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#Post#: 95860--------------------------------------------------
PCN UKCPS No stopping Leeds Train Station
DIR By: adam112
Date: October 28, 2025, 4:22 am
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Hi, I received the following PCN from UKCPS for no stopping at
Leeds Station.
I believe from reading previous posts on this forum that this is
unlawful.
How do I best proceed from here?
Thanks
PCN:
HTML https://cdn.imgpile.com/f/eup6Wfx_xl.jpg
#Post#: 95862--------------------------------------------------
Re: PCN UKCPS No stopping Leeds Train Station
DIR By: DWMB2
Date: October 28, 2025, 4:45 am
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It's not necessarily "unlawful" as such - they're entitled to
write to you to seek payment of a parking charge. Whether that
means you owe it is another matter. Helpfully, they openly say
"Non-PoFA" at the top of the notice, so they're not even trying
to hold you liable as the keeper of the vehicle. You can
therefore appeal with something on the lines of the below:
[indent]Dear Sirs,
I have received your Parking Charge Notice (Ref: ________) for
vehicle registration mark ____ ___, in which you allege that the
driver has incurred a parking charge. I note from your
correspondence that you are not seeking to hold me liable as the
registered keeper, under Schedule 4 of the Protection of
Freedoms Act 2012 ("The Act"). You have chosen not to issue a
Notice to Keeper in accordance with The Act, and it is now too
late for you to do so. Even if you were seeking to do so, Leeds
City Station is not relevant land for the purposes of the Act.
There is no obligation for me to name the driver and I will not
be doing so. I am therefore unable to help you further with this
matter, and look forward to your confirmation that the charge
has been cancelled.
Yours,[/indent]
If appealing online, be careful there are no drop down/tick
boxes that cause you to identify who was driving, and keep a
close eye on your spam folder for their response. If they do not
respond within 28 days, chase them. Them being an IPC member may
mean this is a bit of a protracted process, but if you stick to
your guns you should eventually prevail.
#Post#: 95901--------------------------------------------------
Re: PCN UKCPS No stopping Leeds Train Station
DIR By: adam112
Date: October 28, 2025, 8:19 am
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Great, thanks for your advice! I will keep you posted with the
outcome.
#Post#: 98493--------------------------------------------------
Re: PCN UKCPS No stopping Leeds Train Station
DIR By: adam112
Date: November 17, 2025, 9:18 am
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Hi,
I received the following response. I never once indicated I was
the driver of the vehicle.
HTML https://imgpile.com/p/XuMEQFL
Where do I go from here? Is it worth just paying?
#Post#: 98500--------------------------------------------------
Re: PCN UKCPS No stopping Leeds Train Station
DIR By: b789
Date: November 17, 2025, 9:58 am
---------------------------------------------------------
Where does it say in that boilerplate rejection that you were
the driver? Has it not yet clicked that you are dealing with
bottom-dwelling scammers whose only aim is to get you to pay
them out of ignorance and fear?
Why the hell would you "just pay"? If I sent you an invoice for
£100, would you "just pay"it? Of course you wouldn't, so why do
you think that the invoice you received from a scammer should be
"just paid"?
You will never pay a penny to anyone if you follow the advice
you receive here. The Keeper of the vehicle is not liable for
any charge. Only the driver would be liable. Unless you have
blabbed to them the drivers details, inadvertently or otherwise,
they have absolutely no idea who the driver is.
There is no legal obligation on the Keeper to identify the
driver to an unregulated private parking firm and you must
decline to do so. The burden of proof is on the operator to show
that it is pursuing the right party. How do you imagine they
could do that if you have declined to identify the driver? They
are not allowed to infer or assume.
All you need to do now is move on to the next stage in this scam
and appeal to the IAS kangaroo court. The odds of being
successful there are slim to none. They are no "independent" and
are as corrupt and mendacious as their paymasters as the
operator.
The only way this will be concluded is after they try to
intimidate you by eventually issuing a county court claim. They
will go to the line before giving up because they know that most
low-hanging fruit on the gullible tree can be intimidated into
paying out of ignorance and fear. They would never let it get as
far as a hearing in front of a judge would is likely to give
them a spanking in court.
