URI:
   DIR Return Create A Forum - Home
       ---------------------------------------------------------
       FreeTrafficLegalAdvice
  HTML https://ftla.createaforum.com
       ---------------------------------------------------------
       *****************************************************
   DIR Return to: Private parking tickets
       *****************************************************
       #Post#: 94587--------------------------------------------------
       Group Nexus - Crayford Tower Retail Park PCN
       By: BrahmaCool Date: October 18, 2025, 5:53 am
       ---------------------------------------------------------
       Hello,
       Got this NTK sent by Group Nexus -
  HTML https://ibb.co/mCSc36Sg
       Some Images of the entrance and then parts of the car park -
       don't think signage is that obvious
  HTML https://ibb.co/0j90HVJ9
  HTML https://ibb.co/v4Rv71Cm
  HTML https://ibb.co/RpwMxkZ3
  HTML https://ibb.co/GvSD0S2P
  HTML https://ibb.co/rKgxPvhf
       I appealed to Group Nexus as Keeper but appeal was refused with
       following text -
       Dear Sir/Madam,
       Thank you for your correspondence relating to your Parking
       Charge.
       The Charge was issued and the signage is displayed in compliance
       with The Private Parking Sector Single Code of Practice and all
       relevant laws and regulations.
       Clear signs at the entrance of this site and throughout inform
       drivers of the 3 hours maximum stay (0500-0000) 20 minutes
       maximum stay (0000-0500) , and it is not possible to access any
       part of the premises without passing multiple signs. Your
       representations are not considered a mitigating circumstance for
       appeal.
       We confirm the Charge was issued under Schedule 4 of the
       Protection of Freedoms Act 2012. As full driver details have not
       been provided, we are holding the registered keeper of the
       vehicle liable.
       In light of this, on this occasion, your representations have
       been carefully considered and rejected.
       We can confirm that we will hold the Charge at the current rate
       of £60 for a further 14 days from the date of this
       correspondence. If no payment is received within this period,
       and no further appeal to POPLA is made, the Charge will escalate
       and further costs may be added. Should you appeal to POPLA, and
       your appeal is rejected for any reason, you will also lose your
       right to pay at the reduced rate.
       Please find below the payment options: ...
       Do I have any chance at POPLA ? what points do I raise please?
       #Post#: 94618--------------------------------------------------
       Re: Group Nexus - Crayford Tower Retail Park PCN
       By: Oldstoat Date: October 18, 2025, 8:32 am
       ---------------------------------------------------------
       Looking at google maps the sign you would have seen is on a
       roundabout, so how can that be classed as adequate, as it could
       be blocked by a moving vehicle and you would be looking at
       vehicles coming from your right.  Secondly it does not state any
       penalty for exceeding the three hour max stay.  Appeal points
       for POPLA should include inadequacy and positioning of signage.
       Others will assist with POFA compliance
       #Post#: 94636--------------------------------------------------
       Re: Group Nexus - Crayford Tower Retail Park PCN
       By: b789 Date: October 18, 2025, 11:05 am
       ---------------------------------------------------------
       You appeal to POPLA as the Keeper only and your points of appeal
       are:
       1. No Keeper liability as their Notice to Keeper (NtK) is not
       fully compliant with PoFA.
       2. Driver not identified.
       3. Failure of the BPA CoP
  HTML https://www.britishparking.co.uk/write/Documents/AOS/NEW%20Redesigned%20Documents/Version91.2.2024.pdf<br
       />because there is no Entrance sign informing drivers that they
       are entering private land and that they should seek out tens and
       conditions signs inside the car park.
       4. Insufficient or no terms signs visible within the car park.
       5. No evidence of standing to operate or issue PCNs at this
       location.
       Because a separate company now exists called “GroupNexus Ltd”,
       an NtK that is front-branded “GroupNexus”, directs payment to a
       “groupnexus.co.uk” site, and only buries “CP Plus Ltd t/a
       GroupNexus” in the footer creates ambiguity as to the
       contracting party. When two distinct legal persons could
       plausibly be the creditor (CP Plus Ltd vs GroupNexus Ltd), the
       NtK fails to “identify the creditor” with certainty. That is a
       clean PoFA 9(2)(h) point.
       If they want keeper liability, they must make it crystal-clear
       on the face of the NtK who the creditor is (name + number), not
       leave the recipient to infer it from a trading-as
       line—especially where a different company with the same trading
       style exists.
       #Post#: 102829--------------------------------------------------
       Re: Group Nexus - Crayford Tower Retail Park PCN
       By: BrahmaCool Date: December 17, 2025, 5:38 am
