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POFA does not stipulate that the act must be referred to.
That's what I wanted to know. Thanks. I will have a look at the other NTKs. As I said, I won't be paying - and they won't be going to court albeit for another list of reasons, but the last thing I wanted to do was contest the charge purely on the strength of no keeper liability which I have done at all times successfully in the past when parking companies have not relied on it.