First Parking PCN - disabled passenger

Cute_Doggos

Hi all,

I hope you're well!

I am back to ask for further advice, if you have some time to kindly provide it please

A reply was received from POPLA, stating that the PPC have uploaded their evidence pack and allowing a few days for the claimant to provide any comments on their evidence. I have sifted through these and come up with the following reply:

I, the registered keeper of this vehicle, submitted a POPLA appeal dated [...] and have subsequently received correspondence through POPLA from First Parking LLP. I contend that I, as the keeper, am not liable for the alleged parking charge. In addition to my initial appeal to POPLA, I would like to highlight the following non-compliance with regulations and law by First Parking LLP based on the notes they have submitted:

1.        Inadequately Positioned and Lit Signage: BPA Code of Practice – non-compliance;

2.        Absence of Surface Markings: BPA Code of Practice – non-compliance;

3.        Grace Period: BPA Code of Practice – non-compliance;

4.        Disability Discrimination: BPA Code of Practice & Equality Act 2010 – non-compliance;

5.        No Evidence of Period Parked: Stopping vs Parking, and Notice to Keeper does not meet PoFA 2012 requirements.

 

 

1. Inadequately Positioned and Lit Signage: BPA Code of Practice – non-compliance

The BPA Code of Practice (3) states that: “Signs and surface markings are used to provide information to drivers to indicate that they are entering controlled land, to display such terms and conditions as apply to direct traffic movements and to delineate parking bays. Signs and surface markings must be designed, applied and maintained in such a way as to be visible, legible and unambiguous to drivers.”

 

The signage provided by First Parking LLP is non-compliant with the BPA Code of Practice, being illegible and non-visible during times outside of broad daylight hours due to absolute inadequate lighting on signage throughout the area. The ‘parking charge notice’ was issued during times outside of broad daylight hours, during which figures [x] in the initial appeal were taken. However, the images submitted by First Parking LLP were purposefully photographed during daylight hours, omitting the lack of visibility and legibility of such signs outside of broad daylight hours, as is the case for when the ‘parking charge notice’ was issued.

 

Furthermore, as denoted by page [x] of First Parking LLP’s evidence pack, there is usually an advertising sign for a company within the complex which completely obscures the entrance signage placed by First Parking LLP. However, as can be seen on the photograph provided by First Parking LLP, this has clearly been displaced diagonally for the purpose of First Parking LLP’s photograph, where it would normally obstruct visibility of First Parking LLP’s entrance sign. In addition, this sign further lacks any lighting and is illegible and non-visible during times outside of broad daylight hours, as mentioned in the previous paragraph.

 

Visibility of signage within the premises is further hindered by its placement in areas that are easily obscured by vehicles stopped within the premises, as denoted by page [x] of First Parking LLP’s evidence pack. In addition, visibility of other signage within the premises is also easily hindered by passing or stopped vehicles, as denoted by the low placement of signage on pages [x]. Therefore, the positioning of the signage poses a significant challenge for drivers to view the sign upon entering or leaving, whereby vehicles can easily block the signage.

 

Pages [x] of First Parking LLP’s evidence pack also demonstrates their signage being unremarkable, small, not lit, mostly illegible, overcrowded and cluttered. It is indisputable that placing letters too close together in order to fit more information into a smaller space can drastically reduce the legibility of a sign, especially one which must be read before the action of ‘parking’.

 

Page [x] of First Parking LLP’s evidence pack also wrongly states that there are two entrances to the premises, and further provides photographs on pages [x] of an ‘entrance’ sign at the exit. The true entrance to the premise, according to the landowner, is closest to [...] on the left of the image on page [x], whereas the exit is the way out on the right side of the image. Placing signage on the outside of the exit point without providing any context essentially constitutes false evidence, providing signage beyond the point where an exiting vehicle would be able to review the signage, rendering the signage valueless.

 

Despite First Parking LLP’s ascertainment on page [x] stating that ‘there is clear and adequate signage that shows the regulations to motorists’ and their claims of being ‘fully compliant with British Parking Association regulations’, it is clearly apparent that First Parking LLP’s signage within the premises is non-visible outside of broad daylight hours and not lit, poorly located, and the terms and conditions being illegible for multiple reasons, as stated above (further information on this can be found in the initial appeal to POPLA). As such, their signage demonstrates clear non-compliance with the BPA Code of Practice and it is reasonable to suggest a lack of opportunity to review any terms and conditions in order to enter a contract. Bearing all the evidence above in mind, there was also categorically no contract established between the driver and First Parking LLP. To draw on the basic guidelines of contract law, for a contract to be effective the offer must be communicated. Therefore, there can be no acceptance of an agreement if the other person is without knowledge of the offer.