       ---------------------------------------------------------
       POPLA has refused my appeal !! What do I do next pls?
       POPLA Response =>
       When assessing an appeal POPLA considers if the operator has
       issued the parking charge notice correctly and if the driver has
       complied with the terms and conditions for the use of the car
       park displayed on the signs located within the car park.
       Therefore, the driver is responsible for seeking out these
       signs, reviewing the displayed terms and conditions and
       complying with these. The signs on this site confirm free
       parking is permitted for a maximum stay of three hours and
       failure to comply will result in the issue of a £100 PCN. The
       operator has provided photographic evidence the vehicle remained
       on site for three hours and 41 minutes. The Private Parking
       Sector Single Code of Practice (The Code) sets the standards its
       parking operators need to comply with. This sector Code of
       Practice has been jointly created by the British Parking
       Association (BPA) and the International Parking Community (IPC).
       It is largely based on the Government’s Private Parking Code of
       Practice, which was published in February 2022, and subsequently
       withdrawn in June 2022. The new Code came into force on the 1
       October 2024 and applies to all PCNs issued after this date. The
       new coded supersedes all previous versions of the BPA code of
       practice. The appellant has not admitted to being the driver. I
       will therefore be considering their responsibility as keeper of
       the vehicle. In order for the keeper to be liable for the
       parking charge, the operator has to follow the strict
       requirements of Schedule 4 of POFA. Having reviewed the
       evidence, I consider that there looks to be a contract between
       the driver and the parking operator, and the appellant has not
       provided a current name and address for service for the driver.
       The notice also identifies the creditor. Further, on reviewing
       the Notice to Keeper provided by both parties, I am satisfied
       this complies with the relevant provisions and therefore, I am
       satisfied that the operator has met POFA to transfer liability.
       Section 18.2 of the BPA code of practice no longer applies. It
       is worth noting that section 18.2 has not applied to signage
       since version 7 2018 of the BPA code of practice. Section 3.1.1
       of the Single Code of Practice states that there must be an
       entrance sign displayed and maintained at the entrance to the
       site, to inform drivers whether parking is permitted subject to
       terms and conditions or prohibited. Section 3.1.2 of the Code
       contains the principles the entrance sign must display,
       including whether public parking is available and if a payment
       is required. Its design must also comply with the standard
       format as described in Annex A. The entrance sign must take into
       account the speed of vehicles approaching the car park. Section
       3.1.3 of the Single Code of Practice contains the requirements
       for signs displaying the terms and conditions. The signs must be
       placed throughout the site, so that drivers have the opportunity
       to read them when parking or leaving their vehicle. The terms
       and conditions must be clear and unambiguous, using a font and
       contrast that is be conspicuous and legible. The operator has
       provided multiple images of the entrance sign and also signage
       within the car park and after reviewing these, I am satisfied
       that there are plenty of signs located within the car park and
       at the entrance and that these signs meet the requirements of
       the Single Code of Practice. I recognise the appellant has
       provided two photographs however these images are not time or
       date stamped. As such, I am unable to determine when these were
       taken. As such, I am not satisfied these two images are
       sufficient to cast doubt on the evidence provided by the
       operator. Section 7 of the BPA code of practice is no longer
       applicable. Section 14.1 of the Single Code of Practice states
       that where controlled land is being managed on behalf of a
       landowner, written confirmation must be obtained before a
       parking charge can be issued. There is no requirement in the
       Single Code of Practice for operators to provide a copy of this
       contract as it may contain commercially sensitive information.
       The operator has confirmed it has the landowner’s authority to
       issue PCNs and, as it has signage and ANPR cameras in place
       which would not be possible without the landowner’s permission.
       As the appellant has not provided any evidence to demonstrate
       otherwise, I am satisfied that the operator has the appropriate
       authority on this site. Section 21 of the BPA code of practice
       is no longer applicable. ANPR cameras are used to capture
       vehicles entering and exiting the site to calculate the time a
