Why airport drop-off zones are not 'relevant land' under POFA

From the AppealAirportPCN team • LAST UPDATED: OCTOBER 2026

The "relevant land" rule is an important point in many airport parking appeals. It may sound technical, but the basic idea is simple.

You do not have to become an expert in it. Our airport appeal templates include the argument in plain language.

What is relevant land?

Schedule 4 of POFA lets a parking company claim a charge from the registered keeper in some cases. But it only applies to "relevant land".

The Act excludes land where parking is subject to statutory control. This means rules made under law, rather than rules based only on a private contract. Airport byelaws are one example. They can be made under the Airports Act 1986.

Why airport land may be excluded

Many major UK airports have byelaws that cover how people use airport land, including vehicle movements and parking. Where the relevant land is subject to statutory control, it may not count as relevant land under POFA. Schedule 4 would then not let the company transfer the charge to the keeper.

This is why the details matter. Check the byelaws and the location named on your notice. Read our plain-English guide to POFA and keeper liability.

Key point: The relevant-land exclusion comes from POFA itself. Whether it applies depends on the land and the circumstances. If it applies, the company generally needs to show who was driving to pursue a claim against that person.

What it means for you

If you are the registered keeper but were not driving, a company may be unable to use POFA Schedule 4 to make you liable. You are not generally required to identify the driver just because you received a private parking notice. Do not give false information.

See our separate guide to Elliott v Loake and keeper liability for more on claims that the keeper must have been driving.

Limits

  • Each airport has its own byelaws. Check the ones for your airport.
  • The byelaws have to cover parking on the land where you stopped. Section 63 of the Airports Act leaves out roads where road traffic law already applies.
  • The government can change the "relevant land" rule. It did this for railway stations in 2025.

Sources

  1. Protection of Freedoms Act 2012, Schedule 4, paragraph 3, including the statutory-control definition in paragraphs 3(3) and 3(4). Primary. Legislation.gov.uk
  2. Airports Act 1986, section 63 (byelaws on regulating parking; excludes roads where road traffic enactments apply). Primary. Legislation.gov.uk
  3. Airports Act 1986, section 64 (penalties: a fine on summary conviction). Primary. Legislation.gov.uk
  4. R (Scott) v Heathrow Airport Ltd [2005] EWHC 2669 (Admin) (confirms the Heathrow Airport–London Byelaws 1996). Primary. National Archives case law
  5. The London Luton Airport (Penalty Fares) Order 2021, article 2 (refers to the London Luton Airport Byelaws dated November 2005). Primary. Legislation.gov.uk
  6. Heathrow Airport, terminal drop-off charge page (APCOA contact for refunds). Primary. Heathrow
  7. Forum discussions of airports as non-relevant land, including a Stansted operator reply accepting that airport land is under statutory control. Community. Discussion 1 and discussion 2
  8. The Protection of Freedoms Act 2012 (Definition of Relevant Land) (Amendment) Order 2025. Primary. Legislation.gov.uk
Disclaimer: This article is for information only and does not constitute legal advice. For complex cases, consult a solicitor or Citizens Advice.