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#Post#: 107812--------------------------------------------------
Re: UKCPS Leeds Station - Notice to Keeper (Postal-PoFA) - no
recollection of stopping
DIR By: jfollows
Date: January 29, 2026, 2:24 am
---------------------------------------------------------
If their evidence is all about what the driver did, and does not
respond to the PoFA main point, then you should respond to the
effect that by not responding they accept the point and
therefore the stuff about the driver is irrelevant. But that’s
only a guess for now - the common tactic we’ve already seen is
to ignore things that go against them.
#Post#: 108803--------------------------------------------------
Re: UKCPS Leeds Station - Notice to Keeper (Postal-PoFA) - no
recollection of stopping
DIR By: Snapp1e
Date: February 5, 2026, 7:36 am
---------------------------------------------------------
hi!
Did you see this coming?!!
1.
I have got the reply from UKCPS to the IAS.
UKCPS has now changed my charge notice!!
I was issued with: Notice to Keeper (Postal - PoFA) Issued on
private land
They have now told the IAS the charge is not under the
Protection of Freedoms Act 2012 (PoFA)! They have changed it to:
The Notice to Keeper (Non-ANPR)
Does this mean they are using the change of Law from 26th
December 2026?
UKCPS has correctly stated the NtK was issued on 10/12/2026
Well, well, well...!! BLATANT LYING.
I'm FUMING AND LAUGHING AT THE SAME TIME. >:( ;D
Copy and pasted (see this screen shot in the link below)
----------------------------------
The operator made their Prima Facie Case on 04/02/2026 14:02:13.
The operator reported that...
The appellant was the keeper.
The Notice to Keeper (Non-ANPR) was sent on 17/12/2025.
The ticket was issued on 10/12/2025.
The charge is based in Contract.
The operator made the following comments...
Please be advised that this charge was issued under the site's
terms and conditions and not under the Protection of Freedoms
Act 2012 (PoFA). It is a contractual notice directed at the
driver of the vehicle for stopping in a prohibited area. Under
this framework, liability is assumed to rest with the registered
keeper unless evidence is provided to show that they were not
the driver.
The charge was issued correctly in accordance with site
regulations and the IPC Code of Practice and remains valid and
enforceable.
---------------------------------------------------
HTML https://ibb.co/7NJdkCMT
Email from IAS side 1 with instructions
HTML https://ibb.co/Gvwx0Jy5
Email from IAS side 2 with instructions
HTML https://ibb.co/JRy2nzHq
IAS - UKCPS Prima Facie response
2.
UKCPS has also responded with 'more evidence' to the IAS with
their Leeds Station Site Images. A total of 77 additional photos
all taken on 25/07/2025 (not on the day or month of the charge
sent to me). I have saved these in 42 screen shot images. The
photos cover: station map of site, signage in various locations,
various vehicles parked next to signs or in stopping areas. For
obvious reason, I have not uploaded these images, many random.
People on here already know the signage across the site.
3.
Please, please advise me on wording for a reply.
A. Jfollows advised above to give a response if they do not
respond to the PoFA. Now they're saying PoFA isn't relevant.
If this option is advised in preparation for sending to
adjudication please ley me know and please help with the
response.
B. Or, I could go straight to arbitration. How can IAS
arbitration agree with a change in Law in the Ntk charge?
Surely if the IAS do not drop this charge now, they are also
breaking the Law?
I know this isn't relevant, but I like to say it. The UKCPS
photo evidence shows that the vehicle was stopped for 5 seconds
only and nobody got in our out of the vehicle.
I'm looking forward to reading your responses for my next steps.
Thanks!
#Post#: 108807--------------------------------------------------
Re: UKCPS Leeds Station - Notice to Keeper (Postal-PoFA) - no
recollection of stopping
DIR By: jfollows
Date: February 5, 2026, 7:50 am
---------------------------------------------------------
You’re still trying to make this too complicated.
