This case concerns a Parking Charge Notice (private parking firm) issued by Total Parking Solutions Ltd, relating to an alleged contravention on Thursday, 09 October 2025. The notice itself is dated Friday, 17 October 2025, and I first became aware of it via received initial notice.
The notice appears to have been issued as By post (ANPR/camera). Driver identified status: NO. Equality Act considerations: No. The location is stated as St Mary's Medical Centre, Stamford, PE9 2DH.
A preliminary Protection of Freedoms Act (PoFA) assessment indicates COMPLIANT: Likely PoFA timing compliant for paragraph 9 (postal NtK, no windscreen NtD). Route applied: PoFA paragraph 9 (postal NtK, no windscreen NtD). The notice is treated as given on Tuesday, 21 October 2025 (12 days after the alleged event).
Current stage:
- Notice responded to: Yes
- Debt recovery letters: Yes
- Letter of Claim: No
- County Court claim: No
= = = = = =
Response/appeal already sent (verbatim where possible):
‘Parking Charge’, ref: AT [XXXXXXX]
I am the keeper of the vehicle, and I dispute your 'parking charge'. I deny any liability or contractual agreement and 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. TPS 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 warped interpretation of the law of agency. Your NtK can only hold the driver liable.
I appeal / challenge the “Parking Charge”, ref: AT5144746, on the grounds that:
[1] The Parking Charge notice is not POFA compliant
I additionally appeal on the grounds that:
[2] Unfair / Unclear term: lack of transparency of qualifying condition
[3] Proof & Signage: No proof of parking
[4] Entitlement to park
Further detail:
[1] The Parking Charge notice is not POFA compliant
1.1 The Parking Charge letter, sent to the Registered Keeper, fails to “specify the period of parking” (POFA Paragraph 9, (2)(a)). The letter shows “observation times” rather than a “period of parking”, which falls short of the statutory wording and intent.
1.2 The Parking Charge letter, sent to the Registered Keeper, fails to invite the Registered Keeper to pay the parking charges sought; which is required by POFA (POFA Paragraph 9, (2)(e)(i)).
1.3 The Parking Charge letter, sent to the Registered Keeper, asserts that liability lies with the Driver. There is no statutory warning per POFA Paragraph 9, (2)(f). The letter is non-compliant with the requirements of POFA.
I submit that any of these three failures to be fully POFA compliant is sufficient reason for this Parking Charge notice to be cancelled; the three together makes it even clearer. Partial or even substantial compliance with POFA is not sufficient.
I also submit that this Parking Charge should be cancelled on any of the following grounds:
[2] Unfair / Unclear term: lack of transparency of qualifying condition
If users of the car park must enter the Vehicle Registration Mark at the reception desk, this is a “qualifying condition” for parking. Details must be prominent at the point of decision, but the signage does not make this clear. The qualifying condition / term was not adequately brought to the attention of the driver (see Consumer Rights Act 2015, transparency & prominence)
[3] Proof & Signage: No proof of parking
The Parking Charge letter, and TPS’ online portal, show only ANPR-style images at entry and exit. TPS has not shown that the vehicle was parked in a location to which terms applied, nor provided firm evidence for a ‘period of parking’. The breach and applicable sign for the location have not been proven. The vehicle was not left unattended, and no contract was formed.
[4] Entitlement to park
Even if ‘parked’ (which is not admitted), the driver was a Patient, and thus had entitlement to free parking. Any breach was caused by the parking operator’s failure to signpost the Vehicle Registration Mark entry process adequately.
Please confirm that this Parking Charge has been cancelled.
Yours, etc.
= = = = = = = = = = = =
Additional notes provided:
Additional information - where we are:
- POPLA appeal was pursued on the same grounds as the initial appeal to TPS. POPLA rejected (unsurprisingly, I suspect)
- there followed three or more debt reminder / please pay letters
- and now a letter from "Oak Legal Services", adding some processing costs on, and threatening with imminent Court action
Additional information - appeal points:
- I am not certain that the NtK has a POFA failure of mandatory warning under (9)(2)(f) (para on the right seems to cover it)
- on the appeal's additional grounds, I think I'd now rely on the driver (or other vehicle occupant) being a "visitor" rather than a "patient"; while the latter is arguably true in a broad sense, the former - a visitor - is undeniably true, and I'd suggest is self-evidently true by the very fact of being there...!