       vehicle has remained in the car park. This ANPR data captured is
       then compared with the online transaction record, and if a
       vehicle exceeds the maximum stay, a PCN is issued. As NAPR
       operated car parks are fully automated, a parking operator is
       not required to provide evidence of a vehicle parked as the ANPR
       evidence proves the vehicle exceeded the maximum stay allowed.
       POPLA accept evidence from both parties in good faith unless the
       opposite is proven. The burden of proof begins with the operator
       to show it issued the PCN correctly. If they do that by
       providing ANPR images that support its version of events, the
       burden of proof then passes to the appellant. As I accept there
       is the possibility for inaccuracies, I am happy to accept any
       evidence that suggests the ANOR camera are inaccurate. However,
       as the appellant has not provided evidence to demonstrate
       otherwise, I will work on the basis that the technology is
       accurate. Section 13 of the BPA code of practice no longer
       applies. Section 5.2 of the Single Code of Practice requires a
       parking operator to allow a grace period in addition to the
       parking period. Annex B states the grace period is 10 minutes.
       In this case, the vehicle remained on site for an additional 41
       minutes therefore, both the grace period and maximum stay have
       been exceeded. The appellant has told us in their response that
       the charge is disproportionate and not commercially justified.
       This matter was considered at length by the Supreme Court in the
       case of ParkingEye v Beavis [2015] UKSC 67. In this case, the
       Court recognised that parking charges have all the
       characteristics of a penalty, but nevertheless were enforceable
       because there were legitimate interests in the charging of
       overstaying motorists. This “legitimate interests” approach
       moved away from a loss-based analysis of parking charges: “In
       our opinion, while the penalty rule is plainly engaged, the £85
       charge is not a penalty. The reason is that although ParkingEye
       was not liable to suffer loss as a result of overstaying
       motorists, it had a legitimate interest in charging them which
       extended beyond the recovery of any loss… deterrence is not
       penal if there is a legitimate interest in influencing the
       conduct of the contracting party which is not satisfied by the
       mere right to recover damages for breach of contract.” The Court
       did however make it clear that the parking charge must be
       proportionate: “None of this means that ParkingEye could charge
       overstayers whatever it liked. It could not charge a sum which
       would be out of all proportion to its interest or that of the
       landowner for whom it is providing the service.” It concluded
       that a charge in the region of £85 was proportionate, and it
       attached importance to the fact that the charge was prominently
       displayed in large lettering on the signage. While the specific
       facts of the case concerned a free-stay car park where the
       motorist had overstayed, I consider the principles that lie
       behind the decision remain the same. Taking these principles
       into account, I am not going to consider whether the loss is a
       genuine pre-estimate of loss or whether it reflects a correct
       loss to the landowner. Rather, I am going to consider the charge
       amount in the appellant’s case, as well as the signage. On this,
       I conclude the charge is appropriately prominent and in the
       region of £85 and is therefore allowable. The appellant states
       there is no proof of planning permission for signage and ANPR
       installations. POPLA is an appeals service only. Our remit
       extends solely to determining if the PCN has been issued
       correctly based on the evidence provided. It is not within
       POPLAs scope to comment on how a parking operator chooses to
       manage land it is responsible for. Therefore, should the
       appellant wish to pursue a dispute regarding this matter, they
       will need to contact the relevant authorities. On reviewing the
       operator’s evidence, the appellant expands on their initial
       grounds of appeal. As I have considered these above, I will not
       comment further. POPLA’s role is to assess if the operator has
       issued the PCN in accordance with the conditions of the
       contract. As the terms and conditions of the car park have not
       been met, I conclude that the operator has issued the PCN
       correctly, and the appeal is refused.
       #Post#: 102840--------------------------------------------------
       Re: Group Nexus - Crayford Tower Retail Park PCN
       By: b789 Date: December 17, 2025, 5:59 am
       ---------------------------------------------------------
       What exactly did you out in as your POPLA appeal? You never
       showed us. Also, did you not receive the operators evidence pack
       that also gave you a further 7 days to respond?
       Too late now but the POPLA decision is not binding on you and I
