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#Post#: 96234--------------------------------------------------
NPC Notice to Keeper parked on pavement
DIR By: 8vaibhav
Date: October 30, 2025, 2:41 pm
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I have received this as a keeper:
HTML https://i.ibb.co/Fq6TjmzM/Screenshot-20251030-190922.jpg
HTML https://ibb.co/BKLMScBx
Is this POFA compliant?
Please advise what to challenge this with in text and which of
these options to choose:
HTML https://i.ibb.co/G3CcJSwW/Screenshot-20251030-193910.jpg
HTML https://ibb.co/JFr5dJLv
Please see online "proof" images they have shared:
HTML https://i.ibb.co/RGVgkxbn/c-FFz-RXlw-MTB1-TE9-CT2-J5-TFcv-Z0-Q4-OGd-Dc2x-Bc1-Er-K3dn-QVpyd-Ggz-Ryt-Sa-E83-QVU1-Vzhn-Rkx-Re-VNF.jpg
HTML https://imgbb.com/
HTML https://i.ibb.co/H0gct7k/Sn-FXTXoyem-RLVGt-Va1-JPak1j-Wn-Jmalh-YS0d-IMUNZc-VJz-Wn-Jr-TEs2-TTZt-Zis4-VXl-QYVla-UTh-UQz-Fx-Sj-Q.jpg
HTML https://ibb.co/PRC2cxf
HTML https://i.ibb.co/v6SprMdx/TCt-RNXJJV1pi-Z1g0-Vi9-Mb-Wk0-Nn-BXMXZQNHQrbzk3e-EFMa1-FPUj-J5b2-V5-Ry8v-Qk-Q0-Tz-RDWllv-Rk9p-ZHdj-O.jpg
HTML https://ibb.co/C3fgXS95
HTML https://i.ibb.co/ds1bn5sB/Screenshot-20251030-194648.jpg
HTML https://ibb.co/vCgs2jC1
Many thanks
#Post#: 96237--------------------------------------------------
Re: NPC Notice to Hirer parked on pavement
DIR By: DWMB2
Date: October 30, 2025, 3:04 pm
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The title of your thread says "Notice to Hirer", but the notice
you have shown us says it is a "Notice to Registered keeper".
What is your relationship to the vehicle?
#Post#: 96245--------------------------------------------------
Re: NPC Notice to Keeper parked on pavement
DIR By: 8vaibhav
Date: October 30, 2025, 3:45 pm
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Apologies, I am the keeper, fixed the title
#Post#: 96345--------------------------------------------------
Re: NPC Notice to Keeper parked on pavement
DIR By: 8vaibhav
Date: October 31, 2025, 11:52 am
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I do see that the NTK fails to "state that the creditor does not
know both the name of the driver and a current address for
service for the driver" so not complaint with Protection of
Freedoms Act 2012, schedule 4, paragraph 9, clause 2(e).
Any other instances of non-compliance here? Any other defense
should be added? The pictures do show barely half the tire on
the pavement which itself is ambiguous. Also, observation window
seems to be too low, less than 2 minutes.
Can anybody help me frame an appeal please. Also which option to
choose online while appealing? Many thanks in advance.
#Post#: 96359--------------------------------------------------
Re: NPC Notice to Keeper parked on pavement
DIR By: b789
Date: October 31, 2025, 1:23 pm
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No initial appeal to this bottom-dwelling firm of ex-clampers is
going to succeed. Also, the secondary IAS appeal will not
succeed either as the IAS is owned by the same firm that owns
the IPC. Where this will be won, eventually, is after they issue
a county court claim, which when defended with advice from here
is easily won and the odds of it ever getting as far as an
actual hearing is incredibly low.
Your choice. Pay into the scam and become part of the problem or
fight it with the advice you get here.
The Notice to Keeper (NtK) is not PoFA compliant with para
9(2)(a) and you would argue that there is no evidence of a
contract ever being foamed with the driver. Not that you're
going to waste that argument on the incestuous IPC and IAS.
Here is the initial appeal you should submit. You are ONLY
appealing as the Keeper. They have no idea who the driver is
unless you blab it to them inadvertently or otherwise.
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.
The NtK is not compliant with all the requirements of PoFA which
means that if the unknown driver is not identified, they cannot
transfer liability for the charge from the unknown driver to the
known keeper.
Use the following as your appeal. No need to embellish or remove
anything from it:
--- Quote ---
> I am the keeper of the vehicle and I dispute your 'parking
charge'. I deny any liability or contractual agreement and I
will be making a complaint about your predatory conduct to your
client landowner.
>
> As your Notice to Keeper (NtK) does not fully comply with ALL
the requirements of PoFA 2012, you are unable to hold the keeper
of the vehicle liable for the charge. Partial or even
substantial compliance is not sufficient. There will be no
admission as to who was driving and no inference or assumptions
can be drawn. NPC 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.