Your appeal stated that they could not use PoFA to transfer
liability to you.
They now confirm to the IAS that you were correct, so should
have upheld your appeal initially, and the IAS should also
uphold your appeal.
You also need to rubbish their statement “liability is assumed
to rest with the registered keeper unless evidence is provided
to show that they were not the driver”. Liability rests with the
driver, and can only be transferred to the registered keeper if
the provisions of PoFA are all followed, which in this case they
can not be and UKCPS has admitted this.
When you say “Non-ANPR” is that correct, or did you mean
“Non-PoFA”?
PoFA is completely relevant, and since they now admit they’re
not using its provisions (as they couldn’t, anyway, but they
originally claimed they could) they can’t transfer liability to
you, the registered keeper, which is what you said at the start.
#Post#: 108812--------------------------------------------------
Re: UKCPS Leeds Station - Notice to Keeper (Postal-PoFA) - no
recollection of stopping
DIR By: Snapp1e
Date: February 5, 2026, 8:31 am
---------------------------------------------------------
Hi Jfollows
thanks for your reply.
I'm coming to this from knowing nothing as you can see. I seem
to have totally misunderstood their reply regarding PoFA and
non-ANPR.
Yes it is non-ANPR - see the copy and pasted wording for Notice
to Keeper. It is now different.
So you're saying it's good news?
#Post#: 108813--------------------------------------------------
Re: UKCPS Leeds Station - Notice to Keeper (Postal-PoFA) - no
recollection of stopping
DIR By: Snapp1e
Date: February 5, 2026, 8:33 am
---------------------------------------------------------
The UKCPS finish their evidence by stating:
"The charge was issued correctly in accordance with site
regulations and the IPC Code of Practice and remains valid and
enforceable."
The UKCPS has not dropped the charge.
#Post#: 108819--------------------------------------------------
Re: UKCPS Leeds Station - Notice to Keeper (Postal-PoFA) - no
recollection of stopping
DIR By: InterCity125
Date: February 5, 2026, 10:13 am
---------------------------------------------------------
Research VCS v Edward - this should allow you to disprove their
assertion that liability is automatically passed to the keeper.
Also, if such an assumption could be made, why does PoFA exist??
Point out that sending an NtK which states PoFA keeper liability
is unlawful in situations where PoFA cannot apply - point out
their clearly haphazard methods of running their enforcement
operations at this site - totally unprofessional and a breach of
their Code of Practice.
Draw the assessors attention to the contradictory signage /
markings - you are stopped briefly on double yellow lines which
the law allows - only double reds can mean no stopping. Claims
of 'No Stopping' are not supported by the road markings which is
in direct contravention of the Code of Practice which
specifically states, "Signs and surface markings must be
designed, applied and maintained in such a way as to be visible,
legible and UNAMBIGUOUS TO DRIVERS."
#Post#: 108824--------------------------------------------------
Re: UKCPS Leeds Station - Notice to Keeper (Postal-PoFA) - no
recollection of stopping
DIR By: Snapp1e
Date: February 5, 2026, 10:50 am
---------------------------------------------------------
Intercity
My friend and I are digesting your info. Thanks for your time.
Quote: "Point out that sending an NtK which states PoFA keeper
liability is unlawful in situations where PoFA cannot apply -
point out their clearly haphazard methods of running their
enforcement operations at this site - totally unprofessional and
a breach of their Code of Practice".
Is this point correct?:
The operator can only approach the DVLA for a registered
keeper's vehicle registration and name and address IF a parking
contravention has occurred on relevant land.
If so, is the UKCPS also in breach of DVLA of .... (I dont know
the right words).
Is this relevant to put in my response?
Are you advising I go straight to arbitration now?
-------
I am cobbling a draft and will put it on here for feedback.
I'll try and get it done for tomorrow.
It's good to know from jfollows that by dropping the PoFA they
have agreed to my appeal in law, even though they will not say
that.