 

 

2. Absence of Surface Markings: BPA Code of Practice – non-compliance

The BPA Code of Practice (5.3) states that ‘Parking operators must only pursue parking charges in instances that could be interpreted as stopping if they have explicit consent to do so on evidenced security or safety grounds from their ATA, following audit of the adequacy of the signs and surface markings in place to inform drivers of the terms and conditions in place.’

 

The BPA Code of Practice (2.36) defines surface markings as ‘the lines, symbols and/or text applied to the surface of controlled land or created through the use of surfacing materials’. Figures [x] in the initial appeal clearly show the absence of any surface markings in the area in question. This is further supported by pages [x] of First Parking LLP’s evidence pack. Without these markings, it is impossible to determine the boundaries of the controlled land, rendering the terms and conditions in place unenforceable.

 

The absence of surface markings clearly demonstrates non-compliance with the BPA Code of Practice. As a result, it is reasonable to assert that the boundaries of the land in question were not adequately defined, providing no indication of the parameters of such a controlled zone. Under such ambiguous circumstances, any attempt to establish a contract based on the terms and conditions of the land would be invalid.

 

 

3. Grace Period: BPA Code of Practice – non-compliance

First Parking LLP claim on page [x] of their evidence pack that they provide a grace period of ‘1 minutes’, falsely attributing their non-adjustable grace period of ‘1 minutes’ to ‘a reasonable grace period […] in each car park managed by First Parking’. The BPA Code of Practice (5) clearly states that additional time may be required ‘for recognising the needs of people with limited physical mobility, but adaptations are not purely physical - people with other disabilities might reasonably need longer consideration period and grace periods’, and therefore reasonable adjustments as appropriate for disabled passengers.  Furthermore, Kevin Reynolds, Head of Public Affairs and Policy at the British Parking Association (BPA), has stated that ‘No time limit [for grace periods] is specified. This is because it might take one person five minutes, but another person 10 minutes depending on various factors, not limited to disability.”

 

Grace periods must therefore be adjusted accordingly in line with the Equality Act 2010, so as to not breach primary disability law. First Parking LLP’s defence of simply providing 1 minute of grace for a disabled passenger is both non-compliant with the BPA Code of practice and a breach of the Equality Act 2010, failing to provide reasonable adjustments for a disabled individual with protected characteristics. It is therefore argued that the duration of visit in question does not carry an unreasonable grace period, particularly given the presence of a disabled passenger.

 

 

4. Disability Discrimination: BPA Code of Practice & Equality Act 2010 – non-compliance

The vehicle in question was transporting a disabled passenger with protected characteristics under the Equality Act 2010, as acknowledged by the passenger’s status as a Blue Badge holder (figure [x] on the initial appeal to POPLA) amongst other indicators.

 

The BPA Code of Practice (4) states that ‘parking operators need to have regard to the obligations placed upon them by the Equality Act 2010 and the EHRC statutory code, in particular to make reasonable adaptations to accommodate disabled people. […] people with other disabilities might reasonably need longer consideration period and grace periods […] Recognition of these obligations is important in the consideration of appeals.’

 

The Equality Act 2010 puts organisations under a positive duty to make reasonable adjustments for disabled people, to help them overcome disadvantage resulting from an impairment. The Act includes statutory protection from discrimination arising from disability. This states that it is discrimination to treat a disabled person unfavourably because of something connected with their disability.

 

The Equality Act 2010 (142) further states that ‘A term of a contract is unenforceable against a person in so far as it constitutes, promotes or provides for treatment of that or another person that is of a description prohibited by this Act.’ This includes failure to make reasonable adjustments for those with protected characteristics, including disability, and the application of unreasonable penalties. Failure to anticipate the needs of disabled persons and refusing reasonable adjustments directly violate the Equality Act 2010.

 

First Parking LLP, through their initial ‘parking charge notice’ and through their subsequent evidence pack, have failed to meet the requirements of the BPA Code of Practice and the Equality Act 2010 through their refusal to consider ‘reasonable adjustments’ for disabled passengers with protected characteristics, particularly demonstrated by their failure to adjust grace periods for those with disabilities. First Parking LLP are therefore in clear breach of both regulations and law.

