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       #Post#: 94405--------------------------------------------------
       McDonald's Gatwick, MET PCN, Failure to validate ticket
   DIR By: SatnavSam
       Date: October 16, 2025, 3:35 pm
       ---------------------------------------------------------
       I am the RK of the vehicle and have received this PCN for
       failure to validate the parking ticket.
       The driver did not see any information about how to validate the
       ticket, nor did the staff in the restaurant mention it.
       Any information on the best way to proceed would be gratefully
       received
       #Post#: 94406--------------------------------------------------
       Re: McDonald's Gatwick, MET PCN, Failure to validate ticket
   DIR By: SatnavSam
       Date: October 16, 2025, 3:39 pm
       ---------------------------------------------------------
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       #Post#: 94422--------------------------------------------------
       Re: McDonald's Gatwick, MET PCN, Failure to validate ticket
   DIR By: b789
       Date: October 16, 2025, 5:26 pm
       ---------------------------------------------------------
       You appeal to MET with the following and then come back when
       they reject that so you can finally get it quashed at POPLA:
       --- Quote ---
       > I am the registered keeper. MET cannot hold a registered
       keeper liable for any alleged contravention on land that is
       under statutory control. As a matter of fact and law, MET will
       be well aware that they cannot use the PoFA provisions because
       Gatwick Airport is not 'relevant land'.
       >
       > If Gatwick Airport wanted to hold owners or keepers liable
       under Airport 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 MET is not the
       Airport owner and your 'parking charge' is not and never
       attempts to be a penalty. It is created for MET’s own profit (as
       opposed to a bylaws penalty that goes to the public purse) and
       MET 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.
       MET have no hope at POPLA, so you are urged to save us both a
       complete waste of time and cancel the PCN.
       --- End Quote ---
       You DO NOT identify the driver. They have no idea who the driver
       is unless you blab it to them, inadvertently or otherwise. You
       only ever refer to the driver in the third person. No "I did
       this or that",only "the driver did this or that".
       #Post#: 95976--------------------------------------------------
       Re: McDonald's Gatwick, MET PCN, Failure to validate ticket
   DIR By: SatnavSam
       Date: October 28, 2025, 2:30 pm
       ---------------------------------------------------------
       Thank you.
       Sorry for not replying earlier. I thought I had posted, but
       obviously not.
       Appeal sent as above. Awaiting response. Will post back when it
       arrives.
       #Post#: 96088--------------------------------------------------
       Re: McDonald's Gatwick, MET PCN, Failure to validate ticket
   DIR By: SatnavSam
       Date: October 29, 2025, 12:12 pm
       ---------------------------------------------------------
       Just had response from MET
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       #Post#: 96093--------------------------------------------------
       Re: McDonald's Gatwick, MET PCN, Failure to validate ticket
   DIR By: b789
       Date: October 29, 2025, 12:59 pm
       ---------------------------------------------------------
       Respond with the following:
       --- Quote ---
       > Subject: Parking Charge Notice [ref] – Misrepresentation of
       Keeper Liability / Breach of KADOE Contract
       >
       > Dear MET Parking Services,
       >
       > Thank you for your letter dated 29/10/2025. Your request for a
       McDonald’s receipt is irrelevant, as before any alleged
       contravention can be pursued, you must first establish that the
       registered keeper was the driver. You cannot.
       >
       > Your continued assertion that the registered keeper may be
       pursued under the Protection of Freedoms Act 2012 (PoFA) is
       entirely without legal basis. The site in question, McDonald’s
       Gatwick, is located within the statutory boundary of Gatwick
       Airport and is subject to the Gatwick Airport Byelaws. Land
       subject to statutory control is not “relevant land” for the
       purposes of PoFA Schedule 4. Consequently, you cannot transfer
       liability from the driver to the keeper, and your suggestion
       that you can do so is false and misleading.
       >
       > For the avoidance of doubt, the Private Parking Single Code of
       Practice (Version 1.1, 17 February 2025) at section 8.1.1(d)
       expressly prohibits an operator from stating or implying that
       the keeper is liable under PoFA where such liability cannot
       apply. Your letter of 29/10/2025 and the NtK itself, constitute
       a clear breach of that requirement and of your DVLA KADOE
       contract, which mandates full compliance with the Code.
       >
       > Accordingly, you are now formally notified that this breach
       will be reported to the DVLA’s Data Sharing Investigations Team
       for misuse of my keeper data. A full copy of your NtK and letter
       will be provided as evidence.
