Times24 Gatwick North Terminal Drop-Off – IAS appeal advice

RanjanaSakti

Hi everyone,

I'd really appreciate a sense check before I submit an IAS appeal.

This concerns a Times24 Parking Charge Notice for the Gatwick Airport North Terminal Drop-Off Zone.

Timeline:

• Alleged event: 18 June 2026
• Notice to Keeper dated 7 July 2026
• I did not receive the Notice to Keeper until 15 July 2026.
• I appealed only as the registered keeper and did not identify the driver.
• In my appeal, I asked Times24:
  • whether they were relying on Schedule 4 of the Protection of Freedoms Act 2012;
  • whether they considered the location to be "relevant land";
  • the legal basis for keeper liability; and
  • the evidence they intended to rely upon if rejecting the appeal.
• Instead of answering those questions, they asked me to provide the photo ID section of my driving licence.
• I declined because I was appealing solely as the registered keeper and had not identified the driver.
• Times24 then rejected my appeal because I did not provide the requested evidence.

My proposed IAS appeal focuses on the following points:

1. The driver has never been identified.
2. Times24 has not established a lawful basis for pursuing the registered keeper.
3. If Times24 relies on Schedule 4 of POFA, it should prove that all statutory conditions are met, including that the location is "relevant land".
4. Times24 failed to answer the legal questions raised in my appeal and instead focused on requesting my driving licence.

I'm not asserting that the land definitely is or is not relevant land. My position is simply that, if the operator wishes to rely on keeper liability under POFA, the burden is on them to establish that the statutory requirements are satisfied.

I'd be grateful for any comments before I submit the IAS appeal. Have I focused on the strongest arguments, or is there anything I should add, remove or reword?

Thanks in advance.

Car1980

The burden is on YOU at the IAS, the exact opposite of court. So ditch your points.

See the Gatwick thread of what wording to use.

But remember that there are no guarantees at either POPLA or especially the IAS, no matter how iron-clad your case. But that's not a problem because you'll ignore them anyway.

Gr1pr

Read all the other recent similar cases by Times at Gatwick, especially the ones where they asked for driver I.D.

LoneStarState

The notice to keeper was issued outside the 14 day window to hold the keeper liable even if the land wasn't relevant land. Times relying on schedule 4 is an impossibility as a result.

Because it's the IAS, you will need to make your case more strongly as the adjudicators are a joke that hide behind anonymity to find in favour of operators for the most part.

Coupon-mad

I'd ask @cooldude255220 to write you an IAS appeal, or read the ones they wrote last month in Smart Parking cases and adapt.

RanjanaSakti

Thanks Guys. One final check about IAS appea after going through comments. Is this ok @ Coupon-mad and @cooldude255220 ?

Appeal

I am the registered keeper of the above vehicle.

This appeal is made solely in that capacity.

At no stage have I identified the driver, nor have I made any admission as to the driver's identity.

I respectfully submit that the Operator has failed to establish any lawful basis upon which I may be held liable as the registered keeper.

Ground 1 – The Operator has failed to establish keeper liability

The Operator has chosen to pursue me as the registered keeper rather than the driver.

Throughout the appeal process I have consistently acted only as the registered keeper.

The identity of the driver has never been admitted or established.

There is no legal presumption that the registered keeper was the driver.

Accordingly, the burden rests upon the Operator to establish the legal basis upon which liability can be transferred from an unidentified driver to the registered keeper.

The Operator has failed to do so.

Ground 2 – If the Operator relies upon Schedule 4 of the Protection of Freedoms Act 2012, it must establish that every statutory condition has been satisfied

My original appeal specifically requested clarification of whether the Operator was relying upon Schedule 4 of the Protection of Freedoms Act 2012 ("POFA").

I also requested clarification of the legal basis upon which keeper liability was said to arise.

No answer was provided.

If the Operator now seeks to rely upon POFA, it should demonstrate:

• that Schedule 4 applies to this location;
• that the location constitutes "relevant land" for the purposes of Schedule 4;
• that every statutory condition required to transfer liability from the driver to the registered keeper has been satisfied.

The Operator has not explained any of those matters during the appeal process.

Further, the alleged parking event occurred on 18 June 2026 whereas the Notice to Keeper is dated 7 July 2026, approximately 19 days later.

If the Operator relies upon Schedule 4, it should explain how the statutory requirements for keeper liability have been satisfied.

