PCN UKCPS Leeds City Station

[b789]

I will give you an IAS, kangaroo court, appeal later. In the meantime, just consider the corrupt tosssers response… “We are not relying on PoFA to hold the Keeper liable but we are going to assume that the Keeper was the driver”.

The ONLY legal way a Keeper can be held liable is if they strictly comply with PoFA. There is no assumption or inference allowed to presume the Keeper was the driver. 

If it were me, I would simply respond as follows:

Dear UKCPS,

Re: PCN [reference]

I write as registered keeper. No driver has been identified and no admission is made.

Your position is laughable and is a clear indication of the knuckle dragging level of intelligence applied at your firm of ex-clamper Baboons.

You have admitted that this is a non-PoFA charge and that UKCPS is not relying on Schedule 4 of the Protection of Freedoms Act 2012. You then immediately attempt to hold the keeper liable anyway by pretending that you can simply “assume” the keeper was the driver.

That is not law. That is not evidence. That is not reasoning. It is legal gibberish, but not surprising, coming from a bunch of scammers. 

The only lawful route to keeper liability is strict compliance with PoFA. You have admitted that you are not relying on PoFA. Therefore, unless you have actual evidence that I was the driver, you have no case against me as keeper.

There is no legal presumption that the keeper was the driver. There is no obligation to name the driver. Silence is not evidence. An appeal by the keeper is not an admission of driving. You obviously know that but you hope that this Keeper is one of the low-hanging fruit on the gullible tree who will simply pay up out of ignorance or fear. Think again. 

Your position is therefore reduced to this: “We cannot hold the keeper liable under PoFA, so we will just pretend the keeper was the driver instead.”

That is beyond pathetic, and a clear sign of ignorance backed up by verbal thuggery. 

Cancel the charge.

If UKCPS maintains this nonsense, I refer you to the reply given in Arkel v Pressdram (1971)

Yours faithfully,

[Name]

[samh47]

Lol! Thanks for that response, might be a little offensive and harsh? I think I'll mellow it down a little and not call them baboons! 

[samh47]

@b789 you don't happen to have an email address? I can't find one on their website and the email they sent to me as from a no-reply email. They clearly make things as difficult as possible.

[b789]

No email address off the top of my head. I seriously would unload on the idiots. However, you do not need to respond to an appeal rejection. I will give you an IAS appeal you can use.

Right now, I’m on vacation and will submit something tomorrow.

You really have to understand you are dealing with scammers, and that includes the IAS for the secondary appeal. This would never stand a chance in a real court.

[samh47]

Thanks, rally appreciate that, enjoy your vacation.

[b789]

@samh47, use the following as your IAS appeal:

I appeal as the registered keeper. No driver has been identified and no admission is made as to the identity of the driver.

This appeal turns on one point only: UKCPS has no keeper liability.

UKCPS has expressly admitted that this Parking Charge was issued as a “Non-PoFA matter” and that it is not relying on Schedule 4 of the Protection of Freedoms Act 2012.

That admission is fatal.

Schedule 4 PoFA is the only statutory route by which a private parking operator may transfer liability from an unidentified driver to a registered keeper. If UKCPS does not rely on PoFA, it cannot hold the keeper liable as keeper. That is elementary.

UKCPS has instead attempted to rely on an “assumption” that the keeper was the driver. That is not evidence. It is not law. It is not reasoning. It is legal gibberish.

There is no legal presumption that the registered keeper was the driver. The keeper is under no obligation to identify the driver. Silence is not evidence. A keeper appeal is not an admission of driving. The fact that a person is the registered keeper proves only keeper status; it does not prove driver identity.

Nor should the IAS attempt to repair UKCPS’s defective case by inventing a “balance of probabilities” finding that the keeper was the driver. The balance of probabilities is a standard of proof, not a substitute for proof. It cannot turn an evidential void into a finding of fact.

There is no admission, no photograph of the driver, no witness evidence, no evidence of who had access to the vehicle, no evidence excluding any other possible driver, and no evidence at all that the keeper was driving.

If keeper status alone were enough to infer driver identity, Schedule 4 PoFA would be pointless. Parliament created Schedule 4 precisely because an operator cannot simply pursue a keeper as if the keeper must have been the driver.