I have attached images of the initial NtK, and the current Oak Legal letter, for reference.
Please can I have advice on the strongest next steps and defence points for this case.
(Should I reply to "Oak Legal" to re-outline the grounds, if only to demonstrate "I tried" to a court, should it come to that, or to make it clear to them that I intend to fight (unless you advise otherwise!) and they may as well discontinue?)
Welcome to the forum @Alexander6. The Oak Legal letter is not a Letter of Claim. It is just another debt-collection letter, and Oak Legal Services is a trading name of ZZPS Limited, a bunch of utter shysters.
Do NOT respond to that letter. The more important action is an immediate complaint to St Mary's Medical Centre requesting cancellation.
1. PoFA position
The original appeal overstated the PoFA defects.
Paragraph 9(2)(f): the NtK appears compliant. The paragraph beginning "IMPORTANT NOTE" contains the required warning that, after 28 days, TPS may recover the unpaid amount from the keeper if the driver remains unidentified.
Paragraph 9(2)(a): "observation times" and a stated 23-minute duration may technically be challenged as ANPR records vehicle movement rather than an actual period of parking. However, a court may consider that wording sufficient. It is not a particularly strong standalone defence.
Paragraph 9(2)(e): this remains arguable. The NtK says that if the recipient was the driver, they should pay; otherwise, they should identify the driver. It does not clearly invite the keeper, in their capacity as keeper, to pay the charge. The statutory requirement is to invite the keeper either to pay or, if not the driver, provide the driver's details. PoFA Schedule 4, paragraph 9
So, TPS appears to have complied with paragraph 9(2)(f), but keeper liability remains disputed because the NtK arguably fails paragraph 9(2)(e), and TPS must prove strict compliance with every applicable requirement of Schedule 4.
Do not continue asserting that the NtK contains no paragraph 9(2)(f) warning. That would undermine the more credible arguments.
2. The most important immediate step: contact the surgery
Stamford Surgery publicly states that its ANPR system exists to protect spaces for "patients and visitors", and that both groups must register within ten minutes.
More significantly, in May 2026 the surgery acknowledged that genuine visitors had received PCNs despite entering their registration details, referred to a possible TPS software problem, and expressly instructed affected visitors to contact the practice for assistance. Surgery statement concerning erroneous PCNs
Quote:Parking charges
We are aware that some patients have unfortunately received parking fines when visiting our practices, despite entering the correct registration details at reception.
We are working closely with Total Parking Solutions to find the cause, which could be a software issue due to a recent update on their system. If you get a fine following an appropriate visit to either Sheepmarket or St Mary’s please contact the team who will be able to assist further.
We are urging TPS to remedy the situation as quickly as possible as we know how frustrating an unwarranted parking fine can be.
Thanks for bearing with us while we work hard to find a resolution.
Published: May 22, 2026
That statement does not prove that the same software problem existed in October 2025, but it demonstrates that:
registration failures have occurred;
the practice can intervene despite previously claiming otherwise; and
TPS's registration records cannot simply be treated as infallible.
The complaint should identify exactly why the vehicle was there, who was visiting the premises, and whether anyone attempted to register the VRM. Evidence of the visit should be included if available.
Email the medical centre the following:
Quote:Request for cancellation of TPS parking charge AT5144746
Dear Practice Manager,
I am asking the practice to instruct Total Parking Solutions to cancel Parking Charge AT5144746, arising from a genuine visit to St Mary's Medical Centre on 9 October 2025.
The vehicle was present for only 23 minutes in connection with a genuine visit to the premises. It was not being used for unrelated town-centre parking.
The practice's published information confirms that the car park is provided for patients and visitors. The practice has also subsequently acknowledged that genuine visitors have received parking charges because of apparent problems with TPS's registration system and has asked affected visitors to contact the practice for assistance.
