Appeal Your Manchester Airport Drop-Off Charge

I appeal as the registered keeper of the vehicle. I am not obliged to identify the driver and decline to do so.

1. The parking charge is not notified until after the contract is entered into. Under the principles established by the Court of Appeal in Thornton v Shoe Lane Parking [1971] 2 QB 163, a term introduced after a contract has been formed does not become part of that contract. The charge therefore forms no part of any contract between the driver and the operator.

2. The signage is not compliant with the BPA Code of Practice. The charging terms were not displayed clearly, prominently, or legibly at a point where the driver could have made an informed decision to avoid the zone before entering it. No valid contract was formed.

3. The vehicle was present in the drop-off zone for no more than 5 minutes. The driver is entitled to the 5-minute consideration period expressly mandated by the BPA Code of Practice, during which no charge may be levied.

4. Under the Protection of Freedoms Act 2012, keeper liability cannot be transferred for breaches of the operator's own statutory duties or breaches of the Code of Practice. The operator has failed to comply with the requirement to display adequate signage and therefore cannot pursue the registered keeper.

5. The charge is not a genuine pre-estimate of loss and is therefore an unenforceable penalty at common law. The operator has suffered no identifiable loss as a result of the vehicle's presence in the drop-off zone.

Any one of the above grounds is sufficient on its own to require cancellation of the PCN. I require this charge to be cancelled and invite the operator to confirm cancellation in writing.