       cannot be arsed to read the wall of waffle from this pompous
       moron of a POPLA assessor.
       You DO NOT pay. You can safely ignore all the upcoming useless
       debt recovery letters. Debt collectors are powerless to do
       anything except to try and intimidate the low-hanging fruit on
       the gullible tree into paying out of ignorance and fear.
       Come back when you receive a Letter of Claim (LoC).
       #Post#: 102842--------------------------------------------------
       Re: Group Nexus - Crayford Tower Retail Park PCN
       By: b789 Date: December 17, 2025, 6:11 am
       ---------------------------------------------------------
       This decision reads less like legal reasoning and more like an
       exercise in box-ticking by someone who has memorised buzzwords
       without understanding the law that underpins them. The
       assessor’s analysis is fundamentally flawed, internally
       inconsistent, and demonstrates a worrying lack of comprehension
       of both Schedule 4 of the Protection of Freedoms Act 2012 and
       basic principles of contract formation.
       The opening premise that “the driver is responsible for seeking
       out the signs” immediately signals the problem. That is not the
       legal test. The burden is on the operator to prove that the
       terms were adequately brought to the driver’s attention such
       that a contract could be formed. Treating signage as something a
       motorist must actively hunt for is a complete inversion of
       contract law and serves only to excuse inadequate or poorly
       positioned signs. The assessor later gestures vaguely toward
       signage standards but never applies them in any meaningful way.
       The discussion of the Single Code of Practice is equally
       muddled. Large portions of the reasoning consist of announcing
       that various sections of the BPA Code “no longer apply”, as if
       that alone resolves anything. Compliance with an industry code
       does not replace the need to prove contractual incorporation,
       nor does it relieve the operator of evidential burdens. The
       assessor appears to believe that citing the new Code is a
       substitute for analysis.
       Keeper liability is where the decision collapses entirely. The
       assessor states that there “looks to be a contract” and that
       because the keeper did not name the driver, PoFA has been met.
       That is legally illiterate. Keeper liability does not arise
       because something “looks like” a contract, nor because a keeper
       declined to identify the driver. It arises only if every
       statutory condition in Schedule 4 is strictly complied with. The
       assessor does not identify those conditions, does not analyse
       them, and instead relies on impression and assumption. This is
       not how statute works.
       Signage is dealt with in the same superficial manner. The
       conclusion that there are “plenty of signs” is meaningless. The
       relevant question is whether the signs were prominent, legible,
       and positioned at the correct decision points so that a driver
       would inevitably see and understand the terms before parking and
       leaving the vehicle. Operator photographs taken at close range,
       in good lighting, at an unknown time, prove nothing about the
       driver’s experience on the day. The assessor nonetheless accepts
       them uncritically.
       By contrast, the appellant’s photographs are dismissed outright
       because they are not timestamped. There is no rule of evidence
       that requires photographs to carry embedded metadata to be
       admissible or credible. This is a standard invented by the
       assessor to reject inconvenient evidence. No equivalent
       scepticism is applied to the operator’s images.
       Landowner authority is treated with breathtaking laziness. The
       assessor accepts that authority exists because the operator says
       so, and because signage and ANPR equipment are present. That is
       circular reasoning. The very purpose of requiring written
       landowner authority is to prevent enforcement without
       permission. The idea that enforcement infrastructure could not
       exist without authority is demonstrably false and legally
       irrelevant.
       ANPR evidence is treated as conclusive proof of parking, despite
       the fact that ANPR measures entry and exit, not parking time.
       The assessor simply assumes that time on site equals time
       parked, and then shifts the burden onto the appellant to
       disprove the accuracy of the system. This again reverses the
       burden of proof. The operator must prove reliability,
       calibration, and that the alleged contractual term relates to
       the period measured. None of this is examined.
       Grace periods are similarly mishandled. The assessor
       mechanically subtracts ten minutes from the ANPR duration
       without ever establishing when parking began or ended. The
       analysis collapses different concepts into a single time
       calculation and calls it compliance. It is not.
       The reliance on ParkingEye v Beavis is careless and misleading.
