Civil Enforcement Ltd - POPLA Appeal Help - Invisible Signage at Night

yamalui

Hi all,

I've read the Newbie thread and followed the advice so far. I'm now at POPLA stage with Civil Enforcement and would appreciate any feedback on my draft appeal before submitting.

Background

Operator: Civil Enforcement Limited (BPA member)
Location: Great Western Hotel car park (Southwest England)
Date of incident: 03 October 2025
Time: 18:46-19:12 (dark, evening)
PCN Number: [Redacted]
POPLA Code: [Have code]
Contravention: "Failed to obtain a permit in accordance with the notified terms"
Charge: £100 (reduced to £60 if paid within 14 days)

What Happened

The driver parked at the hotel car park at 6:46 PM (dark) to use toilet facilities as the train station had no accessible toilets. The driver spoke to hotel reception staff. Duration: 25 minutes.

First Appeal

I appealed to CEL using the template from the Newbie thread:

• Challenged signage visibility
• Did NOT name the driver
• Requested evidence of signage, landowner authority, etc.

CEL's Rejection

Received rejection on 13 November 2025 with standard template response stating:

• "No record of vehicle being registered to be exempt"
• "Many clear and visible signs displayed"
• "We maintain a continuous log confirming signage remains in place"
• "Fully compliant with POFA 2012"
• Provided POPLA code

My Main Grounds for POPLA Appeal

1. Catastrophic signage failure - invisible in darkness:

   • Incident at 18:46-19:12 (6:46 PM in early October - completely dark)
   • Signage has ZERO illumination
   • Small, poorly positioned, far from entrance
   • Breaches BPA Code requirement for signs to be "visible, legible and unambiguous"

2. POFA keeper liability concerns:

   • I'm appealing as keeper, not driver
   • Civil Enforcement is mentioned in the guide as having POFA failures
   • They claim compliance but provide no evidence of exact statutory wording

3. No valid contract formation:

   • Invisible signage = no informed consent
   • £100 charge not prominently displayed (Red Hand Rule)
   • Fails Consumer Rights Act transparency requirement

4. Vague allegation:

   • "Failed to obtain a permit" - not explained HOW to obtain permit
   • No evidence of payment machine, or instructions visible in darkness

5. Landowner authority:

   • Request unredacted authority from hotel
   • BPA Code strict proof required

Evidence

I have daytime images (too far to travel back to get any more images) showing:

• Small signage far from entrance
• No prominence even in daylight
• No illumination visible

My argument: If barely visible in DAYLIGHT, impossible to see at 6:46 PM in darkness.

Questions

1. POFA compliance: Looking at my NTK (attached), does it appear POFA compliant? I can see some statutory wording on the back.

2. Draft POPLA appeal: I've prepared a 10+ page detailed appeal (as advised in guide). Is there anything I should definitely include:

   • Beavis case comparison?
   • Vine v Waltham Forest case law?
   • Henry Greenslade quote about keeper liability?
   • Specific POPLA decision references?

3. Timing: I have until 11 December 2025 to submit to POPLA. Any issues with submitting soon?

Draft Appeal Structure

• Executive Summary
• Ground 1: Signage Non-Compliance (BPA Code, Red Hand Rule, darkness, no illumination)
• Ground 2: POFA Keeper Liability Issues
• Ground 3: Operator Hasn't Proven Appellant is Liable Driver
• Ground 4: Landowner Authority / BPA Compliance
• Ground 5: Vague Allegation
• Ground 6: No Valid Contract Formation
• Evidence Attachments (daytime photos showing poor signage)
• Civil Enforcement's Inadequate Rejection Response
• Summary and Conclusion
• Legal References

What I Need

Any feedback on:

• Strength of arguments
• Missing any key points?
• Whether to add case law references (Beavis, Vine, specific POPLA decisions)
• Hotel complaint strategy (Emailed hotel, received standard dismissal claiming "fines are not controlled by us". Worth pushing back or move straight to POPLA?)
• Anything else I should know about Civil Enforcement at POPLA stage?

Thank you in advance for any help! This forum has been invaluable.