UKCPS’s position is therefore reduced to this:

“We are not relying on PoFA, so we will simply assume the keeper was the driver.”

That is not a case. It is a confession that UKCPS has no lawful route to keeper liability and no evidence against the keeper as driver.

The IAS should not rubber-stamp that fiction. If this appeal is rejected on the basis that the keeper was “probably” the driver, that would not be a reasoned legal finding. It would be the IAS doing UKCPS’s work for it by manufacturing an evidential basis that UKCPS has failed to provide.

For the avoidance of doubt, the appellant will not pay a non-PoFA charge based on an unevidenced assumption. If UKCPS wishes to pursue this further, it can explain to a County Court judge how it proposes to hold a registered keeper liable when it has no PoFA liability, no identified driver, no admission, and no evidence that the keeper was driving.

The answer is obvious: it cannot.

The appeal must be allowed.

You'll probably have to upload it as a PDF. Just type in the appeal box, see uploaded file.

[samh47]

Please see response on The IAS website, they've also uploaded various photos, site maps, signs etc, should I share them as well?

The operator made their Prima Facie Case on 15/07/2026 16:38:14.

The operator reported that...
The appellant was the keeper.
The Notice to Keeper (Non-ANPR) was sent on 09/06/2026.
The ticket was issued on 26/05/2026.
The charge is based in Contract.

The operator made the following comments...
The Parking Charge was issued correctly on 26th May 2026 at Leeds City Station for Stopping in a No Stopping Area.
There are numerous signs along the roadway, positioned on both sides of the route and facing approaching drivers, clearly advising motorists that stopping is not permitted. The photographic evidence confirms that the vehicle stopped within the restricted area, and the Parking Charge Notice was issued correctly in line with the clearly displayed terms and conditions.
The appellant states that this is a non-Protection of Freedoms Act 2012 matter and that they have not identified the driver. As previously explained, this Parking Charge has not been issued under Schedule 4 of the Protection of Freedoms Act 2012. The appellant has chosen not to identify the driver, and the Independent Appeals Service can consider the evidence and submissions provided by both parties when determining the appeal.
The appellant does not dispute that the vehicle stopped at the location. Instead, the appeal is based solely on the issue of keeper liability. The Operator relies on the evidence of the parking event, together with the clearly displayed terms and conditions at the site.
As the vehicle stopped in an area where stopping is prohibited, the Parking Charge was issued correctly.
For these reasons, we respectfully ask that the appeal to be dismissed

[b789]

This is a singe point of law issue. The driver is not identified. The ONLY way a Keeper can be held liable is if the creditor has fully complied with all the requirements of PiFA. They have not. They have admitted so. 

So, without PoFA, there is NO Keeper liability. If the IAS supposedly legally trained adjudicator is not just a corrupt pretender, they will agree. If they don’t, it is just more evidence of the corrupt nature of the IAS. 

No court would be able to ignore this point. The IAS is not a court. It is a privately owned company, owned by the same firm that is the IPC. 

Use that point in your response. Nothing else matters. There is no assumption in civil law that the Keeper is slo the driver. End of.

[samh47]

Perfect, thanks. Is the below ok?

Schedule 4 of the Protection of Freedoms Act 2012 ("PoFA") provides the only statutory mechanism by which a private parking operator may recover an unpaid parking charge from the registered keeper where the identity of the driver has not been established. Where a creditor elects not to rely upon, or fails to comply with, the mandatory requirements of Schedule 4, liability cannot lawfully be transferred from the unidentified driver to the registered keeper.

This appeal turns on a single point of law. The driver has not been identified. Accordingly, the only basis upon which the registered keeper could be held liable is through full compliance with the requirements of Schedule 4 of PoFA. UKCPS has expressly confirmed that it is not seeking to rely upon PoFA and has therefore accepted that the statutory provisions creating keeper liability do not apply.

In those circumstances, there is no lawful basis upon which the registered keeper can be held liable for the parking charge. That is the legal consequence of the statutory framework enacted by Parliament.

It follows that the appeal should be allowed. Any decision purporting to impose liability upon the registered keeper, despite the absence of compliance with Schedule 4 of PoFA and in the absence of evidence identifying the driver, would be contrary to the applicable law and unsupported by the statutory scheme.

[b789]

Yup. It will come down to how corrupt the IAS adjudicator is feeling on the day.