For now, simply submit the following as your IAS appeal:
--- 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. This location is a railway station subject to
statutory control and is not “relevant land” as defined in
Schedule 4 of the Protection of Freedoms Act 2012. As the driver
has not been identified, there can be no keeper liability in
law. I therefore require the operator to confirm that they are
not seeking to rely on PoFA. If they dispute that this is
non-relevant land, they must provide strict proof that the land
is “relevant land” and that the Notice to Keeper fully complies
with the mandatory wording and timelines in Schedule 4 of PoFA.
In the absence of full PoFA compliance on relevant land, any
attempt to hold the keeper liable is misconceived and must fail.
>
> 2. 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.
>
> 3. 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.
>
> 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.
--- End Quote ---
#Post#: 117536--------------------------------------------------
Re: PCN UKCPS No stopping Leeds Train Station
DIR By: adam112
Date: May 1, 2026, 1:01 pm
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HI,
I just received the following in the post after all my appeals
were rejected.
HTML https://imgpile.com/p/Lm3Xe2R
Whats next in the process?
Thanks
#Post#: 117568--------------------------------------------------
Re: PCN UKCPS No stopping Leeds Train Station
DIR By: Dave65
Date: May 2, 2026, 4:54 am
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As usual there is no details of what the claim is for.
There are replies in other threads to Moorside Legal, do a
search there is one by b789.
#Post#: 117569--------------------------------------------------
Re: PCN UKCPS No stopping Leeds Train Station
DIR By: jfollows
Date: May 2, 2026, 4:57 am
---------------------------------------------------------
HTML https://www.justice.gov.uk/courts/procedure-rules/civil/rules/pd_pre-action_conduct<br
/>says
--- Quote ---
> the claimant writing to the defendant with concise details of
the claim. The letter should include the basis on which the
claim is made, a summary of the facts, what the claimant wants
from the defendant, and if money, how the amount is calculated;
--- End Quote ---
and, clearly, the letter you have received is utter rubbish.
You need to reply pointing this out, and
--- Quote ---
> The reply should include confirmation as to whether the claim
is accepted and, if it is not accepted, the reasons why,
together with an explanation as to which facts and parts of the
claim are disputed
--- End Quote ---
You’re documenting this for the court to show you’re on top of
things and that Moorside Legal is useless.
Moorside Legal is a bunch of incompetents who try to scare
people into paying without doing their job properly.
Unfortunately the tactic probably works for enough of their
victims.
In due course you will receive a county court claim to which you
will need to file a defence.
#Post#: 117832--------------------------------------------------
Re: PCN UKCPS No stopping Leeds Train Station
DIR By: adam112
Date: May 5, 2026, 1:43 pm
---------------------------------------------------------
Is it worth sending this as a response?
Dear Sirs,
Your Letter Before Claim contains insufficient detail of the
claim and fails to provide copies of evidence your client places
reliance upon and thus is in complete contravention of the
Pre-Action Protocol for Debt Claims.
I am the registered keeper of the vehicle. I am not obliged to
identify the driver and I decline to do so. As there is no legal
presumption that the keeper of a vehicle was its driver on any
particular occasion, your client cannot pursue me as driver as
per VCS v Edward (2023) [H0KF6C9C]
HTML https://www.dropbox.com/scl/fi/yvxek3kfwtb3qent3lj6y/VCS-Limited-v-Ian-Mark-Edward-H0KF6C9C.pdf?rlkey=niecohfdtj1n1ysh5prbsp52p&e=1&dl=0.
If your client is seeking to rely on Schedule 4 of the
Protection of Freedoms Act 2012 (PoFA) in order to hold me
liable as keeper, they are unable to do so. As your client
cannot pursue me as driver or keeper, it would be an abuse of
the court’s process for your client to issue a claim against me
and I will defend any such claim vigorously and seek costs in
relation to your client’s unreasonable and vexatious conduct
under Part 27.14(2)(g)
Because your letter lacks specificity and breaches the
requirements of the Pre-Action Protocol for Debt Claims
(paragraphs 3.1(a)-(d), 5.1 and 5.2) as well as the Practice
Direction - Pre-Action Conduct (paragraphs 6(a) and 6(c)), you
must treat this letter as a formal request for all of the
documents/information that the protocol now requires your client
to provide. Your client must not issue proceedings without
complying with that protocol.
