Vehicle Control Services Ltd v Ozog [2026] EWCC 12 (30 March 2026)

canuk_UK

I have not seen this case discussed here and a simple search does not reveal anything:

https://www.bailii.org/ew/cases/Misc/2026/C12.html

Just in case it has not been discussed, I link to it here because it has some persuasive influence on whether prohibitory signs can form a contract.

Vehicle Control Services Ltd v Ozog [2026] EWCC 12 was a County Court appeal concerning two “No Stopping” charges at Leeds Bradford Airport.

At first instance, the District Judge dismissed both claims, holding that the prohibitory wording did not create a contract and, alternatively, that no breach had been proved.

On appeal, HHJ Walsh disagreed with the broad proposition that a “No Stopping” sign is necessarily incapable of creating a contract. He held that signage stating “No Stopping, Picking Up or Dropping Off – £100 Charge if you fail to comply” can, in principle, amount to a contractual offer: permission to enter and pass over the private land can constitute the consideration, and acceptance can occur by driving past sufficiently prominent signs. 

However, VCS still did not succeed on both alleged contraventions. The court stressed that VCS must prove that the contractual terms were actually communicated before the alleged breach, and that “No Stopping” is not automatically breached by every momentary stoppage; involuntary or unavoidable stopping may fall outside the prohibition. 

VCS v Ozog does not establish that every airport “No Stopping” sign is contractual. It establishes that such wording can create a contract where, on the particular evidence and construction of the signs, the ordinary requirements of offer, notice, acceptance, consideration and intention are proved.

A further important limitation is that Ozog was decided on the case actually pleaded and argued. The defendant had not properly challenged several of VCS’s claim, including aspects of whether the signage was capable of creating contractual obligations. The appeal court was therefore not conducting a free-standing examination of every possible objection to VCS’s contractual case; some points were effectively uncontroverted or insufficiently pleaded.

So, Ozog establishes that prohibitory “No Stopping” signage can, in principle, create a contract, but it does not establish that every such sign does so. The value to VCS is materially affected by the deficiencies in the defendant’s pleaded case and the issues that were never properly put in dispute.

MrJenkinsEsq

On the face of it it's not a very surprising result and it seems to be a bit of an own goal for VCS. But they do now have the line, "it is so obvious as to go without saying that permission was being offered, on terms" that they'll throw at everyone. The construction is essentially, "you may enter but you may not stop". Which is different from a genuinely forbidding sign posted at an entrance which says, "patrons only". Though the difference may now need to be spelled out to the court.

canuk_UK

I agree. Ozog is useful to VCS mainly because it rejects the simplistic proposition that “No Stopping” wording can never be contractual.

But the judgment does not make every prohibitory sign contractual. Its reasoning was that, on those facts, the driver was being offered permission to enter and pass over the land subject to terms. That still leaves VCS having to prove what permission was actually offered, what land it covered, and what the terms objectively meant.

So where the signage is genuinely exclusionary — for example “Patrons Only”, “Permit Holders Only” or, for a case I am pursuing at LJLA, “Rental Cars Only” — the distinction does need to be made expressly. A sign saying a class of motorist is not permitted to enter is much harder to reconcile with the Ozog analysis that the operator was offering that motorist contractual permission to enter on terms.

Coupon-mad

I recall this one, discussed a few months ago:

https://forums.moneysavingexpert.com/discussion/6672354/vcs-no-stopping-county-court-appeal-judgment

Love the phrase 'rifling through his glovebox for a mint' and love the fact a clearly confused Defendant succeeded despite not offering a proper defence for claim 2 and not even turning up for the appeal hearing.

Umkomaas

But they do now have the line, "it is so obvious as to go without saying that permission was being offered, on terms" that they'll throw at everyone.

Like all PPCs throw Beavis around like confetti!

MrJenkinsEsq

I've read it all now and it's a bit odd. Private property on a sign is reasonably understood as "keep out" unless there's some positive invitation with it. "Private property, pay on entry". But this sign was expressed negatively, no stopping, with nothing said about what the driver gets. It reads far more like a gratuitous licence from the airport as occupier, which needs nothing implied that isn't on the sign. Any argument that this leaves VCS without a remedy is moot. The byelaws already provide one, up to level 3, and the airport has simply chosen not to use it (going by the other thread).

He could have taken the contract as read and still dismissed. The barrier failed, so the stop was compelled, so no breach. And the second claim died because VCS never proved the car passed a sign at all. Both failures were VCS's own, and neither needed a ruling on whether a prohibition sign is an offer.

On breach he refuses to imply anything into the contract, construing "no stopping" narrowly instead of adopting DJ James's implied term about keeping the barriers working. On formation he reads an offer of permission into a sign containing no permissive words, because it is "so obvious as to go without saying".

None of it probably would have arisen if the defence had denied that the signs formed a contract and said why. Neither defence engages with formation at all.

Car1980

Yes, not particularly helpful for anyone and plenty I disagree with. I have no particular issue with a no stopping contract in principle. I do take issue with the notion that you have to stop to read a no-stopping contract and get "slapped', as they say, with a charge. The contract cannot be refused either as there is no turning back option. And not forgetting they sometimes incorporate zebra crossings - in effect an instruction to stop. Not to mention where stopping is required in the normal course of driving, or situations such as breakdowns and being caught behind someone in the course of breaking down.

There needs to be a specific section in the code of practice:

• No stopping zones require each driver to stop at the entrance and read the contractual terms and must be include a stop sign and solid line, and preferably a speed hump.

• There must be a facility for a driver to refuse the contract and leave.

• No cameras must be positioned in proximity to zebra or pedestrian crossings.

• There must be a 5 second grace period to cover any brief, inconsequential stoppage. The area must not be treated as one giant yellow box junction.

• There must be double red lines throughout the no-stopping zone.

At least VCS can't really quote from it in their cases since they lost.

The message is still - avoid Bristol County Court for any no-stopping cases!

daveyjp

If you stop at Leeds Bradford to read the sign you are on adopted highway red route so receive council PCN instead!