       The assessor describes a £100 charge as being “in the region of
       £85” in order to squeeze the case into Beavis, ignoring that the
       Supreme Court stressed the importance of clear, prominent
       signage and proportionality in context. None of that analysis is
       actually performed. The case is cited as a talisman, not applied
       as authority.
       Taken as a whole, this decision is not reasoned adjudication. It
       is a collection of assumptions, inferences, and boilerplate
       phrases deployed to justify a foregone conclusion. It suggests
       an assessor who lacks a working understanding of PoFA, contract
       law, evidential standards, and the limits of ANPR technology.
       Frankly, it reads as though it was written by someone
       intellectually malnourished and wholly unsuited to
       quasi-judicial decision-making. A career change would be kinder
       to both the assessor and the appellants subjected to this level
       of incompetence.
       Send the following complaint by email to POPLA:
       [quote]Subject: Formal complaint regarding assessor incompetence
       and defective reasoning
       Dear POPLA Complaints Team,
       I am writing to lodge a formal complaint about the reasoning and
       competence of the assessor who determined my recent appeal.
       The decision demonstrates serious and repeated misunderstandings
       of Schedule 4 of the Protection of Freedoms Act 2012, basic
       principles of contract formation, and the evidential burdens
       that apply in civil disputes. Keeper liability was treated as a
       matter of impression rather than statutory compliance, signage
       was accepted on assertion rather than analysis, and ANPR
       entry/exit timestamps were wrongly equated with a proven period
       of parking.
       The assessor dismissed appellant evidence on invented grounds,
       while accepting operator assertions and inferences without
       proof. Concepts such as landowner authority, grace periods, and
       the application of ParkingEye v Beavis were handled
       superficially and, in several respects, incorrectly. The phrase
       “there looks to be a contract” is particularly alarming in a
       decision that purports to assess legal liability.
       This is not a disagreement over outcome; it is a complaint about
       the quality and integrity of the decision-making process. An
       assessor who reasons in this way should not be determining
       appeals that hinge on statutory interpretation and contractual
       analysis.
       I ask that this decision be formally reviewed, that the
       assessor’s reasoning be examined as a training issue, and that
       POPLA confirm what steps will be taken to ensure assessors
       receive proper instruction in PoFA, contract law, and evidential
       standards before being permitted to determine further appeals.
       I look forward to your substantive response.
       Yours faithfully,
       [Name]
       [Reference / PCN number][/quote]
       #Post#: 102860--------------------------------------------------
       Re: Group Nexus - Crayford Tower Retail Park PCN
       By: BrahmaCool Date: December 17, 2025, 7:32 am
       ---------------------------------------------------------
       Thank you so much for your detailed reponse. I have complained
       to POPLA. I will also reach out to Sports Direct as I did
       substantial shopping that day and hopefully they will be able to
       intervene. Apologies I did not post the pack operator sent to
       POPLA here, I just asked chatgpt to draft a response :( The pack
       was a standard set of images
       #Post#: 104629--------------------------------------------------
       Re: Group Nexus - Crayford Tower Retail Park PCN
       By: BrahmaCool Date: January 5, 2026, 8:46 am
       ---------------------------------------------------------
       Just an update, I have received email from POPLA that the
       compliant has been excalated, not sure if they will re-evaluate
       my case but will let you know.
       #Post#: 104632--------------------------------------------------
       Re: Group Nexus - Crayford Tower Retail Park PCN
       By: DWMB2 Date: January 5, 2026, 8:52 am
       ---------------------------------------------------------
       [quote author=BrahmaCool link=topic=8448.msg104629#msg104629
       date=1767624361]
       not sure if they will re-evaluate my case but will let you know.
       [/quote]
       They almost certainly will not, as they consider POPLA to be a
       one-stage process with no 'appeal' - if you are very lucky they
       might say that the adjudicator was mistaken, but they won't
       overturn the appeal decision.
       #Post#: 107437--------------------------------------------------
       Re: Group Nexus - Crayford Tower Retail Park PCN
       By: BrahmaCool Date: January 26, 2026, 1:08 pm
       ---------------------------------------------------------
       Got the following reponse from POPLA
       ------------------------------------
       Thank you for your email, which was passed to me by the POPLA
       team, as I am responsible for responding to complaints.
       
