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       #Post#: 98145--------------------------------------------------
       PCN Parking Eye Gale St Dagenham
   DIR By: Liffey
       Date: November 14, 2025, 7:19 am
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       The driver entered the car park, found a space and parked. The
       driver was taking their minor daughter to an urgent optician's
       appointment.
       The PCN has been received in the post today
  HTML https://i.ibb.co/Kxms9gp2/20251114-130736.jpg
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       #Post#: 98159--------------------------------------------------
       Re: PCN Parking Eye Gale St Dagenham
   DIR By: b789
       Date: November 14, 2025, 7:51 am
       ---------------------------------------------------------
       Why didn't the driver enter their VRM details into the terminal?
       #Post#: 98162--------------------------------------------------
       Re: PCN Parking Eye Gale St Dagenham
   DIR By: Liffey
       Date: November 14, 2025, 7:56 am
       ---------------------------------------------------------
       They were not visiting either of the businesses it applies to
       #Post#: 98165--------------------------------------------------
       Re: PCN Parking Eye Gale St Dagenham
   DIR By: b789
       Date: November 14, 2025, 8:05 am
       ---------------------------------------------------------
       Then the only argument the Keeper has is to decline to identify
       the driver and rely on the fact that their Notice to Keeper
       (NtK) does not fully comply with all the requirements of PoFA
       2012 and therefore the Keeper cannot be liable.
       You would have to persuade ParkingEye, POPLA and, ultimately, a
       judge that their NtK does not comply with PoFA paragraph
       9(2)(e)(i) for the following reason:
       Schedule 4 paragraph 9(2) is binary (“MUST” means all or
       nothing) and this NtK omits the mandatory invitation to the
       keeper to pay under 9(2)(e)(i)
       Schedule 4 paragraph 9(2) does not say the notice should include
       certain things. It says: “The notice must — (a)… (b)… (c)… (d)…
       (e)… (f)… (g)… (h)… (i)…”. “Must” is compulsory. PoFA 9(2) is a
       statutory gateway to keeper liability: either every required
       element is present or the gateway never opens. There is no such
       thing as “partial” or even “substantial compliance” with 9(2).
       Like pregnancy, it is binary: a notice is either PoFA-compliant
       or it is not. If one required limb is missing, the operator
       cannot use PoFA to pursue the keeper. End of.
       Here the missing limb is 9(2)(e)(i). That sub-paragraph requires
       the NtK to invite the keeper to pay the unpaid parking charges.
       The law is explicit that the invitation must be directed to “the
       keeper”. It is not enough to tell “the driver” to pay; it must
       invite “the keeper” to pay if the creditor wants keeper
       liability.
       What this NtK actually does is talk only to “the driver” when
       demanding payment, and nowhere invites “the keeper” to pay. The
       demand section of the NtK is framed in driver terms (e.g.
       language such as “the driver is required to pay within 28 days”
       / “payment is due from the driver”), and there is no sentence
       that invites “the keeper” to pay the unpaid parking charges. The
       word “keeper” (if used at all) appears only in neutral
       data/disclosure paragraphs or generic definitions, not in any
       invitation to pay. That omission is precisely what 9(2)(e)(i)
       forbids.
       For the avoidance of doubt, 9(2)(e) contains two limbs: (i) an
       invitation to the keeper to pay, and (ii) an invitation to
       either identify and serve the driver and to pass the notice to
       the driver. Even setting aside 9(2)(e)(ii), the absence of the
       9(2)(e)(i) keeper-payment invitation alone is fatal to PoFA
       compliance. The statute makes keeper liability contingent on
       strict satisfaction of every “must” in 9(2). Where a notice
       invites only “the driver” to pay, it fails 9(2)(e)(i), so it is
       not a PoFA notice. The operator therefore cannot transfer
       liability from an unidentified driver to the registered keeper.
       Only the driver could ever be liable; the driver is not
       identified. The keeper is not liable in law.
       #Post#: 98206--------------------------------------------------
       Re: PCN Parking Eye Gale St Dagenham
   DIR By: Liffey
       Date: November 14, 2025, 12:49 pm
       ---------------------------------------------------------
       Many thanks
       #Post#: 98224--------------------------------------------------
       Re: PCN Parking Eye Gale St Dagenham
   DIR By: Liffey
       Date: November 15, 2025, 4:21 am
       ---------------------------------------------------------
       Would there be any poiny in also arguing that the time stamps
       don't reflect the length of parking or that the grace period
       hasn't been given?