Please therefore check the practice's attendance and registration records and instruct TPS to cancel this charge. It would be wholly disproportionate for a genuine short visit to the medical centre now to result in a threatened county court claim for £170.
Please confirm once the cancellation instruction has been issued.
Yours faithfully,
[Name]
Adapt the factual paragraph accurately. Do not claim the VRM was entered unless somebody actually entered or attempted to enter it.
3. "Visitor" is not, by itself, a defence
I would not argue that entitlement is "self-evidently" established merely because somebody was a visitor. TPS would say that visitors were permitted to park only if they registered within ten minutes.
The relevant arguments are instead:
the vehicle was present for an authorised purpose;
whether the registration obligation was sufficiently prominent before parking;
whether the obligation and consequences were clearly communicated at the entrance and at the point where registration was required;
whether registration was attempted or completed;
whether TPS's system correctly retained and matched registrations; and
whether imposing £100 for an innocent or inadequately communicated registration failure was disproportionate and unfair under the Consumer Rights Act 2015.
If the driver remained in the vehicle while an occupant visited the surgery, that does not necessarily mean that the vehicle was not "parked". That argument should not be treated as a principal defence.
4. Defence points if a claim is eventually issued
Subject to seeing the POPLA evidence pack and actual signs, the likely defence would include:
No driver admission and no presumption that the keeper drove.
Strict proof of full PoFA compliance, particularly paragraph 9(2)(e).
Inadequate notice and prominence of the VRM-registration requirement and £100 consequence.
Genuine authorised visit and failure of the registration arrangements.
Strict proof of the accuracy and completeness of TPS's registration and ANPR records.
No proof of TPS's landowner authority to contract, enforce and litigate.
Consumer Rights Act 2015 transparency, prominence and fairness.
The additional £70: no proven loss, no properly incorporated contractual entitlement, double recovery, and the PoFA paragraph 4(5) keeper-liability ceiling.
Deficient Particulars of Claim, if TPS eventually issues the usual generic contractual allegations.
The POPLA evidence pack, POPLA decision, photographs of every sign and the exact circumstances of the visit will determine whether signage/system failure or the technical PoFA point should lead the eventual defence. On the current material, landowner cancellation is considerably more promising than another substantive exchange with Oak.
Can you post the POPLA response (please break it into readable paragraphs) and the name of the assessor.
Never argue with stupid people. They will drag you down to their level and then beat you with experience. - Mark Twain
Thank you for your welcome, @b789 , and thank you for your comprehensive reply too.
The POPLA response (broken up!) is below, and I've attached copies of the signage (images S1 and S5) which TPS submitted to POPLA. Their images date from 2024 (a year + before the alleged contravention), and I have not, yet, verified the signage in place, though I can arrange to do so.
In terms of signage clarity, I propose that "S1" is a very clear "Patient and Visitor Only" sign, which makes no mention of registration using a separate system inside. A reasonable driver, having noticed this sign, would only glance at the second "S5" sign, see the same information repeated in large text at the top, and not read the screed of smaller text underneath. The need to 'book in' at all, let alone inside, is not sufficiently clear (CRA 2015). Would you agree?
Two things, if I may...
- Patient/Visitor: if I had had sight of the signage when submitting the original appeal to TPS, I would have stated "visitor" rather than "patient", both being permitted from the signs. I shifted to include "visitor" for POPLA.
The medical practice in question is an NHS practice, and the driver (or occupant) an NHS patient, who is thus entitled to be treated at that practice should the need arise. They were not, however, visiting on a pre-booked appointment, nor are registered at that practice for routine care. I don't want to get too deep in to "what is a patient" as it could be pages of text to work that out: so "visitor" seems simpler, since they were visiting.
Clearly it should be possible to park at the practice without a pre-booked appointment or invitation to visit (even a registered patient (or someone on their behalf) might need to call in to ask for a fresh sample pot, a form, a repeat prescription, f.e.).
- Appeal to the Practice: Kudos to your knowledge of the known (and admitted) issue with the TPS system at this specific practice!