       I note from your correspondence that you are unhappy with the
       decision reached by the assessor in your appeal against CP Plus.
       
       POPLA is an impartial and independent appeals service, and we do
       not act either for the parking operator or the appellant. It is
       important to explain that POPLA is a one-stage process and we
       would not change a decision because either party disputes the
       assessor’s decision. However, we may consider an appeal if there
       has been a procedural error, for example – if we failed to allow
       a motorist to comment on a parking operator’s evidence pack.
       
       My role as a complaints handler is not to determine if the
       decision is correct, but to establish if the assessor has failed
       to follow the correct POPLA process and identify whether a
       procedural error has occurred.
       
       I have summarised your complaint below and will respond to each
       point individually.
       
       You explain the decision demonstrates serious and repeated
       misunderstandings of Schedule 4 of the Protection of Freedoms
       Act 2012. You explain Keeper liability was treated as a matter
       of impression rather than statutory compliance.
       
       I have reviewed the decision following your complaint and the
       assessor explained the following:
       
       “The appellant has not admitted to being the driver.  I will
       therefore be considering their responsibility as keeper of the
       vehicle.
       
       In order for the keeper to be liable for the parking charge, the
       operator has to follow the strict requirements of Schedule 4 of
       POFA. Having reviewed the evidence, I consider that there looks
       to be a contract between the driver and the parking operator,
       and the appellant has not provided a current name and address
       for service for the driver. The notice also identifies the
       creditor. Further, on reviewing the Notice to Keeper provided by
       both parties, I am satisfied this complies with the relevant
       provisions and therefore, I am satisfied that the operator has
       met POFA to transfer liability.”
       
       The assessor has explained they were satisfied the Notice to
       Keeper complied with the requirements of the Protection of
       Freedoms Act (PoFA) 2012. Upon review of the Notice to Keeper, I
       am of agreement with the assessor.
       
       
       You advise the signage was accepted on assertion rather than
       analysis and the ANPR entry and exit timestamps were wrongly
       equated with a proven period of parking.
       
       Within its evidence file, the operator provided the following
       images of the signage on site:
       
       A sign with text and images on it
       AI-generated content may be incorrect.A aerial view of a parking
       lot
       AI-generated content may be incorrect.
       A sign on the grass
       AI-generated content may be incorrect.
       I refer to the assessor’s rationale, which states:
       
       “The operator has provided multiple images of the entrance sign
       and also signage within the car park and after reviewing these,
       I am satisfied that there are plenty of signs located within the
       car park and at the entrance and that these signs meet the
       requirements of the Single Code of Practice.”
       
       The driver of the vehicle does not need to have read the terms
       and conditions of the contract to accept it. There is only the
       requirement that the driver is given the opportunity to read and
       understand the terms and conditions of the contract before
       accepting it. It is the driver’s responsibility to seek out the
       signs, and ensure they understand them, before agreeing to the
       contract and parking.
       
       I am inclined to agree with the assessor’s determination, the
       operator provided evidence of the signs which clearly outline
       parking is permitted for up to 3 hours.
       
       
       The parking operator provided images taken from the ANPR
       cameras, which I have shown below:
       
       A screenshot of a car
       AI-generated content may be incorrect.
       
       The parking operator also provided a vehicle movement search:
       
       A screenshot of a computer
       AI-generated content may be incorrect.
       The assessor explained within their rationale:
       
       “Section 21 of the BPA code of practice is no longer applicable.
       
       ANPR cameras are used to capture vehicles entering and exiting
       the site to calculate the time a vehicle has remained in the car
       park. This ANPR data captured is then compared with the online
       transaction record, and if a vehicle exceeds the maximum stay, a
       PCN is issued.
       As NAPR operated car parks are fully automated, a parking
       operator is not required to provide evidence of a vehicle parked
       as the ANPR evidence proves the vehicle exceeded the maximum
       stay allowed.
       
       POPLA accept evidence from both parties in good faith unless the
       opposite is proven.
       The burden of proof begins with the operator to show it issued
       the PCN correctly. If they do that by providing ANPR images that
       support its version of events, the burden of proof then passes
       to the appellant.
       As I accept there is the possibility for inaccuracies, I am
       happy to accept any evidence that suggests the ANOR camera are
       inaccurate. However, as the appellant has not provided evidence
       to demonstrate otherwise, I will work on the basis that the
       technology is accurate.”
       
       
       The evidence provided demonstrates that the vehicle entered at
       10:18:51 and exited the car park at 14:00:47, totaling a stay of
       3 hours and 41 minutes. ANPR cameras are primarily used to
       capture vehicles' entry and exit times and to calculate the time
       a vehicle has remained in the car park. As such, the parking
       operator would not be able to provide evidence of the vehicle
       parked in a bay. You did not provide any evidence to refute the
       ANPR images, therefore I agree with the assessor’s rationale.
       
       
       You explain the assessor dismissed your evidence on invented
       grounds, whilst accepting the operators assertion and inferences
       without proof.
       
       The assessor explained the following:
       “I recognise the appellant has provided two photographs however
       these images are not time or date stamped. As such, I am unable
       to determine when these were taken. As such, I am not satisfied
       these two images are sufficient to cast doubt on the evidence
       provided by the operator.”
       
       I cannot agree that the assessor has dismissed your evidence.
       The assessor refers to the evidence but did not consider the
       images cast doubt on the evidence of the signage provided by the
       parking operator.
       
