Adaptis Solutions Railway Byelaw s14

Going to do the DVLA request today - will post exact wording later on, together with washed PCN from Adaptis.

Just to throw another spanner in the works, I was reading POFA 2012 and noticed this:

!!!8220;keeper!!!8221; means the person by whom the vehicle is kept at the time the vehicle was parked, which in the case of a registered vehicle is to be presumed, unless the contrary is proved, to be the registered keeper;

I know they aren't applying on POFA, but either way, in my situation, although I'm the registered keeper, someone else actually keeps the vehicle and drives it. So re this station fine, it genuinely wasn't me driving. I may also be able to argue that I'm not the owner, although I am on the V doc (Although doesn't that say something about not being proof of ownership) as someone has made several payments to me so are half way to owning the car themselves. (A different person to who keeps and drives it at the moment.)

Anyway is it worth me, when appealing mentioning that I am not the keeper as per that definition. It says unless the contrary can be proved, but it doesn't say who I would need to prove it to, or who I would need to tell.

EDIT: I guess there's also the comical option that I reply on Day 25 appealing and include that as part of my appeal. After stringing them along for a while, I could in theory release the current keeper as per that definition, and they would have to do this all again, all wasting time on that 6 months?