It might well be worth a request to them directly. However, given the above, I am not sure this is likely to lead anywhere - i.e. there is no appointment for a registered patient which they can easily reference on their system to tally with the visit. There is the potential risk, if the practice are engaged in internal correspondence with TPS, that they reveal the identity of the driver (if the practice requested that information in order to look further at the parking charge). I will write a fairly generic note (as RK) and see if this helps matters.
Aside from a generic note to the practice, I think that POFA failure under (9)(2)(e)(i), and less importantly (9)(2)(a), should, in theory, be enough for dismissal - it's a failure of full compliance, let alone strict compliance. Anything else argued should not be required to be considered, as their case should fall at this first hurdle. Or am I overly optimistic?
Assessor Case Summary: The appellant has provided the following grounds of appeal: • The Notice to Keeper issued by the operator does not fully comply with all the requirements of PoFA 2012. As such, the operator is unable to hold the keeper of the vehicle liable for the charge. • The operator’s signage is not clear. • The PCN and TPS portal only show ANPR entry/exit images. TPS has not proven the vehicle was parked where terms applied or evidenced a ‘period of parking’. The breach and relevant signage remain unproven, the vehicle was not left unattended, and no contract was formed. • Even if ‘parked’ (which is not admitted), a "visitor or patient" was present, and thus had entitlement to free parking. Any breach was caused by the parking operator’s failure to signpost the Vehicle Registration Mark entry process adequately.
The appellant has provided comments in response to the operator’s case file including the following summary: The Operator’s failure to fully comply with the statutory requirements of POFA (2012) Paragraph 9 – which the Operator does not dispute - is sufficient reason for this Parking Charge to be cancelled. With the additional factors noted also taken into account, it is proportionate and reasonable that the appeal should be allowed, and the Parking Charge cancelled.
Assessor supporting rational [sic]:
When assessing an appeal POPLA considers if the operator has issued the parking charge notice correctly and if the driver has complied with the terms and conditions for the use of parking on the site. The appellant states that the PCN is not PoFA compliant and The Protection of Freedoms Act (PoFA) 2012 is a law that allows parking operators to transfer the liability to the registered keeper in the event that the driver or hirer is not identified. In this case, it is not clear who the driver of the appellant’s vehicle is, so I must consider the Protection of Freedoms Act (PoFA) 2012, as the operator issued the Parking Charge Notice (PCN) to the keeper of the vehicle.
The operator has provided me with a copy of the notice to keeper sent to the appellant. I have reviewed the notice to keeper against the relevant sections of PoFA 2012 and I am satisfied that it is compliant in all aspects. I will therefore be assessing keeper liability.
The Private Parking Sector Single Code of Practice (The Code) sets the standards its parking operators are required to comply with. Section 3.1.3 of the Single Code of Practice contains the requirements for signs displaying the terms and conditions. The signs must be placed throughout the site, so that drivers have the opportunity to read them when parking or leaving their vehicle. The terms and conditions must be clear and unambiguous, using a font and contrast that is be conspicuous and legible. The operator has provided evidence of the signage on the site and this advises the following : Patient and visitor parking only, This car park is monitored using Automatic Number Plate Recognition cameras and Parking Attendants, 24 hours a day 7 days a week, Patients and visitors must validate their parking inside the surgery, Failure to comply will result in a Parking Charge of £100. Due to the above I am satisfied that the signage on the site complies with Section 3.1.3 of The Code.
The appellant states that the ANPR does not prove parking. The site operates Automatic Number Plate Recognition (ANPR) cameras, which capture vehicles entering and exiting the site to calculate the time a vehicle has remained in the car park. This data captured is then compared with the online transaction record, and therefore if no permit can be located for the correct vehicle registration, a PCN is issued. The operator has provided evidence of the vehicle parked on the site for 23 minutes on the day in question. The appellant has advised that they had not parked on the day and Section 2.19 and 2.24 of the code clarifies what constitutes parking. This defines parking as the length of time a vehicle remains on controlled land, including the consideration period. A vehicle may be classed as parked even if the driver stays inside, keeps the engine running, or once the consideration period has ended. Parking is simply a vehicle being stationary other than in the course of driving. Independent research shows ANPR is generally reliable, but POPLA sometimes receives appeals alleging errors. POPLA assesses whether any evidence casts doubt on ANPR accuracy. The operator must first prove the PCN was issued correctly; if it does, the burden shifts to the appellant. If the appellant provides evidence or an account that challenges the ANPR’s reliability, the assessor decides whether this is sufficient. Physical evidence, such as receipts showing the appellant was elsewhere, is usually most persuasive.