       >
       > You are required to either:
       > [indent]• Cancel this charge immediately; or
       > • Issue a POPLA verification code without delay.[/indent]
       >
       > Any further attempt to pursue the keeper on the basis of PoFA
       liability will be retained as further evidence of non-compliance
       and will be submitted to both the DVLA and the Information
       Commissioner’s Office (ICO).
       >
       > Yours faithfully,
       >
       > [Name]
       > Registered Keeper
       --- End Quote ---
       #Post#: 96094--------------------------------------------------
       Re: McDonald's Gatwick, MET PCN, Failure to validate ticket
   DIR By: SatnavSam
       Date: October 29, 2025, 1:02 pm
       ---------------------------------------------------------
       Thanks very much, b789. Will do.
       Edit: reply sent by email, cc'd to me.
       #Post#: 96239--------------------------------------------------
       Re: McDonald's Gatwick, MET PCN, Failure to validate ticket
   DIR By: SatnavSam
       Date: October 30, 2025, 3:19 pm
       ---------------------------------------------------------
       Got a quick refusal with POPLA code.
  HTML https://i.postimg.cc/FdZcf8Gz/appeal-reply-33183982edited.png
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       #Post#: 96251--------------------------------------------------
       Re: McDonald's Gatwick, MET PCN, Failure to validate ticket
   DIR By: b789
       Date: October 30, 2025, 4:54 pm
       ---------------------------------------------------------
       A single point appeal to POPLA is all that this requires.
       Irrespective of whatever alleged contravention took place, they
       can only pursue the driver. If the driver has not been
       identified, they cannot chase the Keeper.
       Whilst they may squeal on about the fact that the location is
       "private land" that does not negate the fact that the location
       is covered by airport byes and is therefore not relevant and for
       the purposes of PoFA. You can attach either or both of the maps
       below that shows the location of McDonalds and the airport
       byelaws boundary.
  HTML https://i.ibb.co/PGKqg3Xn/LGW-gatwick-boundary.jpg
  HTML https://i.ibb.co/Z1Lxytm7/McD-LGW.jpg
       --- Quote ---
       > Ground: Keeper liability cannot arise because the site is not
       “relevant land” under Schedule 4 of the Protection of Freedoms
       Act 2012 (PoFA). Therefore, irrespective of any alleged
       contravention by the driver, the appeal must be allowed.
       >
       > The operator is pursuing the Registered Keeper and the driver
       has not been identified. PoFA can only transfer liability from a
       driver to a keeper where the land is “relevant land”. Land
       subject to statutory control (including airport byelaws) is
       excluded from PoFA’s definition of relevant land. McDonald’s
       Gatwick lies within the Gatwick Airport byelaws boundary, so the
       site is not relevant land and keeper liability cannot arise. A
       boundary map is provided showing the location within the airport
       perimeter.
       >
       > MET’s claim that because the land is “private” it must be
       “relevant” is legally illiterate. Ownership or title
       (private/public) is immaterial. Relevance under PoFA is
       determined by location and status: if the land sits within an
       airport byelaws boundary, it is under statutory control and
       cannot as a matter of law be “relevant land”, however much the
       operator wishes it were.
       >
       > By asserting keeper liability on such land, MET has made a
       prohibited and misleading statement contrary to the Private
       Parking Single Code of Practice section 8.1.1(d), which states:
       “The parking operator must not serve a notice or include
       material on its website which in its design and/or language: d)
       state the keeper is liable under the Protection of Freedoms Act
       2012 where they cannot be held liable.”
       >
       > Strict proof: MET is put to strict proof that the location
       does not lie within the Gatwick Airport byelaws boundary. Mere
       assertion is insufficient. The operator must produce
       contemporaneous, authoritative evidence (for example, an
       official boundary plan from Gatwick Airport Limited or other
       primary source) demonstrating that the site is outside the
       byelaws area and not subject to statutory control. In the
       absence of such proof, POPLA must find that PoFA does not apply
       and that keeper liability cannot arise.
       >
       > Conclusion: Because the site is within the airport byelaws
       boundary and therefore not relevant land, POPLA must first
       conclude that the keeper cannot be liable. Once that is
       established, all questions about signage, validation procedures,
       or alleged driver conduct are irrelevant. The appeal must be
       allowed and the charge cancelled.
       --- End Quote ---
       #Post#: 96302--------------------------------------------------
       Re: McDonald's Gatwick, MET PCN, Failure to validate ticket
   DIR By: SatnavSam
       Date: October 31, 2025, 7:00 am
       ---------------------------------------------------------
       Appeal submitted.
       Thanks, b789.
       Now we await POPLA.
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