Ground 3 – The Operator failed to answer the legal issues raised in my appeal

My initial appeal asked the Operator to explain:

• whether it relied upon Schedule 4 of the Protection of Freedoms Act 2012;
• the legal basis upon which it alleged keeper liability;
• whether the location constituted relevant land;
• the evidence upon which it intended to rely.

Rather than addressing those questions, the Operator requested that I provide a copy of the photo identification section of my driving licence in order to verify the identity of the driver.

As my appeal had been made solely as the registered keeper, I declined to provide that information.

The Operator then rejected my appeal because I had not supplied the requested evidence instead of answering the legal questions that had been raised.

I respectfully submit that requesting identification of the driver does not establish liability on the part of the registered keeper.

Ground 4 – Evidence

Should the Operator contend that keeper liability exists, I respectfully request that it provides evidence of:

• the legal basis upon which it pursues the registered keeper;
• compliance with all statutory requirements relied upon;
• its authority from the landowner to issue and enforce Parking Charge Notices at this location;
• the signage relied upon on the date of the alleged contravention.

Conclusion

The Operator has failed to establish that I, as the registered keeper, am legally liable for this Parking Charge Notice.

The driver has not been identified.

The legal basis for keeper liability has not been explained.

The issues raised in my appeal have not been addressed.

Accordingly, I respectfully request that the Independent Appeals Service allows this appeal and directs that the Parking Charge Notice be cancelled.

Bazarius

Times24 are breaching the Code for redacting photos of the driver . Make a formal complaint to the IPC for the below code breach .

7.4. Alteration of photographic evidence

Parking operators must not digitally or by other means alter images used as photographic

evidence other than:

a) to blur faces or the VRMs of other vehicles in the image in accordance with their GDPR

obligations;

b) to enhance the image of the VRM for clarity, but not to alter the letters and numbers.

cooldude255220

@RanjanaSakti

I have put together an appeal for you here:

https://www.dropbox.com/scl/fo/dcsk8l8dyr84uvwmx4ymb/ALIxbywm_qlPqS4bD762o3c?rlkey=seuxmqme1zqpfmnby6i7o7r1m&st=dbl7dy91&dl=0

Please read through it and make sure you're happy with it.

And make sure to upload all of the attachments when you submit it.

pgregory

I've just received a response to my claim from Times24, stating that they are not pursuing under Schedule 4 of the Protection of Freedoms Act 201, but instead stating the "principles considered in Elliott v Loake (1982)". Quote:

As this charge is not being pursued under Schedule 4 of the Protection of Freedoms Act 2012, we are not relying on the
statutory keeper liability provisions in Schedule 4, so its specific conditions do not need to be met. In the absence of driver
details, we rely on the principles considered in Elliott v Loake (1982) when assessing, on the balance of probabilities, who was
driving.

Does this mean the appeal written above would not be applicable to me if I decide it's worth appealing to the IAS as it clearly revolves around Schedule 4, which they are now distancing themselves from, presumably because there have been many such appeals?

kryten3000

Ah the old chestnut Elliott v Loake. This was a criminal case where there was physical evidence placing the driver behind the wheel. It's easy to rebut, see this excellent summary:

https://www.parkingcowboys.co.uk/elliot-vs-loake/

Coupon-mad

https://forums.moneysavingexpert.com/discussion/comment/82109014#Comment_82109014

It was also deftly debunked & dismissed by HHJ Jackson in Excel v Wilkinson.

"Does this mean the appeal written above would not be applicable to me if I decide it's worth appealing to the IAS as it clearly revolves around Schedule 4, which they are now distancing themselves from, presumably because there have been many such appeals?"

Nope! Nothing has changed.

They are simply misleading you with irrelevant case law that never sticks in court. Touted by Will Hurley of the IAS but debunked in court every time it's attempted.

There is no lawful presumption that a keeper was the driver on private land. If it were that simple in law, there would never have been a need for POFA schedule 4.

That was confirmed years ago in a POPLA Annual Report by parking 'guru' barrister and (very good at the time) POPLA Lead Adjudicator, Henry Greenslade. Sadly, that was over a decade ago and POPLA and the IAS are considered now to be involved in a 'race to the bottom'.

However, put in your IAS apoeal. Costs you nothing and we have seen this argument 'no keeper liability' win recently.