       #Post#: 98250--------------------------------------------------
       Re: PCN Parking Eye Gale St Dagenham
   DIR By: InterCity125
       Date: November 15, 2025, 7:25 am
       ---------------------------------------------------------
       --- Quote from: Liffey link ---
       >
       > Would there be any poiny in also arguing that the time stamps
       don't reflect the length of parking or that the grace period
       hasn't been given?
       >
       --- End Quote ---
       In a word 'No'.
       The grace period is not a period of free parking - the grace
       period is the period which allows the driver to examine the
       offer of contract and decide if they wish to either remain on
       site or leave.
       Your argument would have validity if there had been a payment
       which fell slightly short on time - for example, if you paid for
       60 minutes but your 'time on site' was 70 minutes.
       #Post#: 98251--------------------------------------------------
       Re: PCN Parking Eye Gale St Dagenham
   DIR By: jfollows
       Date: November 15, 2025, 7:32 am
       ---------------------------------------------------------
       No, the “grace period” is the extra time added to a valid
       payment for parking.
       --- Quote ---
       > It is essentially the period of time required for a driver to
       identify and read the signs that display the parking terms and
       conditions – plus the time it takes to exit the car park should
       they decide not to accept the terms and conditions. If the
       driver decides to park, the consideration period falls away – it
       is not a period of ‘free parking’ before the parking event
       starts.
       >
       > Unlike the grace period, the duration of the consideration
       period varies depending on the number of spaces in the car park
       and other factors, including exceptional circumstances. For
       detailed information, see the table in Annex B (page 35) of the
       Code of Practice.
       --- End Quote ---
       The “consideration period” is the one about thinking about the
       contract and deciding not to enter into it.
       See
  HTML https://www.britishparking.co.uk/write/Documents/AOS/NEW%20Redesigned%20Documents/sectorsingleCodeofPractice.pdf
       #Post#: 98261--------------------------------------------------
       Re: PCN Parking Eye Gale St Dagenham
   DIR By: b789
       Date: November 15, 2025, 9:24 am
       ---------------------------------------------------------
       Consideration and grace periods have nothing to do with this
       PCN. The vehicle was on the private property in breach of the
       terms and conditions.
       Read the alleged contravention:
       --- Quote ---
       > By either not purchasing a valid pay and display ticket, by
       remaining at the car park for longer than permitted, or by not
       entering your registration details via the terminal, in
       accordance with the terms and conditions set out in the signage,
       the Parking Charge is now payable to ParkingEye Ltd (as the
       Creditor).
       --- End Quote ---
       I specifically asked why did the driver not enter their VRM into
       the terminal and was told "They were not visiting either of the
       businesses it applies to".
       The only defence the Keeper has is to not identify the driver
       and plead no PoFA liability as para 9(2)(e)(i) has not been
       complied with.
       #Post#: 98269--------------------------------------------------
       Re: PCN Parking Eye Gale St Dagenham
   DIR By: Liffey
       Date: November 15, 2025, 10:31 am
       ---------------------------------------------------------
       --- Quote from: b789 link ---
       >
       > Consideration and grace periods have nothing to do with this
       PCN. The vehicle was on the private property in breach of the
       terms and conditions.
       >
       > Read the alleged contravention:
       >
       > [quote]By either not purchasing a valid pay and display
       ticket, by remaining at the car park for longer than permitted,
       or by not entering your registration details via the terminal,
       in accordance with the terms and conditions set out in the
       signage, the Parking Charge is now payable to ParkingEye Ltd (as
       the Creditor).
       --- End Quote ---
       I specifically asked why did the driver not enter their VRM into
       the terminal and was told "They were not visiting either of the
       businesses it applies to".
       The only defence the Keeper has is to not identify the driver
       and plead no PoFA liability as para 9(2)(e)(i) has not been
       complied with.
       [/quote]
       Ok, thank you. I was a bit concerned as you said this argument
       would ultimately need to convince a Judge. Does that mean
       ParkingEye will take me to court?
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