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       #Post#: 107107--------------------------------------------------
       Parking Charge @ Brockwell Lido, Herne Hill SE24
       By: nasmin Date: January 23, 2026, 9:34 am
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       Hello
       I hope you can help.
       The driver has received a PCN for a failure to pay for duration
       of stay at Brockwell Lido. Images of the PCN below.
       [img width=135
       height=180]
  HTML https://i.postimg.cc/QK3fBbX2/IMG-4983.jpg[/img]
  HTML https://postimg.cc/QK3fBbX2
       [img width=135
       height=180]
  HTML https://i.postimg.cc/k2pwN9Jv/IMG-4984.jpg[/img]
  HTML https://postimg.cc/k2pwN9Jv
       Things to note which may help
       1. The signs have been up requiring payment for car parking
       2. The driver has used the car park for the past two / three
       years and as is common practice not registered on the app (there
       is two hours free parking) and has never received a notification
       or PCN
       3. On the day in question - the driver was blocked in by another
       car and couldn't get out. In the end had to leave and return
       later and get help from the member of the gym to reverse the car
       out as the other car had not moved.
       Thank you
       #Post#: 107301--------------------------------------------------
       Re: Parking Charge @ Brockwell Lido, Herne Hill SE24
       By: Hippocrates Date: January 25, 2026, 8:45 am
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       @b789 Please can you help?
       #Post#: 107351--------------------------------------------------
       Re: Parking Charge @ Brockwell Lido, Herne Hill SE24
       By: RichardW Date: January 26, 2026, 1:12 am
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       Plan A should be to approach the Lido and see if they can
       arrange cancellation.
       If not, in this case there appear to be shortcomings in the NTK
       that would prevent transfer of liability (no identification of
       the creditor, and the warning paragraph per 9.1.f of POFA is not
       present).  So a 2 pronged appeal to Gemini on the basis of
       frustration of contract (i.e. you wanted to leave but were
       prevented from doing so by factors beyond your control) and that
       the NTK is not compliant with POFA to transfer liability looks
       in order.  They are unlikely to cancel it however, and they are
       IPC so appeals are to IAS - who almost never uphold appeals, so
       don't get your hopes up.
       If Plan A and the appeal fails, then you will have to weather
       the storm of debt collection letters, and wait for a court
       claim, which is usually easily defended.
       #Post#: 107370--------------------------------------------------
       Re: Parking Charge @ Brockwell Lido, Herne Hill SE24
       By: nasmin Date: January 26, 2026, 5:44 am
       ---------------------------------------------------------
       Thank you for your response. It is much appreciated.
       I have spoken to the Lido and they unfortunately stated that the
       car park is nothing to do with them, so cannot cancel the
       ticket.
       Based on the previous entries to Gemini I wonder if you could
       comment on whether the following is a suitable response.
       I am the keeper of the vehicle and I dispute your 'parking
       charge' on two points. I deny any liability or contractual
       agreement and I will be making a complaint about your predatory
       conduct to your client landowner.
       1.
       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. Gemini 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
       a poor interpretation of the law of agency. Your NtK can only
       hold the driver liable. Gemini will not be successful in any
       litigation, so are  urged to save time and cancel the PCN.
       2.
       Contract in their defence. The contract was formed between the
       Claimant and the driver, in which the Claimant granted the
       consideration of free parking for 120 minutes, in return for a
       promise to leave within 120 minutes on the part of the driver.
       There was, in this case, a change in circumstances which was not
       the fault of either party, and which rendered it impossible for
       the driver to perform the contract. Specifically, the driver was
       blocked by another driver from exiting the car park and sought
       to find said driver without success (in the nearby facilities).
       Where a contract is found to be frustrated, each party is
       discharged from future obligations under the contract and
       neither party may sue for breach. The allocation of loss is
       decided by the Law Reform (Frustrated Contracts) Act 1943, but
       in this case there was no loss to the Claimant at the time the
       contract was breached, and so they have no valid claim for £100
       or any amount at all. The case of Nicholl and Knight v Ashton,
       Eldridge & Co [1901] 2 KB 126 provides authority for this.
       #Post#: 107794--------------------------------------------------
       Re: Parking Charge @ Brockwell Lido, Herne Hill SE24
       By: nasmin Date: January 28, 2026, 4:17 pm
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       Hello - just following up to see if there were any comments on
       the proposed response. Thank you in advance
       #Post#: 107799--------------------------------------------------
       Re: Parking Charge @ Brockwell Lido, Herne Hill SE24
       By: DWMB2 Date: January 28, 2026, 5:17 pm
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       That should do as an initial appeal.
       #Post#: 107801--------------------------------------------------
       Re: Parking Charge @ Brockwell Lido, Herne Hill SE24
       By: nasmin Date: January 28, 2026, 5:19 pm
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       Thank you kindly
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