#Post#: 108825--------------------------------------------------
Re: UKCPS Leeds Station - Notice to Keeper (Postal-PoFA) - no
recollection of stopping
DIR By: DWMB2
Date: February 5, 2026, 10:54 am
---------------------------------------------------------
--- Quote ---
> Is this point correct?:
>
> The operator can only approach the DVLA for a registered
keeper's vehicle registration and name and address IF a parking
contravention has occurred on relevant land.
>
--- End Quote ---
Not quite - they're allowed to request keeper details on land
that isn't relevant land, what they're not allowed to do is
claim that they can rely on PoFA in situations where they
cannot.
The "if" would relate to if a parking contravention has
occurred. In this case there's a fair argument that one hasn't
#Post#: 108870--------------------------------------------------
Re: UKCPS Leeds Station - Notice to Keeper (Postal-PoFA) - no
recollection of stopping
DIR By: Snapp1e
Date: February 5, 2026, 7:18 pm
---------------------------------------------------------
DRAFT reply
7-day deadline. I am submitting it on 9th February
Not sure of decision:
Counter-respond to UKCPS: ? (I need to ensure assessor in
appeal)
To IAS Arbitration: ? (I need to ensure adjudicator in appeal)
Guessing it is Arbitration - please confirm.
I might use NtK and CPN wrongly...
Lots of wording and layout taken from b789 previous posts to
other cases. I hope we haven't used wording not relevant to my
case.
This draft has taken 12 hours with 3 people involved!
Dear IAS Adjudicator,
I am the registered keeper of vehicle [XXXX] and wish to appeal
the Parking Charge Notice (PCN) issued by UKCPS based on the
following seven grounds:
1. The operator has now changed the PCN because it was not PoFA
compliant.
2. The operator has failed to deliver a Notice To Keeper that is
PoFA compliant.
3. The operator has not shown that the individual who it is
pursuing is in fact the driver.
4. New claims? (non-ANPR, the charge is based in Contract)
5. Signage and the claim that the charge is based on Contract.
6. No evidence of Landowner Authority - the operator is put to
strict proof of full compliance with the IPC Code of Practice.
???
7. Shambolic operator in breach of Code of Practice of IPS and
DVLA.
1.
UKCPS has changed the PCN since the appellant submitted their
appeal to the IAS:
from: PCN: "Notice to Keeper (Postal - PoFA) issued on private
land, was sent on 17/12/2025. Reason for issue: no stopping."
to: Prima Facie Case: "The Notice to Keeper (Non-ANPR), was sent
on 17/12/2025. The charge is based in Contract."
2.
The Notice to Keeper (NtK) issued by UKCPS fails to comply with
the requirements of the Protection of Freedoms Act 2012 (PoFA).
UKCPS has already admitted in their correspondence that they are
no longer relying on PoFA to establish keeper liability and they
have changed their claim. This admission unequivocally confirms
that they acknowledge the PCN does not meet the statutory
requirements. Therefore, as a matter of law, the operator cannot
hold the registered keeper liable for this parking charge. The
appeal must be allowed.
UKCPS changed the PCN:
New claim: "Please be advised that this charge was issued under
the site's terms and conditions and not under the Protection of
Freedoms Act 2012 (PoFA)."
2.1. UKCPS has agreed with my appeal. The definition of
'relevant land' was amended by The Protection of Freedoms Act
2012 (Definition of Relevant Land) (Amendment) Order 2025 to
include railway land, and this amendment only came into force on
26th December 2025, and is not retrospective. This alleged
parking event took place on 10th December 2025, before the
amendment came into force.
3.
UKCPS: "It is a contractual notice directed at the driver of the
vehicle for stopping in a prohibited area. Under this framework,
liability is assumed to rest with the registered keeper unless
evidence is provided to show that they were not the driver".
question - can I say there was no valid contract? does the VCS
vs Edward evidence there was no contract or does signage only
make the contract?