 

 

6. No Evidence of Period Parked: Stopping vs Parking, and Notice to Keeper does not meet PoFA 2012 requirements

Contrary to the mandatory provisions of the BPA Code of Practice, there is no record to show that the vehicle was parked versus stopped, having not entered into a contract. The Notice to Keeper on page [x] of First Parking LLP’s evidence pack states that the vehicle ‘entered [x] at [x] and departed at [x]’. Furthermore, page [x] of First Parking LLP’s evidence pack states that the ‘vehicle entered the area at [x] and exited at [x]’, failing to state any evidence of period parked.

 

This demonstrates clear non-compliance with PoFA 2012 requirements. PoFA 2012 Schedule 4 paragraph 9 refers at numerous points to the ‘period of parking’, most notably paragraph 9(2)(a) stating that it is a requirement for the Notice to Keeper to: ‘specify the vehicle, the relevant land on which it was parked and the period of parking to which the notice relates’. However, First Parking LLP’s Notice to Keeper simply claims the vehicle ‘was in breach of the terms and conditions for parking’.  At no stage do First Parking LLP explicitly specify the 'period of parking to which the notice relates', nor have they provided evidence of such, as required by PoFA 2012. Therefore, no evidence of period ‘parked’ has been provided.

For further information, please refer to the initial appeal to POPLA containing the relevant information and evidence.

Yours sincerely,

The Keeper

Coupon-mad

That is much much too long for comments!

Cute_Doggos

Coupon-mad said:

That is much much too long for comments!

Thank you so much for the reply! I haven't submitted comments before so I do apologise if this is a silly question, but how would you suggest I change it? I tried not to include too much extra stuff so I'm not sure what else to do. Thank you very much

Coupon-mad

Just a few short bullet points, as post 3 of the NEWBIES thread says. Pick your best point but you can expect to lose at POPLA (I never bother with trying it, except in easy win cases).

Cute_Doggos

Thank you so much!

I've gone back over the sticky NEWBIES thread post and some of the rebuttals on the forum. I tried to cut it down and make it more relevant and succinct, and have rewritten it as this - the only part I haven't changed is the point 4 (grace periods), just added in parts of the EA relevant to their crappy 1 minute 'grace period' into this section.

The only other thing I was considering to add in again was the difference between stopping + parking, considering the PPC have added a map of a nearby car park in their 'evidence pack' which is entirely irrelevant - but not sure how to frame this or whether it would add value, and conscious of not making the comments too long...

Need to submit by tomorrow at the max because they only gave a few days to comment on the evidence - would be super grateful for any further comments! Please and thank you in advance!

Ref. POPLA Appeal:

 

 

In response to the ‘evidence pack’ First Parking LLP have submitted:

First Parking LLP have submitted a x-page ‘evidence pack’ in support of their speculative and disputed invoice. I do not intend to address each and every point raised in detail, as their submission is clearly a repetitive and irrelevant template to the matter at hand.

 

In making their assessment, I kindly request the POPLA assessor to consider the following in further support of my original POPLA appeal submitted on x.

 

1.        Inadequately positioned, poorly located, non-lit signage that is non-visible outside of broad daylight hours, with the terms and conditions being illegible – non-compliance with the BPA Code of Practice.

2.        Absence of surface markings denoting the existence of a controlled zone – non-compliance with the BPA Code of Practice.

3.        No Genuine Pre-Estimate of Loss (GPEOL) breakdown provided to justify the issuance of a £100 ‘parking charge notice’ – non-compliance with the BPA Code of Practice and Department of Transport guidance.

4.        Unreasonable grace period provision, particularly given the presence of a disabled passenger – non-compliance with the BPA Code of Practice and clear breach of the Equality Act 2010.

 

 

1. Inadequately positioned, poorly located, non-lit signage that is non-visible outside of broad daylight hours, with the terms and conditions being illegible – non-compliance with the BPA Code of Practice

The BPA Code of Practice (3) states that: “Signs and surface markings are used to provide information to drivers to indicate that they are entering controlled land, to display such terms and conditions as apply to direct traffic movements and to delineate parking bays. Signs and surface markings must be designed, applied and maintained in such a way as to be visible, legible and unambiguous to drivers.”