The appellant has stated that they were entitled to park and The Appeals Charter is a statement on how certain circumstances should be handled by the parking operator. This details when a parking charge should be cancelled, and when a parking charge should be reduced to £20, when an appeal is based on an error or mitigating circumstances. Section F.3 of the Code lists specific circumstances where a parking operator must reduce a PCN to £20, subject to appropriate evidence being provided. It is noted that it may be appropriate for evidence to be requested where it is lacking before the parking operator finalises their decision. In this case no evidence was provided to the parking operator during these initial stages, nor was it provided when requested by the operator. Due to this I am satisfied that the operator is not required to reduce the charge to £20.
The operator has issued the Parking Charge Notice (PCN) because the driver parked on the site without a permit and therefore did not comply with the terms and conditions. Based on the evidence provided, I am satisfied the parking charge has been issued correctly therefore, I must refuse the appeal. This means the appellant is required to pay the full parking charge to the operator. = = = = = = = = = = = =
Thanks for that @Alexander6. Based on the POPLA assessors points and the signs you have shown, I would not put the signage argument quite as strongly as proposed. On the two photographs alone, the terms sign is not an especially weak contractual sign.
The entrance sign clearly says:
"TERMS AND CONDITIONS APPLY — SEE NOTICES IN THE CAR PARK FOR MORE DETAILS"
A reasonable driver therefore cannot safely rely on "Patient & Visitor Parking Only" while choosing merely to glance at the detailed sign. On the terms sign, the requirement:
"Patients and Visitors must validate their parking inside the surgery"
is not buried in the tiny legal screed at the bottom. It appears in the main conditions section, alongside a parking symbol, with the £100 consequence displayed very prominently below it. If the terms sign was adequately positioned and visible, a judge could readily find the registration term sufficiently prominent under section 68 CRA 2015.
The better signage challenge is therefore evidential and contextual, rather than pretending the wording cannot be read:
TPS's photographs are dated 28 March 2024, over 18 months before the alleged event.
They do not prove which signs remained in place on 9 October 2025.
They do not prove the number or distribution of signs.
They do not show the relationship between the entrance, the route taken, the parking bay and the terms sign.
the entrance sign does not itself state that registration is required.
TPS must prove that a driver entering and parking where this vehicle did had a reasonable opportunity to encounter and read the terms sign before becoming contractually bound.
Any material difference between the 2024 photographs and the signs actually present in October 2025 damages TPS's evidence substantially.
So yes, arrange contemporary photographs, but they need to cover the whole driver's route, not merely close-ups:
the entrance from the approaching driver's viewpoint;
every sign visible while entering;
the route to the relevant parking position;
the view from that position;
distances and sign heights;
any reception or internal registration notices; and
whether the sign layout has changed since TPS's photographs.
Patient or visitor
"Visitor" is the factually cleaner description if an occupant genuinely entered the medical centre for some legitimate purpose. A visitor need not have a pre-booked appointment or be registered as a patient at that practice. Someone may legitimately call in to make an enquiry, deliver or collect something, accompany another person or deal with an administrative matter.
However, the signs do not confer unconditional parking merely because someone qualifies as a visitor. They purport to permit patient and visitor parking subject to validation inside the surgery. Therefore:
visitor status establishes that the vehicle belonged to the permitted user class;
it does not, by itself, answer the alleged failure to validate;
the defence then turns on whether that additional condition was adequately communicated, whether validation was attempted, whether the system worked correctly and whether TPS can prove its records are complete.
