royston,
If you are going to try and argue your case by refering to the ANO, I suggest that you quote the correct section, in it's entirety.
Rule 5, (3), (a), (ii) Exemptions from the low flying prohibitions states:
Any aircraft shall be exempt from the 500 feet rule when landing and taking-off
in accordance with normal aviation practice. (My emphasis).
Now then, arriving unannounced at a non-licenced site (without the landowner's permission) and allegedly landing in a car park (which was full of cars at the time) is hardly 'in accordance with normal aviation practice', is it?