---

Note: I have NOT named the driver in any appeal and will not do so.

Coupon-mad

POPLA is a last resort (or it can be swerved completely if you like - usually I do NOT even bother) and the POPLA code lasts a month, so you have ages to exhaust PLAN A first.

What happened when you complained to the hotel? You could try that by phone one evening this week and if the manager is not on board to cancel the PCN, you could ask nicely if they would take some general wide view photos of the car park in the dark, to allow you to use them as evidence. You might also pick up from the staff if CEL are more trouble than they are worth and that the hotel might be peeee'd off.

yamalui

Coupon-mad said:

POPLA is a last resort (or it can be swerved completely if you like - usually I do NOT even bother) and the POPLA code lasts a month, so you have ages to exhaust PLAN A first.

What happened when you complained to the hotel? You could try that by phone one evening this week and if the manager is not on board to cancel the PCN, you could ask nicely if they would take some general wide view photos of the car park in the dark, to allow you to use them as evidence. You might also pick up from the staff if CEL are more trouble than they are worth and that the hotel might be peeee'd off.

Thank you for replying. (Sorry for the delay, just saw this).

Plan A Update (The Hotel Negotiation so far):
I've had a back-and-forth with an admin at the hotel.

1. Me: "We stopped for 25 mins to use toilet, your staff gave permission. Signs invisible in dark. Please cancel."
2. Hotel: "Parking is for customers only. Fines not controlled by us. Appeal to them."
3. Me: "You are the landowner, you definitely can cancel. Staff gave permission. Please escalate to GM."
4. Hotel (Today): 
   - "I do wish to remind you that the using of our facilities does not equate to permission of usage of our car park."
   - "However, if the receptionist did explicitly allow you to park in our car park I must ask for more details of who granted it?"
   - "As mentioned prior parking tickets are not distributed by us, and not controlled by us. As a gesture of goodwill I am happy to speak to the company to see if they would be willing to doc this parking charge to £25.
   - "If you still wish to speak with my manager she is currently on annual leave, however I am happy to forward this issue to her when she comes back."

So:
- They are offering £25 (settlement). Is it worth accepting the £25 to make this go away? Or should I refuse and insist on waiting for the Manager?

- There is nowhere else to park if you use their toilets in that location. And why would you drive far away just to walk back to their hotel to use the toilets?

Evidence situation:

• I only have daytime photos (which show the signs are small/unlit). I don't have photos from the night itself as I thought we were okay considering they let us in.
• Asking for the receptionist's name seems like a deflection (who asks for a name when using a toilet?).

Plan:
I'm thinking of replying to refuse the £25 and insist on the Manager.
I will also use your tip: I'll ask them to take a photo of the car park in the dark themselves to prove visibility (or lack of it). That's a good idea.

What do you think? Is the £25 offer a "good result"?

Jame4ters

yamalui said:

Coupon-mad said:

POPLA is a last resort (or it can be swerved completely if you like - usually I do NOT even bother) and the POPLA code lasts a month, so you have ages to exhaust PLAN A first.

What happened when you complained to the hotel? You could try that by phone one evening this week and if the manager is not on board to cancel the PCN, you could ask nicely if they would take some general wide view photos of the car park in the dark, to allow you to use them as evidence. You might also pick up from the staff if CEL are more trouble than they are worth and that the hotel might be peeee'd off.

Thank you for replying. (Sorry for the delay, just saw this).

Plan A Update (The Hotel Negotiation so far):
I've had a back-and-forth with an admin at the hotel.

1. Me: "We stopped for 25 mins to use toilet, your staff gave permission. Signs invisible in dark. Please cancel."
2. Hotel: "Parking is for customers only. Fines not controlled by us. Appeal to them."
3. Me: "You are the landowner, you definitely can cancel. Staff gave permission. Please escalate to GM."
4. Hotel (Today): 
   - "I do wish to remind you that the using of our facilities does not equate to permission of usage of our car park."
   - "However, if the receptionist did explicitly allow you to park in our car park I must ask for more details of who granted it?"
   - "As mentioned prior parking tickets are not distributed by us, and not controlled by us. As a gesture of goodwill I am happy to speak to the company to see if they would be willing to doc this parking charge to £25.
   - "If you still wish to speak with my manager she is currently on annual leave, however I am happy to forward this issue to her when she comes back."