I would avoid the statement that an occupant was an NHS patient who was entitled to treatment "should the need arise". That sounds artificial and is unnecessary. Either an occupant genuinely visited the surgery for an identifiable purpose or they did not. The actual purpose need not involve an appointment, but it should not be obscured by an abstract debate about who counts as a patient.
Complaint to the practice
There is no need to identify the driver. The registered keeper can say:
"The vehicle was present in connection with a genuine visit to the practice by an occupant. I am the registered keeper and request that the practice instruct TPS to cancel the charge."
If further detail is necessary, it can be provided in terms of "an occupant". The practice cannot disclose the driver's identity to TPS unless it knows who drove; identifying an attendee or patient does not necessarily identify the driver.
The practice complaint remains worthwhile because cancellation is the only useful intervention at this stage. Oak/ZZPS should, of course, be completely ignored.
PoFA: strong enough to defeat keeper liability?
Yes. As a matter of law, the paragraph 9(2)(e) failure is fatal to keeper liability.
PoFA does not impose liability upon a registered keeper merely because the parking operator has made a reasonable attempt to follow Schedule 4. Paragraph 4 permits recovery from the keeper only where ALL the applicable conditions have been met. Paragraph 9(2) expressly provides that the Notice to Keeper must contain the prescribed information.
Paragraph 9(2)(e) requires the NtK to:
state that the creditor does not know both the name of the driver and a current address for service for the driver; and
invite the keeper either:
to pay the unpaid parking charge; or
if the keeper was not the driver, to notify the creditor of the driver's name and current address for service and pass the notice to the driver.
TPS's NtK does not comply:
It says "Where we do not know…", which merely describes a conditional situation. It does not state the required fact that the creditor does not know both the driver's name and a current address for service.
Its payment instruction is expressly directed only to the recipient "if you were the driver".
It does not invite the recipient to pay the charge as keeper, as paragraph 9(2)(e)(i) requires.
If the recipient was not the driver, TPS directs them only to provide the driver's details.
That is not a minor defect or an alternative form of the prescribed invitation. It is the omission of mandatory statutory information.
Compliance with Schedule 4 is binary. Just as a person cannot be partially pregnant, mostly pregnant or substantially pregnant, a Notice to Keeper cannot be partially, mostly or substantially compliant with PoFA. It either satisfies every applicable mandatory requirement or it does not. The Act contains no saving provision allowing keeper liability where an operator has conveyed what it considers to be broadly similar information.
TPS has failed paragraph 9(2)(e). Consequently, it cannot exercise the right under paragraph 4 to recover the charge from the keeper. The unidentified driver might potentially remain liable, but the keeper cannot be made liable merely because TPS does not know who that driver was.
POPLA's bare assertion that the NtK is "compliant in all aspects" does not identify, analyse or answer the specific paragraph 9(2)(e) failure. POPLA cannot repair a defective NtK or create keeper liability where Parliament has not conferred it. Its decision is not binding upon the keeper or any court.
No litigation outcome can be literally guaranteed because a judge must still identify and apply the law correctly. However, that does not make the underlying legal test uncertain: if the NtK fails any mandatory requirement of paragraph 9(2), there is no keeper liability. "Substantial compliance" is not an available halfway house.
Paragraph 9(2)(a) provides an additional, although less decisive, failure. TPS has supplied only ANPR entry and exit observation times and described the intervening 23 minutes as the "duration of stay". Those camera timestamps merely record the vehicle crossing two points; they do not specify the period during which it was actually parked. TPS has not identified or evidenced where within the car park the vehicle was allegedly parked. Consequently, it has established neither the route taken to that position nor the route subsequently taken by the driver to enter the medical centre.
Without that evidence, TPS cannot show which signs the driver would have encountered, whether any detailed contractual sign was visible from the parking position or route taken, or whether the validation requirement was displayed with sufficient prominence to bind that driver. Nevertheless, the paragraph 9(2)(e) failure is sufficient by itself, without reliance upon paragraph 9(2)(a).
