Given the council's rejection of your initial appeal, consider the following steps:
Review the Traffic Management Order (TMO): Analyse Croydon Council's Traffic Management Order for Springfield Road. Identify any exemptions for residents that may not have been properly communicated, highlighting procedural unfairness.
Mitigating Circumstances: If escalating to an independent adjudicator, argue that your brother's lack of awareness was a reasonable mistake based on the expectation that a resident should not need repeated administrative approval to access their own street.
Proof of Residency: Provide evidence like utility bills to support that your brother's entry was an honest mistake based on a reasonable assumption of access rights as a resident.
Proportionality Assessment: Emphasise that the enforcement was disproportionate, as your brother's mistake posed no safety risk or inconvenience to others, arguing for a more lenient response.
Seek Formal Appeal Assistance: Hippocrates, whose expertise lies in this field, or a solicitor specialising in traffic law to review for procedural errors or further appeal options.
In appealing to the adjudicator, focus on equity, proportionality, and your brother's genuine misunderstanding as a resident.
My 2p.