So:
- They are offering £25 (settlement). Is it worth accepting the £25 to make this go away? Or should I refuse and insist on waiting for the Manager?

- There is nowhere else to park if you use their toilets in that location. And why would you drive far away just to walk back to their hotel to use the toilets?

Evidence situation:

• I only have daytime photos (which show the signs are small/unlit). I don't have photos from the night itself as I thought we were okay considering they let us in.
• Asking for the receptionist's name seems like a deflection (who asks for a name when using a toilet?).

Plan:
I'm thinking of replying to refuse the £25 and insist on the Manager.
I will also use your tip: I'll ask them to take a photo of the car park in the dark themselves to prove visibility (or lack of it). That's a good idea.

What do you think? Is the £25 offer a "good result"?

Personally I wouldn’t take the “offer” as a good result. 

It is clear from what you are saying that the signage is “unclear” at night.

If they can persuade the parking company to reduce the invoice then they can persuade them to waive the invoice in full. 

Others may have different opinions but either appeal to POPLA or don’t. The outcome at POPLA won’t make any difference in the end

Car1980

Remember the signage is approved and audited by the BPA. The BPA pay Popla, in part using Civil Enforcment's cash. 

You see where this is going?

Civil Enforcement use DCB Legal mostly these days. Easier to just defend a court claim and await the inevitable discontinuance nowadays.

yamalui

Yeah that makes sense, thanks for the comments.

Regarding the Hotel, they shut down negotiation after I refused the £25 offer.

I sent the email refusing the £25 and asking for the "darkness photo" evidence.
Admin replied today:

• "I have reviewed this email chain with my manager and she agrees with my assessment... I will not be responding to further emails on this matter."
• She ignored my request for them to take a photo of the signage in the dark. She just said "The parking company is in charge of signage... raise with them."

Status:
So Plan A (Hotel Cancellation) is dead. They are digging in.
Which leaves POPLA and court.

POPLA Plan:
I have my appeal drafted (based on the templates). I hear you guys saying that POPLA is pointless these days, why is that?
Key Ground: Signage was unlit/invisible in darkness.
New Point: I will state that I asked the landowner to verify visibility with a photo at the relevant time, and they refused/ignored the request. (Does this help?)

I'm ready to submit the POPLA appeal. Any final tips before I lock it in?
How much would court cost, if it got to that?

Cheers

Car1980

 I hear you guys saying that POPLA is pointless these days, why is that?

Key Ground: Signage was unlit/invisible in darkness.

Here's the spoiler alert of the Popla decision for you  

"Whilst the appellant entered the car park in the hours of darkness, I am satisfied that the signage was clear and adheres to the operator's code of practice requirements. It is the appellant's responsibility to seek out any signage."

Honestly, just ignore. Civil Enforcement use DCB Legal, who will make a court claim against you in six months and then discontinue a few months later after you file your defence online. That is how you make it go away - there is nothing you can do until that point. It's just an invoice at the end of the day.

Coupon-mad

Yep, no point doing POPLA without photos proving the signage is unlit in darkness.

POPLA isn't fully independent due to it being set up and paid for by the industry themselves.

yamalui

Okay thanks, I'll just wait for DCB. I skipped POPLA.

yamalui

Hi all, I've just received a 'Letter Before Action - Claim for Debt' dated 12 Feb directly from Civil Enforcement Limited Team (not a solicitor like DCB Legal yet). I have 30 days. Just confirming I should ignore their reply forms and send the standard robust LBA response template from the Newbies thread via email?

They didn't include an email in the letters themselves. Do we know what email address to respond to? I have these two I found online:
- legal3@ce-service.co.uk
- office@ce-service.co.uk

Coupon-mad

Yes use those and obviously remove words like 'your client' from the suggested LBC response.

You likely won't see DCB Legal involved if CEL have sent a LBC themselves. That signals an in-house claim.