NPC have no hope should you be so stupid as to try and litigate,
so you are urged to save us both a complete waste of time and
cancel the PCN.
--- End Quote ---
#Post#: 96381--------------------------------------------------
Re: NPC Notice to Keeper parked on pavement
DIR By: 8vaibhav
Date: October 31, 2025, 5:38 pm
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--- Quote from: b789 link ---
>
> No initial appeal to this bottom-dwelling firm of ex-clampers
is going to succeed. Also, the secondary IAS appeal will not
succeed either as the IAS is owned by the same firm that owns
the IPC. Where this will be won, eventually, is after they issue
a county court claim, which when defended with advice from here
is easily won and the odds of it ever getting as far as an
actual hearing is incredibly low.
>
> Your choice. Pay into the scam and become part of the problem
or fight it with the advice you get here.
>
> The Notice to Keeper (NtK) is not PoFA compliant with para
9(2)(a) and you would argue that there is no evidence of a
contract ever being foamed with the driver. Not that you're
going to waste that argument on the incestuous IPC and IAS.
>
> Here is the initial appeal you should submit. You are ONLY
appealing as the Keeper. They have no idea who the driver is
unless you blab it to them inadvertently or otherwise.
>
> 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.
>
> The NtK is not compliant with all the requirements of PoFA
which means that if the unknown driver is not identified, they
cannot transfer liability for the charge from the unknown driver
to the known keeper.
>
> Use the following as your appeal. No need to embellish or
remove anything from it:
>
> [quote]I am the keeper of the vehicle and I dispute your
'parking charge'. I deny any liability or contractual agreement
and I will be making a complaint about your predatory conduct to
your client landowner.
>
> As your Notice to Keeper (NtK) does not fully comply with ALL
the requirements of PoFA 2012, you are unable to hold the keeper
of the vehicle liable for the charge. Partial or even
substantial compliance is not sufficient. There will be no
admission as to who was driving and no inference or assumptions
can be drawn. NPC 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.
NPC have no hope should you be so stupid as to try and litigate,
so you are urged to save us both a complete waste of time and
cancel the PCN.
--- End Quote ---
[/quote]
Thanks, can you also advise which option from the drop down to
choose?
I am tempted to select "I was not aware that I have incurred a
charge", all others seem less true than this one.
#Post#: 96404--------------------------------------------------
Re: NPC Notice to Keeper parked on pavement
DIR By: 8vaibhav
Date: November 1, 2025, 4:48 am
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I have appealed as keeper and choosing the above option with the
following text:
--- Quote ---
> I am the keeper of the vehicle and I dispute your 'parking
charge'. I deny any liability or contractual agreement and I
will be making a complaint about your predatory conduct to your
client landowner.
>
> As your Notice to Keeper (NtK) does not fully comply with ALL
the requirements of PoFA 2012, you are unable to hold the keeper
of the vehicle liable for the charge.
>
> Besides, other shortfalls, as an example, your NTK fails to
"state that the creditor does not know both the name of the
driver and a current address for service for the driver" so it
is not complaint with the Protection of Freedoms Act 2012,
schedule 4, paragraph 9, clause 2(e).
>
> Partial or even substantial compliance is not sufficient.
There will be no admission as to who was driving and no
inference or assumptions can be drawn. NPC 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.
NPC have no hope should you be so stupid as to try and litigate,
so you are urged to save us both a complete waste of time and
cancel the PCN.
>
--- End Quote ---
#Post#: 98681--------------------------------------------------
Re: NPC Notice to Keeper parked on pavement
DIR By: 8vaibhav
Date: November 18, 2025, 12:16 pm
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I have got the following expected rejection:
Please share a draft for the IAS appeal, many thanks in advance.
HTML https://i.ibb.co/pvr1hFxn/Screenshot-20251118-172754.jpg
HTML https://ibb.co/Lzh0N78v
#Post#: 98729--------------------------------------------------
Re: NPC Notice to Keeper parked on pavement
DIR By: b789
Date: November 19, 2025, 12:24 am
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We really don’t need to see their rejection. We know they will
reject, irrespective of whatever you appealed with.
Now you have to submit a useless IAS appeal. You are just going
through the process. That will also be rejected. This wil only
conclude after they issue a county court claim. Anything before
the claim is part of the scam that is the IPC, which owns the
IAS.
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. 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.
--- End Quote ---
#Post#: 100133--------------------------------------------------
Re: NPC Notice to Keeper parked on pavement
DIR By: 8vaibhav
Date: November 27, 2025, 4:14 pm
---------------------------------------------------------
Sharing another winner update here. Thanks guys, NPC gave up
even before IAS could review the appeal.
Appeal Status
Operator Conceded
[b][I]The Operator conceded this appeal due to Landowner
Intervention.
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