 

First Parking LLP, on page x of their ‘evidence pack’, ascertain that they provide ‘clear and adequate signage that shows the regulations to motorists’, being ‘fully compliant with British Parking Association regulations’. However, through their own ‘evidence pack’ and through the images submitted in the initial appeal to POPLA, First Parking LLP have proved their statement to be false on the following grounds:

a.        Non-lit signage that is non-visible outside of broad daylight hours: images provided by First Parking LLP on pages x-x of their ‘evidence pack’ have been purposefully and deceitfully photographed during broad daylight hours, entirely the opposite to the conditions in which the ‘parking charge notice’ was issued. Pages x and x of their ‘evidence pack’ and figures x to x of the initial appeal have been photographed under the actual conditions of when the ‘parking charge notice’ was issued. Pages x and x of their ‘evidence pack’ demonstrates the absolute lack of visibility of any signage in the darkness, and figures x to x further highlight the lack of lighting in the area and illegibility of signage. Consequently, it is apparent that the signage is non-lit, non-visible and illegible outside of broad daylight hours.

b.       Signage being inadequately positioned and poorly located: images provided by First Parking LLP on pages x to x of their ‘evidence pack’ provide further evidence of poor positioning of signage. The signage is easily obscured by advertising signs for organisations within the complex which has clearly purposefully been laterally displaced for the sake of the photograph on page x, in addition to stopped and passing vehicles and persons due to the low positioning of such signage, making it illegible. The images provided by First Parking LLP also fail to show how close the vehicle in question was to any signage, with the burden of proof of such imaging being placed on the operator to provide.

c.        Signage being small, mostly illegible, overcrowded and cluttered: pages x to x of First Parking LLP’s ‘evidence pack’ also demonstrates the significantly reduced legibility of their signage due to the placement of small letters too close together to fit more information into a smaller space, making it illegible from any normal distance.

d.       Exit signage being referred to as entrance signage: pages x, x and x of First Parking LLP’s ‘evidence pack’ provide false information on the presence of two entrances in a one-way system. The true entrance is on the left of these pages, whereas the exit is on the right. Placing signage beyond the assumed exit point is pointless due to lack of visibility to exiting vehicles and constitutes false evidence.

 

As a result of the above, it is clear that First Parking LLP’s signage is non-compliant with the BPA Code of Practice and it is reasonable to suggest the lack of opportunity to review any terms and conditions in order to enter a contract. Consequently, no contract was established between First Parking LLP and the driver.

 

 

2. Absence of surface markings denoting the existence of a controlled zone – non-compliance with the BPA Code of Practice

The BPA Code of Practice (2.36) defines surface markings as ‘the lines, symbols and/or text applied to the surface of controlled land or created through the use of surfacing materials’. As demonstrated by pages x and x of First Parking LLP’s ‘evidence pack’, in addition to figures x and x in the initial appeal to POPLA, there are undisputedly absolutely no surface markings to denote the existence of controlled land, demonstrating non-compliance with the BPA Code of Practice. Without these markings, it is impossible to determine the existence or boundaries of a controlled land, particularly given the lack of visibility and illegibility of any signage outside of daylight hours. Under such ambiguous circumstances, any attempt to establish a contract based on the terms and conditions of the land would be invalid.

 

 

3. No Genuine Pre-Estimate of Loss (GPEOL) breakdown provided to justify the issuance of a £100 ‘parking charge notice’ – non-compliance with the BPA Code of Practice and Department of Transport guidance

The Department of Transport guidance states that ‘Charges for breaking a parking contract must be reasonable and a genuine pre-estimate of loss. This means charges must compensate the landholder only for the loss they are likely to suffer because the parking contract has been broken. Charges may not be set at higher levels than necessary to recover business losses and the intention should not be to penalise the driver.’

 

The costs of issuing the ‘parking charge notice’, postage of Notice to Keeper, Admin and Personnel Hours are business losses that are excluded by the Department of Transport’s guidelines and are all grossly overestimated business losses that First Parking LLP are trying to recover through issuing grossly disproportionate 'parking charge notices'. As part of the appeals process, First Parking LLP have been provided with the opportunity to provide a breakdown of their costs to highlight exactly which losses they have allegedly suffered. However, First Parking LLP on page x of their ‘evidence pack’ state that they conveniently believe ‘it would not be proportionate to supply our [their] calculations relating to Parking Charges at this time’. Therefore, no genuine pre-estimate of loss has been provided. The fact that First Parking LLP have repeatedly offered a ‘discounted’ charge of £60 amidst their ascertainment that their charges are ‘calculated using our [their] company records’ demonstrates that these charges are clearly in conflict with the Department of Transport guidance and are, in fact, ‘punitive’ and a gross overestimate in an attempt to recover business losses.

