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#Post#: 96504--------------------------------------------------
GXS Parking Charge - Notice to Keeper - Rose and Crown Pub
Orpington
DIR By: Patrick
Date: November 2, 2025, 5:23 am
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Any assitance with the following would be greatly recieved. I
had success on here before so I am hoping that your wisdom will
once again be of help.
The driver entered the car park and parked up. Then entered the
pub for antenatal classes there and whilst there ordered a drink
at the bar. Then a few days later recieved the parking charge
notice to keeper in the post. They called the pub to see if they
could cancel it as they have been advised previously the
quickest way to get them cancelled is normally to contact the
busniess owner and not the parking services company. The pub
manager was very helpful and explained that he cannot cancel
parking charge but did state that he can provide a copy of the
reciept and to submit it when appealing. Aparantely GXS do not
accept banking transactions but receipts from the pub only.
Aparantly there are loads of signs in the car park and the
driver should have entered their registration into an iPad on
the way in. It was dark when the car was parked and the driver
did not notice any of this.
A copy of the email confirming the pub as the venue with times
and dates for the antenatal classes is available to be submitted
as part of the appeal. Also a screenshot of credit card
transaction on the date but not the time. Hopefully the manager
will reply with the till reciept for the drink bought with time
and date.
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#Post#: 96548--------------------------------------------------
Re: GXS Parking Charge - Notice to Keeper - Rose and Crown Pub
Orpington
DIR By: b789
Date: November 2, 2025, 1:32 pm
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That Notice to Keeper (NtK) is not fully compliant with ALL the
requirements of PoFA to be able to hold the Keeper liable if the
driver is not identified. As you are dealing with an IPC member
company and the fact that tea re all ex-clampers, don't expect
anything will get this cancelled by the operator.
If the pub contracted GXS, then they are perfectly able to get
this cancelled. Ask the landlord who is the Monkey and who is
Organ Grinder in their contractual relationship?
I am amused by your optimism that these ex-clampers will accept
your appeal. You are dealing with a scum of the earth firm whose
sole desire is to scam you out of your money. Also, don't expect
the IAS to assist either. The IAS is a kangaroo court and you
have a less than 4% chance of that being successful.
Where this will be won is after a county court money claim is
issued and you defend it with our advice. The odds of it ever
reaching a hearing are slim to none, and even if it did, the
Keeper cannot be liable if the driver is not identified.
If you get the till receipt in time, ten you can try your
appeal, for what it's worth. Personally, I would simply appeal
on the following grounds:
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. GSX 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.
GSX have no hope should you try to litigate, so you are urged to
save us both a complete waste of time and cancel the
PCN.[/quote]
#Post#: 98190--------------------------------------------------
Re: GXS Parking Charge - Notice to Keeper - Rose and Crown Pub
Orpington
DIR By: Patrick
Date: November 14, 2025, 11:21 am
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Good evening,
Thanks for your help. I appealed with the following,
"The drop down menu for reason is not extensive enough and does
not included the option 'Other reason'. I have selected one at
random.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. GSX 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. GSX have no
hope should you try to litigate, so you are urged to save us
both a complete waste of time and cancel the PCN."
They have declined the appeal with the following letter. This is
the first two pages. There are about 10 pages afterwards of
photos of the signage. Taken during daylight hours most likely
years ago I might add.
Advice on how best to proceed now is welcomed. Also irritatingly
the driver attended the same pub a week later and did enter
their registration into the iPad and would you believe it they
recieved another Parking Charge in the post for that date too.
Also shown below. Advice how how best to proceed with this one
is also welcomed. Thanks in advance!
HTML https://i.ibb.co/1VXKr8g/Screenshot-2025-11-14-170848.png
HTML https://ibb.co/c58t6DB
HTML https://i.ibb.co/996yBXjg/Screenshot-2025-11-14-170911.png
HTML https://ibb.co/gMNtQ1C9
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HTML https://ibb.co/F4vSfh9Z
HTML https://i.ibb.co/SwSGV82r/20251114-171520.jpg
HTML https://ibb.co/pjq548gy
#Post#: 98258--------------------------------------------------
Re: GXS Parking Charge - Notice to Keeper - Rose and Crown Pub
Orpington
DIR By: b789
Date: November 15, 2025, 8:59 am
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My advice is to tell the pub landlord that you, your family and
friends will no longer be customers and will be taking your
custom elsewhere unless they get the PCN cancelled and rein in
their agent who is issuing speculative invoices to their
customers.
