UKPC ticket whilst driver was delivering parcels on moat lane, nine elms.

[b789]

@zyno, having reviewed both sides of the Notice to Keeper (NtK), there are several grounds on which to challenge UKPC's parking charge.

First, however, an important distinction:

The driver is NOT appealing. The appeal must be submitted ONLY by the registered keeper.

UKPC has absolutely no idea who the driver was. Do not assist them by identifying the driver, either directly or inadvertently.

The driver and the registered keeper are two legally distinct capacities. There is no legal obligation on the keeper to identify the driver to an unregulated private parking company.

Parliament enacted Schedule 4 of the Protection of Freedoms Act 2012 (PoFA) to provide private parking operators with a statutory mechanism for pursuing registered keepers where the driver's identity is unknown. However, that mechanism is only available where the operator complies with the relevant statutory requirements.

UKPC cannot simply disregard those requirements and presume that the keeper was driving.

The NtK raises concerns regarding the statutory warning under paragraph 9(2)(f), the specification of the period of parking under paragraph 9(2)(a), and whether the alleged conduct amounts to a contractual breach at all.

I suggest submitting the following appeal through UKPC's online appeals portal, selecting Registered Keeper as the appellant and ensuring nothing in the submission identifies the driver.

Re: Parking Charge Notice [reference number]

I am the registered keeper of the vehicle identified in your Notice to Keeper dated 30 September 2026. I dispute the parking charge and require its cancellation.

1. Failure to establish keeper liability under Schedule 4 of the Protection of Freedoms Act 2012

Your Notice to Keeper does not adequately comply with the mandatory requirements of Schedule 4 of the Protection of Freedoms Act 2012 (PoFA).

In particular, the warning concerning keeper liability under paragraph 9(2)(f) appears to misrepresent the cumulative statutory conditions through its use of alternative wording.

PoFA requires that the parking charge remains unpaid and that the creditor does not know both the name of the driver and a current address for service before the statutory warning can operate as prescribed.

The notice fails to reproduce those conditions correctly. Consequently, you have not established any entitlement to recover the charge from me as registered keeper.

2. Failure to specify the period of parking – paragraph 9(2)(a)

Your notice states that the recorded duration of stay was 12 minutes and 31 seconds.

However, it does not specify the actual period of parking to which the charge relates, as expressly required by paragraph 9(2)(a).

A recorded duration of presence on the site is not necessarily evidence of a period of parking, particularly where the alleged contravention concerns a roadway.

3. No demonstrated contractual liability

The allegation is described as "Parked in a roadway".

You have provided no adequate evidence that the terms displayed at the location offered a contractual licence to park on the roadway, that those terms were capable of acceptance in the circumstances, or that any enforceable contractual obligation arose.

If the signage prohibits parking on the roadway, rather than offering parking subject to payment of a specified charge, you must explain the contractual basis on which you contend that the parking charge is recoverable.

4. No presumption that the registered keeper was the driver

The identity of the driver has not been established. There is no statutory presumption that the registered keeper was driving, nor any obligation on the keeper to identify the driver.

Any attempt to impose keeper liability must therefore satisfy the applicable requirements of PoFA.

I require you to cancel this parking charge. Should you refuse, provide a POPLA verification code so that the matter may be considered independently.

Submit the appeal without adding any explanation of who was driving, why the vehicle was present or what occurred at the location.

If UKPC rejects it (almost certainly), the next stage is POPLA, where we can develop the statutory and contractual arguments using the operator's evidence.

If possible, I would also like to see photographs of the actual roadway signage, particularly the wording concerning prohibited parking. That may provide another substantial ground of appeal independently of PoFA.