Accordingly, the eventual defence points should be ranked as follows:
Failure to comply with paragraph 9(2)(e), defeating keeper liability.
Paragraph 9(2)(a): failure to specify the actual period of parking.
TPS's failure to prove the signs and layout existing on 9 October 2025, rather than in March 2024.
Failure to prove that the validation condition was adequately brought to the driver's attention along the actual route taken.
The genuine visitor status and legitimate purpose of the visit.
Strict proof of the completeness and correct operation of the registration system and its records.
TPS's landowner authority to contract, enforce parking terms and commence litigation.
The additional £70, including the paragraph 4(5) prohibition against recovering from a keeper more than the amount specified in the NtK.
POPLA's supposed finding that TPS "provided evidence of the vehicle parked on the site" should also be checked against the evidence pack. If TPS supplied only the two ANPR entry/exit images, that statement is factually wrong: those images establish presence between two timestamps, not where or for how long the vehicle was stationary.
The position now remains simple: complain to the practice, ignore Oak/ZZPS completely, obtain proper photographs, retain all evidence and respond only if a genuine Letter of Claim arrives.
A formal complaint to the Practice Manager is worthwhile because the medical centre is TPS's principal and can instruct it to cancel the charge. It should be made expressly by the registered keeper, without identifying the driver. The purpose is not to rehash the POPLA appeal but to require the practice to address the treatment of a genuine visitor and its agent's escalation of the charge.
Quote:Dear Practice Manager,
FORMAL COMPLAINT: TPS PARKING CHARGE AT5144746
I write as the registered keeper of the vehicle concerned.
On 9 October 2025, the vehicle was present at St Mary's Medical Centre for approximately 23 minutes in connection with a genuine visit to the practice by an occupant. It was not being used for unrelated parking. Nevertheless, Total Parking Solutions Ltd (TPS), acting as the practice's parking contractor, issued Parking Charge AT5144746 and is now demanding £170 through its debt-collection trading style, Oak Legal Services/ZZPS.
I ask that this correspondence be registered and investigated as a formal complaint concerning the actions of the practice's contractor.
The car park signage prominently describes the site as "PATIENT & VISITOR PARKING ONLY". The vehicle was present for precisely that permitted purpose. TPS alleges a failure to validate the vehicle inside the surgery, but the separate validation requirement was not stated on the prominent "Patient & Visitor Parking Only" sign.
TPS has produced only photographs of signage dated 28 March 2024, more than 18 months before the alleged event. It has not established:
what signs were actually present on 9 October 2025;
where within the car park the vehicle was allegedly parked;
the route taken to that position;
the route subsequently taken by the driver to enter the medical centre;
which signs would have been encountered along those routes; or
whether the validation requirement was sufficiently visible and prominent to the driver concerned.
The practice has subsequently published an acknowledgement that genuine visitors have received parking charges despite entering the correct registration details and that a TPS system problem may have been responsible. The practice invited affected visitors to contact it for assistance. Although that announcement postdates this particular incident, it demonstrates that the registration system and TPS's records cannot safely be treated as infallible.
The registered keeper also disputes TPS's entitlement to transfer liability under Schedule 4 to the Protection of Freedoms Act 2012. In particular, its Notice to Keeper does not comply with the mandatory requirements of paragraph 9(2)(e). However, the practice should not require a genuine visitor to defend threatened county court proceedings arising from its contractor's parking and registration arrangements.
TPS acts at the authority of the practice or its landowner. Any suggestion that the practice is unable to intervene would therefore be untenable: TPS's authority cannot exceed that of its principal, and the principal can instruct its agent to cancel a charge.
I therefore require the practice to:
instruct TPS immediately to cancel Parking Charge AT5144746 and remove the associated, unlawful £70 enhancement;
require TPS and ZZPS/Oak Legal Services to cease recovery activity;
investigate whether the registration system and signage were operating correctly on 9 October 2025;
confirm what signs were present on that date and when they were last inspected; and
provide a substantive written response under the practice's formal complaints procedure.
Please confirm that this complaint has been formally recorded and that the cancellation instruction has been issued to TPS.
