Free Traffic Legal Advice

Intro:
On Tuesday the 13th June I received 2 Bus Lane PCN's through the post:
BQ95001402-Bridge St Interchange and BQ95005287-Bridge St Hall Ings in Bradford.
They are both date 20/05/2023 at 15:56 (both for the exact same time - See documents).

https://imgur.com/a/wxvSOGw

Summary:
On the 20th May 2023, my father borrowed my vehicle to visit a few friends up north. Neither myself nor my father know Bradford very well. Unbeknown to them they had drove in a bus lane that day. Both letters (PCN's) state the same time for the same contravention. I contacted Bradford City Council to question why they think its acceptable to issue 2 bus lane pcn's on the same stretch. The response I got was, pay one and appeal the other on the grounds that it is unfair and they will cancel it.

As i am unaware of the area, i am unable to locate the exact stretch on google maps.
Google Street View Bridge Street:
https://goo.gl/maps/exNTkGLqMwTxzExu8

Google Street View Hall Ings:
https://goo.gl/maps/JYiP9cQurwEnERrL7

Conclusion:
My question is, are they within their right to issue 2 x PCN's for the same stretch (contravention)?
Should i appeal one and what would be my best argument other than what i was told by the call handler?

Thank you Mike,
I was planning on paying the one but not the other, just don't know how to go about it.
As I still have a couple of weeks, should I wait for someone r.e the validity of the PCN before I pay one?
Secondly, do I just draft a simple paragraph stating 2 pcns for the same contravention is unfair?

Can we see the remaining pages of the PCN please?

The response I got was, pay one and appeal the other on the grounds that it is unfair and they will cancel it.

We need to see this response as well please.

Can't see any obvious technical grounds, so a basic challenge will have to do:

---

Dear City of Bradford Metropolitan District Council,

I am challenging PCNs BQ95001402 and BQ95005287. Both PCNs were issued in under a minute on the same road, and I have not been able to locate any evidence of any signage, nor is any shown in any of the videos or photographs on the council website.

If you are not willing to cancel both penalties, I would ask that you at least cancel one of them and then allow me to pay the other at the 50% rate.

Yours faithfully,

---

If you send a single letter in the post, there's a chance they might only consider it as a representation against one of them, which then amounts to a procedural impropriety of failing to consider the representation against the other one, so this is one of the rare cases where I'll suggest a letter in the post would be best. But make sure to keep a copy, and get a certificate of postage from the post office (don't send it recorded delivery, a certificate of posting is free).

You won't hear back for weeks, but as long as you submit representations during the initial discount period, the rejection letter will re-offer the discount for at least another 14 days from the date of the letter.

I'm going to have a look for the TROs, we've had strange things turn up in this sort of scenario before.

Ok, now I'm confused. Am I sending this letter?

Yes

Apologies if I come across thick but the last 2 posts before this post have gone over my head.

Don't worry, that's more of an internal discussion amongst experts, I have requested the traffic orders and I'll post them on here when they come back. If they open more avenues of appeal, I'll explain in more detail in due course.

Also, if I send the letter with just proof of  postage, can't they just say they never received it.

If they receive it they're not going to lie and say that they didn't. Also as long as you can prove you posted it, there is a legal presumption it was received, see https://www.legislation.gov.uk/ukpga/1978/30/section/7