3.1. There is no evidence the Keeper was the driver – Keeper
Cannot Be Held Liable.
(I found this from b789 for a different case, I have to be
cautious because their case involved a parking metre, different
to my case)
UKCPS has provided not provided any evidence whatsoever that the
appellant was the driver at the time of the alleged
contravention. The appeal made it clear that the identity of the
driver has not been disclosed, and UKCPS has not disputed this
or provided any evidence to the contrary.
3.2. This leaves the operator with just one legal route: to
pursue the registered keeper under Schedule 4 of the Protection
of Freedoms Act 2012 (PoFA). However, that mechanism only
becomes available if the operator fully complies with every
single mandatory condition set out in PoFA. UKCPS has now
confirmed that the initial claim was not PoFA compliant,
therefore the UKCPS has no legal route to pursue the registered
keeper. The appeal must be allowed.
3.3. It is not appropriate to draw an inference that, on
balance of probability, the registered keeper was driving on any
given occasion. As explained in caselaw VCS v Edward H0KF6C9C
[2023], the keeper’s refusal to identify the driver does not
permit any assumption of driver identity. With PoFA compliance
withdrawn by UKCPS, the only remaining option would be to prove
— with actual evidence — that the keeper was also the driver.
They have not done so. There is no legal presumption that the
keeper was the driver. UKCPS has made no attempt to rebut this
point, nor have they presented any evidence to support such an
inference. The appeal must be allowed.
3.4. The UKCPS assessor who is supposedly legally qualified,
should have considered, if such an assumption could be made that
liability is assumed to rest with the registered keeper, why
does PoFA exist?
3.5. If the owners of the land, Leeds Station, wanted to hold
owners or keepers liable under Railway Bylaws, that would be
within the landowner's gift and another matter entirely.
However, not only is that not pleaded, it is also not legally
possible because UKCPS is not the station owner and the UKCPS
'parking charge' is not and never attempts to be a penalty. The
appeal must be allowed.
3.6. IAS is not entitled to make assumptions in the operator’s
favour, nor is it permitted to apply a lower evidential
threshold than the law requires. Keeper liability only arises if
PoFA is complied with. It is not a default position, and it does
not arise by implication. Accordingly, the only lawful
conclusion is that UKCPS cannot pursue the appellant as keeper.
There is no PoFA compliance, no driver identification, and
therefore no legal basis for continuing enforcement of this
charge. The appeal must be allowed.
4.
UKCPS has changed the NtK - "The Notice to Keeper (Non-ANPR)"
(Note: I don't know what to say about this? Do I need to say
something?
I found some sentences from b789 on a different case involving
"paying for parking" (different claim), but it applies to ANPR,
not "non-ANPR)
(is this relevant here? I did not mention this in my appeal):
(found a quote from b789: 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). is that the wrong CoP, should it be IPS?
5.
UKCPS claim: "The charge was issued correctly in accordance with
site regulations and the IPC Code of Practice and remains valid
and enforceable".
5.1. Signage and the claim that the charge is based on
Contract.
The IAS assessor must consider that the initial claim of 'No
Stopping' and the new claim of "the charge is based in Contract,
a contractual notice directed at the driver of the vehicle for
stopping in a prohibited area" are not supported by the road
markings which is in direct contravention of the IPC Code of
Practice which specifically states:
"Signs and surface markings must be designed, applied and
maintained in such a way as to be visible, legible and
UNAMBIGUOUS TO DRIVERS."
The charge has not been issued correctly, it is not valid and it
is not enforceable. The appeal must be allowed.
(Note: For a driver to have agreed to any contractual terms, the
signage must have been legible, prominently positioned, and
capable of being read before entering into a contract = I have
left this out???)
5.2. The IAS assessor must consider the contradictory signage/
road markings. The driver is stopped briefly on double yellow
lines which the law allows - only double reds can mean no
stopping. The appeal must be allowed.
