hold the
       Keeper liable and the enquiry ends there.
       Any attempt to conjure liability by asserting that the Keeper
       was “probably” the driver is a legal fiction flatly contrary to
       the very purpose of PoFA (which was enacted to remove such
       inferences), repeatedly rejected in persuasive authorities
       including VCS v Edward (2023) and the consistent line of county
       court appeal decisions disapproving Elliott v Loake/AJH Films
       misuse, and it would be irrational and perverse to proceed to
       signage or “no stopping” merits when the claimant has no cause
       of action against the Keeper at all.[/quote]
       If it were myself responding, I would go even further and use
       this instead, such is my contempt for the IAS:
       [quote]If the anonymous IAS “assessor” were genuinely legally
       trained, never mind the solicitor or barrister they pretend to
       be, they would recognise that liability must first exist before
       any alleged contractual breach can even be discussed. The
       operator admits PoFA does not apply, as this is alleged
       contravention was at a railway station and therefore not
       relevant land.
       Without PoFA and without an identified driver, there is simply
       no lawful route to Keeper liability. To fabricate liability “on
       the balance of probabilities” is not only contrary to statute
       but flies in the face of persuasive case law such as VCS v
       Edward (2023), where the court confirmed that no such
       presumption exists. The whole point of PoFA was to prevent
       precisely this kind of inference.
       To proceed on that basis would expose the IAS’s assessment
       process as legally incompetent at best, and institutionally
       dishonest at worst — a parody of legal reasoning conducted by
       anonymous baristas masquerading as barristers.[/quote]
       Your choice.
       #Post#: 95589--------------------------------------------------
       Re: UKCPS Parking charge - no stopping  - Leeds city station
       By: Kbr1 Date: October 25, 2025, 8:32 pm
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       Perfect I'll submit and I'll come back when I get the letters
       from the collectors!
       Thanks everyone
       #Post#: 95628--------------------------------------------------
       Re: UKCPS Parking charge - no stopping  - Leeds city station
       By: b789 Date: October 26, 2025, 10:16 am
       ---------------------------------------------------------
       Please, you do not need to show us or tell us about the useless
       debt recovery letters. If the IAS appeal is rejected, just show
       us the rejection reason.
       Ignore the debt collector letters. Shred them and use as hamster
       bedding for all anyone cares. Come back if/when you receive a
       Letter of Claim (LoC).
       #Post#: 97200--------------------------------------------------
       Re: UKCPS Parking charge - no stopping  - Leeds city station
       By: Imogen Date: November 7, 2025, 5:51 am
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       Removed.
       #Post#: 97201--------------------------------------------------
       Re: UKCPS Parking charge - no stopping  - Leeds city station
       By: DWMB2 Date: November 7, 2025, 5:54 am
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       If you would like advice on your own case, please start your own
       thread.
       #Post#: 97202--------------------------------------------------
       Re: UKCPS Parking charge - no stopping  - Leeds city station
       By: jfollows Date: November 7, 2025, 5:55 am
       ---------------------------------------------------------
  HTML https://www.ftla.uk/announcements/house-rules/
       [quote]We operate some "house rules" on the site.
       1. We operate a "one case, one thread" rule. This means that you
       should keep any posts relating to one case (one incident of
       speeding, one PCN, etc) to a single thread. Do not start
       multiple topics on the same case.[/quote]
       Please start your own thread.
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