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       #Post#: 103040--------------------------------------------------
       Horizon Parking - Maximum Stay - Tesco Hackney Morning Lane
   DIR By: terika4e
       Date: December 18, 2025, 10:47 am
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       Hi all,
       The driver parked in this car park and used what they thought
       was YourParkingSpace to pay for parking.
       I (registered keeper) then recieved this PCN today (18/12).
       Either it was a technical issue or something else (user error)
       on the app that caused this.
       What do you suggest? I do not have photos of signage but here
  HTML https://maps.app.goo.gl/wAtkQ3KXJ7ZBG5ZTA
       is the GSV link. PCN
       is here
  HTML https://drive.google.com/drive/folders/1TLQ2RW5majrbXs9lCq6yHauBGje-3tru?usp=sharing
       Cheers,
       terika4e
       #Post#: 103053--------------------------------------------------
       Re: Horizon Parking - Maximum Stay - Tesco Hackney Morning Lane
   DIR By: DWMB2
       Date: December 18, 2025, 11:44 am
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       --- Quote from: terika4e link ---
       >
       > PCN is here
  HTML https://drive.google.com/drive/folders/1TLQ2RW5majrbXs9lCq6yHauBGje-3tru?usp=sharing
       >
       --- End Quote ---
       Half of it is - we need to see the back.
       #Post#: 103245--------------------------------------------------
       Re: Horizon Parking - Maximum Stay - Tesco Hackney Morning Lane
   DIR By: terika4e
       Date: December 19, 2025, 11:59 am
       ---------------------------------------------------------
       I have updated the link.
       #Post#: 103908--------------------------------------------------
       Re: Horizon Parking - Maximum Stay - Tesco Hackney Morning Lane
   DIR By: terika4e
       Date: December 28, 2025, 12:38 pm
       ---------------------------------------------------------
       Just bumping this as the 28 days has passed to submit a appeal.
       Does anyone have any suggestions?
       #Post#: 103917--------------------------------------------------
       Re: Horizon Parking - Maximum Stay - Tesco Hackney Morning Lane
   DIR By: b789
       Date: December 28, 2025, 1:49 pm
       ---------------------------------------------------------
       You have until tomorrow to submit an appeal. The PPSCoP states
       that an appeal can be made up tp 28 days after "receipt" of the
       NtK. With an issue date of Thursday 27 November, it was deemed
       received (if they can prove a first class or equivalent 1-2
       delivery, which they can't) on Monday 01 December.
       It would be useful to see the terms signs but they are claiming
       "Exceeded maximum stay period ANPR" which is NOT a period of
       parking, but a period of time on site. Also, according to the
       September 2025 GSV view of the entrance, there is no compliant
       entrance sign, which therefore invalidates any supposed contract
       with the driver.
       The main issue with this Notice is that it is a PARKING charge,
       but the “evidence” and the allegation are about time on site,
       not parking.
       On the front page Horizon only give two ANPR timestamps. Those
       are camera capture times at the perimeter. They do not show when
       the car was parked, where it was parked, or for how long it was
       parked. They also include an “Issue Reason: Exceeded Maximum
       Stay Period ANPR” which again shows they are relying on ANPR
       entry/exit times, not evidence of a defined period of parking.
       That distinction matters for keeper liability. Parliament did
       not create keeper liability for being on site for a certain
       length of time. Schedule 4 of the Protection of Freedoms Act
       2012 only allows a parking operator to transfer liability from
       the driver to the registered keeper if the Notice to Keeper
       complies with strict requirements. One of those requirements is
       PoFA Schedule 4 paragraph 9(2)(a), which says the Notice to
       Keeper must specify the vehicle, the relevant land on which it
       was parked, and the period of parking to which the notice
       relates.
       This Notice does not specify any period of parking at all. It
       gives entry and exit camera times and then asserts there was a
       breach. That is not the same thing as stating a period of
       parking. ANPR cannot prove a period of parking because it only
       records a vehicle passing a camera. It cannot account for time
       spent queuing, circulating, waiting for a bay, manoeuvring,
       loading or unloading, or any other time when the vehicle is on
       site but not parked. Because the Notice fails to specify a
       period of parking, it fails PoFA 9(2)(a). The consequence is
       that Horizon cannot hold the keeper liable. They can only pursue
       the driver, and the keeper is under no obligation to identify
       the driver.
       The second core point is contract formation. A private parking
       charge is only recoverable if the driver was clearly alerted to
       the existence of parking terms and given a fair opportunity to
       read and accept them. At this site there is no entrance sign (or
       there wan't one in September this year) that complies with the
       mandatory entrance signage requirements. If there is no
       compliant entrance sign at all, the driver is not alerted on
       entry that terms apply, who the parking operator is, what the
       principal terms are, or where the full terms can be read.
       Without that, there is no proper offer and acceptance on entry
       and no reliable basis for claiming a contract was formed. In a
       later POPLA appeal, Horizon would be put to strict proof by
       providing clear photographs of the entrance signage in place on
       the date and a site plan showing where those signs were
       positioned and how they would be seen by a driver entering.
       Those are the two main foundations of a later POPLA appeal in
       this case: first, no keeper liability because the Notice does
       not specify a period of parking as required by PoFA 9(2)(a) and
       relies on time on site; second, no contract because there is no
       compliant entrance sign to bring terms to a driver’s attention
       on entry.
       For now, simply submit the following as your initial appeal.
       Once it is rejected, you can then try and explain to POPLA why
       there can be no Keeper liability and, even if there was, not
       contract formed with the driver:
       --- 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. Horizon 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.
       Horizon have no hope at POPLA, so you are urged to save us both
       a complete waste of time and cancel the PCN.
       --- End Quote ---
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