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Redbidge council cctv PCN

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Redbidge council cctv PCN
on:
#1
Hello there folks, (already posted in pepipoo and was asked to post here again just in case)

I have received a cctv PCN from redbridge council, with the contravention :
STOPPED ON RESTRICTED BUS STOP OR STAND
Location : CRANBROOK ROAD ILFORD (A)
DATE 01/08/2023

On that day I had to pick up my disabled wife and kids who were on the bus and they got off for me to pick them up, it was night time so did not pay attention, I stopped for few seconds for them to get on and then drove off.

I do not understand the councils location CRANBROOK ROAD ILFORD (A)! I stopped here
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Find local businesses, view maps and get driving directions in Google Maps.
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picture of pcn :

20230808 155953
Image 20230808 155953 hosted in Freeimage.host
freeimage.host

20230808 160131
Image 20230808 160131 hosted in Freeimage.host
freeimage.host

20230808 160151
Image 20230808 160151 hosted in Freeimage.host
freeimage.host

20230808 160201
Image 20230808 160201 hosted in Freeimage.host
freeimage.host




All your inputs will be much appreciated.

Thanks
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Re: Redbidge council cctv PCN
Reply #1 on:
#2
The contravention is clear-cut:



Next time stop on the yellow line behind the bus-stop, there's an exemption that allows you to stop to let passengers get in and out of the car, even where there is a no-loading restriction.

There is a possible issue with the camera authorisation, but that will take me some time to investigate. In the meantime send this via the council portal on Sunday 20 August 2023 in order to buy us some time:

Dear London Borough of Redbridge,

I challenge liability because the alleged contravention did not occur. The penalty charge notice alleges a contravention on Cranbrook Road in the vicinity of bus stop A, I do not know where bus stop A is but it is not the location shown in the images on the PCN. It follows that the contravention alleged did not occur.

Yours faithfully,
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I practice law in the Traffic Penalty Tribunal, London Tribunals, the First-tier tribunal for Scotland, and the Traffic Penalty Tribunal for Northern Ireland, but I am not a solicitor or a barrister. Notwithstanding this, I voluntarily apply the cab rank rule. I am a member of the Society of Professional McKenzie Friends, my membership number is FM193 and I abide by the SPMF service standards.

Quote from: 'Gumph' date='Thu, 19 Jan 2023 - 10:23'
cp8759 is, indeed, a Wizard of the First Order
Re: Redbidge council cctv PCN
Reply #3 on:
#4
Quote from: sofnet2000 on August 15, 2023, 10:56:29 pm
Shall I make a representation specifically on sunday 20th?
Yes, make the representation before midnight tonight as that will buy us the most time.
Logged
I practice law in the Traffic Penalty Tribunal, London Tribunals, the First-tier tribunal for Scotland, and the Traffic Penalty Tribunal for Northern Ireland, but I am not a solicitor or a barrister. Notwithstanding this, I voluntarily apply the cab rank rule. I am a member of the Society of Professional McKenzie Friends, my membership number is FM193 and I abide by the SPMF service standards.

Quote from: 'Gumph' date='Thu, 19 Jan 2023 - 10:23'
cp8759 is, indeed, a Wizard of the First Order
Re: Redbidge council cctv PCN
Reply #6 on:
#7
Well, you now have to decide whether to give up, or risk the full penalty at the tribunal.

I think you have some valid grounds to carry on: the explanation as to the location is wholly unsatisfactory because while there might be some internal council classification of zones, to the recipient of the PCN "zone A of Cranbrook Road" is essentially meaningless, it's not as it it says "zone a" on google maps or the ordnance survey, so the point is possibly stronger now than it was before.

Also they've conflated the concepts of service and delivery, which can win on its own as it's been held to be a procedural impropriety.

If you want to carry on, I'm happy to represent you at the tribunal.
Logged
I practice law in the Traffic Penalty Tribunal, London Tribunals, the First-tier tribunal for Scotland, and the Traffic Penalty Tribunal for Northern Ireland, but I am not a solicitor or a barrister. Notwithstanding this, I voluntarily apply the cab rank rule. I am a member of the Society of Professional McKenzie Friends, my membership number is FM193 and I abide by the SPMF service standards.

Quote from: 'Gumph' date='Thu, 19 Jan 2023 - 10:23'
cp8759 is, indeed, a Wizard of the First Order
Re: Redbidge council cctv PCN
Reply #7 on:
#8
Quote from: cp8759 on September 10, 2023, 07:52:29 pm
Well, you now have to decide whether to give up, or risk the full penalty at the tribunal.

I think you have some valid grounds to carry on: the explanation as to the location is wholly unsatisfactory because while there might be some internal council classification of zones, to the recipient of the PCN "zone A of Cranbrook Road" is essentially meaningless, it's not as it it says "zone a" on google maps or the ordnance survey, so the point is possibly stronger now than it was before.

Also they've conflated the concepts of service and delivery, which can win on its own as it's been held to be a procedural impropriety.

If you want to carry on, I'm happy to represent you at the tribunal.
If we got a case I am more than happy to carry on, just let me know what to do next.
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Re: Redbidge council cctv PCN
Reply #8 on:
#9
I'll drop you a PM.
Logged
I practice law in the Traffic Penalty Tribunal, London Tribunals, the First-tier tribunal for Scotland, and the Traffic Penalty Tribunal for Northern Ireland, but I am not a solicitor or a barrister. Notwithstanding this, I voluntarily apply the cab rank rule. I am a member of the Society of Professional McKenzie Friends, my membership number is FM193 and I abide by the SPMF service standards.

Quote from: 'Gumph' date='Thu, 19 Jan 2023 - 10:23'
cp8759 is, indeed, a Wizard of the First Order
Re: Redbidge council cctv PCN
Reply #9 on:
#10
Got this response from the council about these cameras:

Model of camera 1021 on the top: Indigo BX520 HD (Public surveillance camera)
Model of dome static camera on top left: AXIS P3364-VE 12MM (Parking enforcement camera)
Model of dome static camera on top right: AXIS P3364-VE 12MM (Parking enforcement camera)
Model of the static bullet camera on the bottom left: AXIS Q1700-LE (Parking enforcement camera)
Model of the static bullet camera on the bottom right: AXIS Q1700-LE (Parking enforcement camera)
Logged
I practice law in the Traffic Penalty Tribunal, London Tribunals, the First-tier tribunal for Scotland, and the Traffic Penalty Tribunal for Northern Ireland, but I am not a solicitor or a barrister. Notwithstanding this, I voluntarily apply the cab rank rule. I am a member of the Society of Professional McKenzie Friends, my membership number is FM193 and I abide by the SPMF service standards.

Quote from: 'Gumph' date='Thu, 19 Jan 2023 - 10:23'
cp8759 is, indeed, a Wizard of the First Order
Re: Redbidge council cctv PCN
Reply #10 on:
#11
A very thorough and detailed decision by adjudicator Walsh, copy here.
Logged
I practice law in the Traffic Penalty Tribunal, London Tribunals, the First-tier tribunal for Scotland, and the Traffic Penalty Tribunal for Northern Ireland, but I am not a solicitor or a barrister. Notwithstanding this, I voluntarily apply the cab rank rule. I am a member of the Society of Professional McKenzie Friends, my membership number is FM193 and I abide by the SPMF service standards.

Quote from: 'Gumph' date='Thu, 19 Jan 2023 - 10:23'
cp8759 is, indeed, a Wizard of the First Order
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