As for the appeal rejection, as advised already, it is exactly
as expected. Appeal to the IAS, for what it's worth, with the
following:
--- 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#: 98309--------------------------------------------------
Re: GXS Parking Charge - Notice to Keeper - Rose and Crown Pub
Orpington
DIR By: Patrick
Date: November 15, 2025, 3:47 pm
---------------------------------------------------------
Thanks for such a detailed reply. What is the next steps if the
appeal to IAS is rejected? Does this then go to a court order or
similar?
#Post#: 98326--------------------------------------------------
Re: GXS Parking Charge - Notice to Keeper - Rose and Crown Pub
Orpington
DIR By: jfollows
Date: November 16, 2025, 2:20 am
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--- Quote from: Patrick link ---
>
> Thanks for such a detailed reply. What is the next steps if
the appeal to IAS is rejected? Does this then go to a court
order or similar?
>
--- End Quote ---
See Reply #1
--- Quote ---
> Where this will be won is after a county court money claim is
issued and you defend it with our advice. The odds of it ever
reaching a hearing are slim to none, and even if it did, the
Keeper cannot be liable if the driver is not identified.
--- End Quote ---
Wait for a Letter of Claim and post it here. Ignore and do not
contact debt collectors.
#Post#: 99664--------------------------------------------------
Re: GXS Parking Charge - Notice to Keeper - Rose and Crown Pub
Orpington
DIR By: Patrick
Date: November 25, 2025, 2:13 am
---------------------------------------------------------
Does the fact that the driver entered their registration into
the iPad on the way in effect the inital appeal for the second
one? Or should I use the one below, the same one as the first
one.
"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. GSX 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.
GSX have no hope should you try to litigate, so you are urged to
save us both a complete waste of time and cancel the PCN."
#Post#: 99677--------------------------------------------------
Re: GXS Parking Charge - Notice to Keeper - Rose and Crown Pub
Orpington
DIR By: b789
Date: November 25, 2025, 4:17 am
---------------------------------------------------------
No appeal is going to work with these scammers. You are only
doing so to show that you have gone through their futile process
and have satisfaction of knowing that they are going to have to
work to try and get their money, which they never will, as long
as you keep following the advice.
What has the pub management said after complaints were made
about their rogue agent pissing off all their customers who are
not likely to return and neither will others once they learn
about the way this pub treats its genuine customers? Have you
given them any ratings through social media or TrustPilot,
warning others about the high likelihood of receiving a £100
invoice, just for being a patron?
The fact that the driver entered their VRM but still received a
PCN is indicative of how corrupt and greedy this operator is. It
does not make one iota of difference for the appeals stages.
You have already been advised that there is no basis in law for
them to hold the Keeper liable for the charge if the driver is
not identified. They will push this all the way to a county
court claim for debt. That is very good for you, the Keeper.
Their MO is to try and intimidate you into paying out of
ignorance and fear.
However, if the claim were to ever reach a hearing in front of a
judge (highly unlikely), they would receive a spanking in court.
What they are most likely going to do, is discontinue at a late
stage, in the hope you are low-hanging fruit.
#Post#: 99679--------------------------------------------------
Re: GXS Parking Charge - Notice to Keeper - Rose and Crown Pub
Orpington
DIR By: DWMB2
Date: November 25, 2025, 4:23 am
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--- Quote from: b789 link ---
>
> The fact that the driver entered their VRM but still received
a PCN is indicative of how corrupt and greedy this operator is.
It does not make one iota of difference for the appeals stages.
>
--- End Quote ---
Whilst I agree, I'd be tempted to include a sentence pointing it
out (in a way that does not identify the driver, of course).
Additional fuel to the defensive fire if it can be pointed out
that they haven't even addressed the underlying fact that the
charge shouldn't have been issued in the first place if their
equipment had been working.
#Post#: 103774--------------------------------------------------
Re: GXS Parking Charge - Notice to Keeper - Rose and Crown Pub
Orpington
DIR By: Patrick
Date: December 25, 2025, 12:41 am
---------------------------------------------------------
Update on the outcome in case it is helpful for you for future
advice.
Both cancelled!
I recieved emails from the IAS that stated, "Your appeal to the
Independent Appeals Service has now been conceded. The operator
will no longer be pursuing the PCN detailed below."
No reason was given so I logged onto the IAS portal and it
states, "The Operator conceded this appeal due to not completing
their Prima Facie Case on time"
I can only assume that GXS didn't bother to reply to the IAS.
Thanks for all the help!
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