 

It is therefore clear that First Parking LLP are attempting to create a loss where none had existed prior to the issuing of the ‘parking charge notice’. The fact that First Parking LLP have stated on many occasions that they are willing to accept £60 as opposed to £100 for the alleged offence highlights this flagrant bending of the guidelines.

 

 

4. Unreasonable grace period provision, particularly given the presence of a disabled passenger – non-compliance with the BPA Code of Practice and clear breach of the Equality Act 2010

First Parking LLP claim on page x of their evidence pack that they provide a grace period of ‘1 minutes’, falsely attributing their non-adjustable grace period of ‘1 minutes’ to ‘a reasonable grace period […] in each car park managed by First Parking’. The BPA Code of Practice (5) clearly states that additional time may be required ‘for recognising the needs of people with limited physical mobility, but adaptations are not purely physical - people with other disabilities might reasonably need longer consideration period and grace periods’, and therefore reasonable adjustments as appropriate for disabled passengers.  Furthermore, Kevin Reynolds, Head of Public Affairs and Policy at the British Parking Association (BPA), has stated that ‘No time limit [for grace periods] is specified. This is because it might take one person five minutes, but another person 10 minutes depending on various factors, not limited to disability.”

 

The Equality Act 2010 (142) further states that ‘A term of a contract is unenforceable against a person in so far as it constitutes, promotes or provides for treatment of that or another person that is of a description prohibited by this Act.’ This includes failure to make reasonable adjustments for those with protected characteristics, including disability, and the application of unreasonable penalties. Failure to anticipate the needs of disabled persons and refusing reasonable adjustments directly violates the Equality Act 2010.

 

Grace periods must therefore be adjusted accordingly in line with the Equality Act 2010, so as to not breach primary disability law. First Parking LLP’s defence of simply providing 1 minute of grace for a disabled passenger is both non-compliant with the BPA Code of practice and a breach of the Equality Act 2010, failing to provide reasonable adjustments for a disabled individual with protected characteristics. It is therefore argued that the duration of visit in question does not carry an unreasonable grace period, particularly given the presence of a disabled passenger, and that the terms of the contract are inherently unenforceable under the BPA Code of Practice and Equality Act 2010.

Gr1pr

Still seems far too long to me,  plus you can only comment on their evidence pack, not add extra stuff 

Keep each point extremely short,  less is more,  the background explanation should have been in your popla appeal,  so if it was then no need to reiterate it, just point it out

The limit used to be 2000 characters, it was increased by popla some time ago,  but try to condense yours with a 2000 target in mind,  not war and peace 

We usually discourage your point 3, mainly because the Beavis case killed it off a decade ago 

Cute_Doggos

Gr1pr said:

Still seems far too long to me,  plus you can only comment on their evidence pack, not add extra stuff 

Keep each point extremely short,  less is more,  the background explanation should have been in your popla appeal,  so if it was then no need to reiterate it, just point it out

The limit used to be 2000 characters, it was increased by popla some time ago,  but try to condense yours with a 2000 target in mind,  not war and peace 

We usually discourage your point 3, mainly because the Beavis case killed it off a decade ago 

Thank you! Gosh it's currently on around 8k characters, I'll try to cut that down now to roughly 2k and will bear your and CM's advice in mind. Will also cut out point 3 - it's a shame that it's no longer effective, esp considering it makes sense as a valid point

Cute_Doggos

Final update - tried to cut it down as much as I could (can't see any further places to cut), although it's still over 2000 characters! Thank you all for the feedback. Would sincerely appreciate any last comments or advice. Thank you again

Ref. POPLA Appeal:

 

 In response to the ‘evidence pack’ First Parking LLP have submitted:

First Parking LLP have submitted a x-page ‘evidence pack’ in support of their speculative and disputed invoice. I do not intend to address every point raised in detail, as their submission is clearly a repetitive and irrelevant template to the matter at hand.

 

In making their assessment, I kindly request the POPLA assessor to consider the following in further support of my original POPLA appeal submitted on x.

