05/02/2026
Mr Jackson Yamba Secures Landmark Parking Enforcement Decision
A Watershed Moment for Motorists Across England and Wales
Mr Jackson Yamba has secured an important and consequential appeal judgment that will fundamentally impact the parking enforcement industry. The decision in Euro Parking Services Ltd v Mr Nicholas Bryant before HHJ Brownhill establishes critical legal principles regarding statutory compliance with the Protection of Freedoms Act 2012.
The Core Issue: Issue Date vs. Posting Date
The judgment clarifies a fundamental distinction that parking companies have systematically misunderstood: the posting date and the issue date are not the same thing for statutory purposes .
Under Schedule 4, paragraph 9(2)(f) of the Protection of Freedoms Act 2012, the Notice to Keeper is statutorily required to specify the date on which the notice is sent—whether posted or delivered by hand.
The Act further provides that when a notice is sent by post, it is presumed to be given (delivered) on the second working day after posting , not on the date of posting itself.
Euro Parking failed this requirement. By referencing the "issue date" (the posting date of 23 March) rather than the date the notice was deemed given (27 March), the Notice to Keeper did not comply with the mandatory statutory framework.
The Compliance Failure: Incorrect Payment Deadline
Beyond the dating error, Euro Parking's notice contained an additional statutory violation
The Notice stated: "Payment is required within 28 days of the issue date" (i.e., by 20 April 2023)
The statute requires: "Payment must be made after 28 days beginning with the day after that on which the notice is given"** (i.e., by 24 April 2023)
This is not merely a semantic difference. The notice gave motorists an incorrect and earlier deadline than the law permits .
HHJ Brownhill concluded:
"The explanation given on the face of the notice as to how to calculate that deadline was also wrong. It referred to the 28 days from the issue of the notice. It did not refer to the wording of paragraph 9(2)(f) of Schedule 4. On that basis, it seems to me the notice was invalid ."
Why This Matters: Mandatory Compliance is Non-Negotiable
The Notice to Keeper is a statutory notice . The provisions of Schedule 4, paragraph 9(2) are mandatory , not discretionary. As HHJ Brownhill found:
"Given its purpose and effect, the provision of the correct date is clearly important ."
A reasonable recipient cannot be expected to calculate a deadline when the notice provides an incorrect date and explanation. The notice must be sufficiently clear and unambiguous to leave no doubt about when payment is actually due.
Euro Parking's notice failed this test. The result: the Notice to Keeper was invalid, and the entire claim was dismissed .
A Victory for Motorists
This judgment represents a watershed moment for motorists. It establishes that parking companies cannot rely on technical shortcuts or sloppy administrative procedures. Compliance with the Protection of Freedoms Act 2012 is absolute and enforceable .
If you have received a parking charge notice with an incorrect or unclear payment deadline, you now have legal grounds to challenge it.
Justice served.