As solicitors you must surely be familiar with the requirements
of both the Practice Direction and the Pre-Action Protocol for
debt claims and your client, as a serial litigator of debt
claims, should likewise be aware of them. As you (and your
client) must know, the Practice Direction and Protocol bind all
potential litigants, whatever the size or type of the claim. Its
express purpose is to assist parties in understanding the claim
and their respective positions in relation to it, to enable
parties to take stock of their positions and to negotiate a
settlement, or at least narrow the issues, without incurring the
costs of court proceedings or using up valuable court time. It
is embarrassing that a firm of Solicitors are sending a consumer
a vague and un-evidenced 'Letter of Claim' in complete ignorance
of the pre-existing Practice Direction and the Pre-Action
Protocol.
I confirm that, once I am in receipt of a Letter Before Claim
that complies with the requirements of para 3.1 (a) of the
Pre-Action Protocol, I shall then seek advice and submit a
formal response within 30 days, as required by the Protocol.
Thus, I require your client to comply with its obligations by
sending me the following information/documents:
[indent]1. An explanation of the cause of action
2. whether they are pursuing me as driver or keeper
3. whether they are relying on the provisions of Schedule 4 of
POFA 2012
4. what the details of the claim are; for how long it is claimed
the vehicle was parked, how the monies being claimed arose and
have been calculated
5. Is the claim for a contractual breach? If so, what is the
date of the agreement? The names of the parties to it and
provide to me a copy of that contract.
6. If the claim is for a contractual breach, photographs showing
the vehicle was parked in contravention of said contract.
7. Is the claim for trespass? If so, provide details.
8. Provide me a copy of the contract with the landowner under
which they assert authority to bring the claim, as required by
the BPA/IPC Private Parking Single Code of Practice (PPSCoP).
9. a plan showing where any signs were displayed
10. Photographs of the signs displayed (size of sign, size of
font, height at which displayed) at the time of any alleged
contravention.
11. Provide details of the original charge, and detail any
interest and administrative or other charges added
12. Am I to understand that the additional £70 represents what
is dressed up as a 'Debt Recovery' fee, and if so, is this nett
or inclusive of VAT? If the latter, would you kindly explain why
I am being asked to pay the operator’s VAT?
13. With regard to the principal alleged PCN sum: Is this
damages, or will it be pleaded as consideration for
parking?[/indent]
I am clearly entitled to this information under paragraphs 6(a)
and 6(c) of the Practice Direction. I also need it in order to
comply with my own obligations under paragraph 6(b).
If your client does not provide me with this information then I
put you on notice that I will be relying on the cases of Webb
Resolutions Ltd v Waller Needham & Green [2012] EWHC 3529 (Ch),
Daejan Investments Limited v The Park West Club Limited (Part
20) Buxton Associates [2003] EWHC 2872, Charles Church
Developments Ltd v Stent Foundations Limited & Peter Dann
Limited [2007] EWHC 855 in asking the court to impose sanctions
on your client and to order a stay of the proceedings, pursuant
to paragraphs 13, 15(b) and (c) and 16 of the Practice
Direction, as referred to in paragraph 7.2 of the Protocol.
Until your client has complied with its obligations and provided
this information, I am unable to respond properly to the alleged
claim and to consider my position in relation to it, and it is
entirely premature (and a waste of costs and court time) for
your client to issue proceedings. Should your client do so, then
I will seek an immediate stay pursuant to paragraph 15(b) of the
Practice Direction and an order that this information is
provided.
Yours faithfully,
#Post#: 121389--------------------------------------------------
Re: PCN UKCPS No stopping Leeds Train Station
DIR By: adam112
Date: June 10, 2026, 2:49 pm
---------------------------------------------------------
Hi,
I have now received a claim form from HM tribunal services
detailing that if I do not respond, a CCJ may be requested
against me. How should I respond?
Thanks
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