 

1.        Inadequately positioned, poorly located, non-lit signage that is non-visible outside of broad daylight hours, with the terms and conditions being illegible – non-compliance with the BPA Code of Practice.

2.        Absence of surface markings denoting the existence of a controlled zone – non-compliance with the BPA Code of Practice.

3.        Unreasonable grace period provision, particularly given the presence of a disabled passenger – non-compliance with the BPA Code of Practice and clear breach of the Equality Act 2010.

 

 

1. Inadequately positioned, poorly located, non-lit signage that is non-visible outside of broad daylight hours, with the terms and conditions being illegible – non-compliance with the BPA Code of Practice

The BPA Code of Practice (3) is states that signage must be ‘visible, legible and unambiguous to drivers.’ First Parking LLP, on page x of their ‘evidence pack’, ascertain that they provide ‘clear and adequate signage that shows the regulations to motorists’. However, their own images have proven their statement to be false on the following grounds:

a.        Non-lit signage that is non-visible outside of broad daylight hours:

                                        i.               Images on pages x of their ‘evidence pack’ have been purposefully and deceitfully photographed during broad daylight hours, the opposite of the conditions under which the ‘parking charge notice’ was issued.

                                      ii.               Pages x of their ‘evidence pack’ and figures x of the initial appeal have been photographed under the actual conditions of when the ‘parking charge notice’ was issued, demonstrating lack of visibility and legibility of signage under these conditions.

b.       Signage being inadequately positioned and poorly located:

                                        i.               Images on pages x of their ‘evidence pack’ provide further evidence of poor positioning of signage in purposefully low and easily obscured places, by stopped and/or passing vehicles, and by advertising signs for organisations within the complex (e.g., the purposeful lateral displacement of such advertising signs on page x).

                                      ii.               The images provided by First Parking LLP further fail to show how close the vehicle in question was to any signage, with the burden of proof of such imaging being placed on the operator.

c.        Signage being small, mostly illegible, overcrowded and cluttered:

                                        i.               Images on pages x of their ‘evidence pack’ also demonstrates the significantly reduced legibility of their signage due to the placement of small letters too close together to fit more information into a smaller space, making it illegible from any normal distance.

d.       Exit signage being referred to as entrance signage:

                                        i.               Images on pages x of their ‘evidence pack’ provide false information on the presence of two entrances in a one-way system. The true entrance is on the left of these images, whereas the exit is on the right. Placing signage beyond the assumed exit point is pointless due to lack of visibility to exiting vehicles and constitutes false evidence.

 

First Parking LLP’s signage is non-compliant with the BPA Code of Practice and demonstrates a clear lack of opportunity to review any terms and conditions to enter a contract. Consequently, no contract was entered.

 

 

2. Absence of surface markings denoting the existence of a controlled zone – non-compliance with the BPA Code of Practice

The BPA Code of Practice (2.36 & 3) requires the use of surface markings to illustrate the boundaries of controlled land. Images on pages x of First Parking LLP’s ‘evidence pack’, and figures x in the initial appeal to POPLA, demonstrate the lack of any surface markings to denote the existence of controlled land. It is therefore impossible to determine the existence or boundaries of any controlled land. Under such ambiguous circumstances, any attempts to establish a contract based on the terms and conditions of the land are invalid.

 

 

3. Unreasonable grace period provision, particularly given the presence of a disabled passenger – non-compliance with the BPA Code of Practice and clear breach of the Equality Act 2010

The BPA Code of Practice (5) states reasonable adjustments for consideration and grace periods may be required for those with protected characteristics, including disability. This is supported by the Equality Act 2010 (142), which states that the terms of a contract are unenforceable if they fail to provide reasonable adjustments and discriminate against those with protected characteristics.

 

On page x of First Parking LLP’s evidence pack, they state they have provided a grace period of ‘1 minutes’, falsely attributing their non-adjustable grace period of ‘1 minutes’ to ‘a reasonable grace period’. Despite knowledge of a disabled passenger with protected characteristics under the Equality Act 2010, they have repeatedly failed to provide reasonable adjustments. Under such regulations and primary disability law, First Parking LLP are in contravention of the BPA Code of Practice and the Equality Act 2010, rendering the terms of their contract (which were never entered in the first place) inherently unenforceable.

Cute_Doggos

Submitted everything, thank you all for your help!