Accident: Illegally Parked Car, Bumped - Whose Fault is It?

This happened yesterday, April 15, 2008 around 4PM
Scenario : The gold car was parked in a no-parking zone of a store parking lot (metered). The silver car which was parked properly began backing up, and due to limited space, the driver accidentally hit the gold car, denting its bumper.
Whose fault is it?
Place : In front of metered parking lot of a store at the corner of Academy and Bergen Avenue, Jersey City. Right across Bergen Avenue is the Bergen Square.
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