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Road Traffic Act 2004 Penalty Charge Notice available on Permit Only Car Park???

I parked on a permit only car park operated by the local council where the on street pay and display expired at six p.m. but all the on street bays were full that evening. 

I returned to find a RTA 2004 Penalty Charge Notice on my car

The question is whether that is a valid procedure in off street non publicly available land or whether - even if council owned but private, the correct procedure should have been a civil Parking Charge Notice thus rendering the statutory 2004 Act notice invalid.

Forum opinions???? 

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