       You advise that concepts of landowner authority, grace periods,
       and the application of ParkingEye v Beavis were handled
       superficially and incorrectly.
       
       Regarding landowner authority, the assessor stated:
       “Section 7 of the BPA code of practice is no longer applicable.
       
       Section 14.1 of the Single Code of Practice states that where
       controlled land is being managed on behalf of a landowner,
       written confirmation must be obtained before a parking charge
       can be issued.
       
       There is no requirement in the Single Code of Practice for
       operators to provide a copy of this contract as it may contain
       commercially sensitive information.
       
       The operator has confirmed it has the landowner’s authority to
       issue PCNs and, as it has signage and ANPR cameras in place
       which would not be possible without the landowner’s permission.
       As the appellant has not provided any evidence to demonstrate
       otherwise, I am satisfied that the operator has the appropriate
       authority on this site.”
       
       The assessor was satisfied the parking operator provided
       sufficient evidence to demonstrate they have the appropriate
       authority to issue parking charges. You did not provide any
       evidence to cast doubt on the evidence provided by the parking
       operator. I agree with the assessor's reasoning.
       
       Relating to grace periods, the assessor addressed this ground of
       appeal and explained section 5.2 of the Single Code of Practice
       requires parking operators to allow a 10-minute grace period in
       addition to the parking period. In this case, the vehicle was
       captured on site for 41 additional minutes, which exceeds the
       grace period and maximum stay. I agree with the assessor’s
       determination.
       
       In relation to the assessor’s response regarding ParkingEye vs
       Beavis.
       
       The appellant has told us in their response that the charge is
       disproportionate and not commercially justified. This matter was
       considered at length by the Supreme Court in the case of
       ParkingEye v Beavis [2015] UKSC 67. In this case, the Court
       recognised that parking charges have all the characteristics of
       a penalty, but nevertheless were enforceable because there were
       legitimate interests in the charging of overstaying motorists.
       This “legitimate interests” approach moved away from a
       loss-based analysis of parking charges:
       
       “In our opinion, while the penalty rule is plainly engaged, the
       £85 charge is not a penalty. The reason is that although
       ParkingEye was not liable to suffer loss as a result of
       overstaying motorists, it had a legitimate interest in charging
       them which extended beyond the recovery of any loss… deterrence
       is not penal if there is a legitimate interest in influencing
       the conduct of the contracting party which is not satisfied by
       the mere right to recover damages for breach of contract.”
       
       The Court did however make it clear that the parking charge must
       be proportionate:
       
       “None of this means that ParkingEye could charge overstayers
       whatever it liked. It could not charge a sum which would be out
       of all proportion to its interest or that of the landowner for
       whom it is providing the service.”
       
       It concluded that a charge in the region of £85 was
       proportionate, and it attached importance to the fact that the
       charge was prominently displayed in large lettering on the
       signage. While the specific facts of the case concerned a
       free-stay car park where the motorist had overstayed, I consider
       the principles that lie behind the decision remain the same.
       Taking these principles into account, I am not going to consider
       whether the loss is a genuine pre-estimate of loss or whether it
       reflects a correct loss to the landowner. Rather, I am going to
       consider the charge amount in the appellant’s case, as well as
       the signage. On this, I conclude the charge is appropriately
       prominent and in the region of £85 and is therefore allowable.
       
       The assessor has addressed the ground of appeal and explained in
       detail regarding the ParkingEye vs Beavis case. The assessor has
       considered the amount of the parking charge is prominent and in
       the region of £85.
       
       I understand your concerns about how decisions are made by
       POPLA. Our FAQ’s explain the following:
       
       A white background with black text
       AI-generated content may be incorrect.
       
       On review of the decision made, I am satisfied that the assessor
       has addressed all grounds and evidence appropriately, and I
       consider the outcome reached is correct. As POPLA is a one-stage
       process, there is no opportunity for you to appeal the decision.
       
       You are still free to dispute your parking charge through other
       channels, such as the courts, if you wish to do so. For
       independent legal advice, please contact Citizens Advice at:
       www.citizensadvice.org.uk or call 0345 404 05 06 (English) or
       0345 404 0505 (Welsh).
       
       To conclude, I am sorry that you have not had a positive
       experience when using our service. POPLA’s involvement with your
       case has now ended, and my response closes our complaints
       process. I must advise there will be no further review of your
       complaint and any further correspondence on the matter will not
       be responded to.
       *****************************************************
   DIR Next Page