5.3. The CPN is created for UKCPS’s own profit (as opposed to a
bylaw's penalty that goes to the public purse) and UKCPS has
relied on contract law allegations of breach against the driver
only.
6.
No evidence of Landowner Authority - the operator is to provide
strict proof of full compliance with the IPC Code of Practice.
???
Flawed Assumption Regarding Signage and Landowner Authority ???
6.1. The operator has provided an undated site plan, the date
of July 2025 is in the file name only which can be changed at
the users' discretion. (Valid?)
(Note: all wording provided by b789 in another case with edits
relevant to evidence provided to me. I do not know how much of
this (if any) applies to me? I did not cover signage in my
appeal, but since then the PCN has changed substantially and is
more focused on the Contract now. All the evidence photos
submitted by UKCPS to me for my appeal are dated 24/07/2025 and
27/07/2025. Is this timescale relevant? Because I am raising
signage now, do I need to return to the UKCPS (not arbitration?)
6.2. They have provided signage templates and in location
photographs of signage all digitally dated 25th and 27th July
2025, but no photographs showing how the signs actually appeared
on-site at or around the date of the alleged contravention on
10th December 2025.
6.3. There is no evidence the signage was present, visible, or
reflected any landowner-approved terms at that time.
(Note: there is no signage in the photos of my vehicle. They
have sent me many generic photos of locations with signage and I
do not know how close signage was to my vehicle).
6.4. They have not shown that the signage was authorised by the
landowner, nor that it matched any valid, current agreement. A
layout plan that is not dated on the template and file images of
signs for a different time period, prove nothing in isolation.
6.5. It is inappropriate for IAS to assume that signage is
valid or authorised simply because it exists. Contracts often
remain static while terms change — such as grace periods, charge
levels, or maximum stay durations — and if the signage was
updated without a revised landowner agreement, then the operator
is enforcing terms never approved. The appeal must be allowed.
7.
Shambolic operator in breach of Codes of Practice
7.1. By sending me an initial NtK which states PoFA, keeper
liability is unlawful in situations where PoFA cannot apply,
this is clearly evidence of UKCPS having haphazard methods of
running their enforcement operations at this site. It is
totally unprofessional and a breach of their Code of Practice.
The appeal must be allowed.
7.2. The NtK is not supported by the road markings of yellow
double lines which is in direct contravention of the IPC Code of
Practice.
7.3. Further evidence of unprofessionalism and breach of UKCPS:
UKCPS has contradicted the DVLA Code of Practice. The IAS
assessor must consider that operators are not allowed to claim
that they can rely on PoFA in situations where they can not when
making requests to the DVLA for the registered keeper's details.
In this case, a parking contravention has not occurred.
question - can I say lack of "reasonable cause" to contact the
DVLA?
question - and requesting data when no contract was formed?
question - can they be reported?
8.
In short, I dispute this charge in its entirety, primarily based
on the operator not showing that the individual who it is
pursuing is in fact the driver. I require full evidence of
compliance with the law, industry codes of practice, and basic
contractual principles. (question - is this point only valid for
the UKCPS or is it ok for arbitration?)
If the assessor chooses to overlook these legal requirements and
accept vague assertions about no stopping violations and
unhelpful dated photographs from the operator, then this will
lend further weight to the growing concern that this appeals
service is neither independent nor genuinely legally qualified.
An erroneous and non valid NtK was issued to me and this case
now needs to stop.
---------
The End
---------
There must be a lot to correct and improve on this draft. I
hope someone can help.
#Post#: 108871--------------------------------------------------
Re: UKCPS Leeds Station - Notice to Keeper (Postal-PoFA) - no
recollection of stopping
DIR By: Snapp1e
Date: February 5, 2026, 7:21 pm
---------------------------------------------------------
ignore the emojis in my draft reply.
i did not insert any emojis. they have appeared when i have
done a copy and paste into here.
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