10-11-2026, 09:16 AM
@zyno, thanks for providing the reverse of the NtK.
Having now seen both sides, I cannot see anything that remedies the previously identified failure to specify a period of parking, as required by PoFA paragraph 9(2)(a). That remains a potentially decisive point concerning keeper liability.
However, I still need you to log on to the PPS website at www.paypps.co.uk and check whether there are any additional photographs of the vehicle. If there are any beyond the two reproduced on the NtK, please download them and post them here. I want to see the complete photographic evidence before drafting the keeper appeal.
You have also mentioned that the vehicle was stopped briefly to make an Amazon delivery. That raises another potentially important argument.
In Jopson v Homeguard Services Ltd [2016] B9GF0A9E, HHJ Harris QC distinguished temporary stopping for loading or unloading from parking. Making a genuine delivery would therefore provide an additional defence, depending on the circumstances.
Can you confirm approximately how long the vehicle was stopped and whether the delivery was to someone at Donnington House?
Finally, do not identify the driver to PPS. The keeper has no legal obligation to do so. Any appeal will be made solely in the capacity of registered keeper, relying primarily on PPS's failure to establish keeper liability under PoFA, with the signage and delivery circumstances providing additional grounds where appropriate.
Let's see the remaining photographs, if any, before proceeding.
Having now seen both sides, I cannot see anything that remedies the previously identified failure to specify a period of parking, as required by PoFA paragraph 9(2)(a). That remains a potentially decisive point concerning keeper liability.
However, I still need you to log on to the PPS website at www.paypps.co.uk and check whether there are any additional photographs of the vehicle. If there are any beyond the two reproduced on the NtK, please download them and post them here. I want to see the complete photographic evidence before drafting the keeper appeal.
You have also mentioned that the vehicle was stopped briefly to make an Amazon delivery. That raises another potentially important argument.
In Jopson v Homeguard Services Ltd [2016] B9GF0A9E, HHJ Harris QC distinguished temporary stopping for loading or unloading from parking. Making a genuine delivery would therefore provide an additional defence, depending on the circumstances.
Can you confirm approximately how long the vehicle was stopped and whether the delivery was to someone at Donnington House?
Finally, do not identify the driver to PPS. The keeper has no legal obligation to do so. Any appeal will be made solely in the capacity of registered keeper, relying primarily on PPS's failure to establish keeper liability under PoFA, with the signage and delivery circumstances providing additional grounds where appropriate.
Let's see the remaining photographs, if any, before proceeding.
Never argue with stupid people. They will drag you down to their level and then beat you with experience. - Mark Twain
