Author Topic: Bromley Code 34J Being in a Bus Lane, Widmore Road  (Read 677 times)

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Hippocrates

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Re: Bromley Code 34J Being in a Bus Lane, Widmore Road
« Reply #30 on: February 11, 2024, 02:46:30 pm »
Sorry for the late post:  DNCed.  Costs application to follow.
There are known knowns which, had we known, we would never have wished to know. It is known that this also applies to the known unknowns. However, when one attends a hearing, Mr Rumsfeld's idea that there are also unknown unknowns fails to apply because, anyone who is in the know, knows that unknown unknowns are purely a deception otherwise known as an aleatory experience or also known as a lottery. I know that I know this to be a fact and, in this knowledge, I know that I am fully prepared to present my case but, paradoxically, in full knowledge that the unknown unknowns may well apply in view of some adjudicators' lack of knowing what they ought to know through no fault of their own.

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Martyn21uk

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Re: Bromley Code 34J Being in a Bus Lane, Widmore Road
« Reply #31 on: February 12, 2024, 09:32:15 am »
Sorry for the late post:  DNCed.  Costs application to follow.

Thanks for all of your help Hippocrates!
 


Hippocrates

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Re: Bromley Code 34J Being in a Bus Lane, Widmore Road
« Reply #32 on: February 12, 2024, 12:44:30 pm »
Let's get on with the costs, Marve!
There are known knowns which, had we known, we would never have wished to know. It is known that this also applies to the known unknowns. However, when one attends a hearing, Mr Rumsfeld's idea that there are also unknown unknowns fails to apply because, anyone who is in the know, knows that unknown unknowns are purely a deception otherwise known as an aleatory experience or also known as a lottery. I know that I know this to be a fact and, in this knowledge, I know that I am fully prepared to present my case but, paradoxically, in full knowledge that the unknown unknowns may well apply in view of some adjudicators' lack of knowing what they ought to know through no fault of their own.

"Hippocrates"
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Hippocrates

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Re: Bromley Code 34J Being in a Bus Lane, Widmore Road
« Reply #33 on: April 03, 2024, 09:05:52 am »
@cp8759 @Martyn21uk

Well, after not bothering to attend yesterday in another case, they have no comment to make re this application.  ;)
« Last Edit: April 03, 2024, 09:07:55 am by Hippocrates »
There are known knowns which, had we known, we would never have wished to know. It is known that this also applies to the known unknowns. However, when one attends a hearing, Mr Rumsfeld's idea that there are also unknown unknowns fails to apply because, anyone who is in the know, knows that unknown unknowns are purely a deception otherwise known as an aleatory experience or also known as a lottery. I know that I know this to be a fact and, in this knowledge, I know that I am fully prepared to present my case but, paradoxically, in full knowledge that the unknown unknowns may well apply in view of some adjudicators' lack of knowing what they ought to know through no fault of their own.

"Hippocrates"
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Hippocrates

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Re: Bromley Code 34J Being in a Bus Lane, Widmore Road
« Reply #34 on: April 03, 2024, 12:23:29 pm »
Costs allowed. A walk in the park.
There are known knowns which, had we known, we would never have wished to know. It is known that this also applies to the known unknowns. However, when one attends a hearing, Mr Rumsfeld's idea that there are also unknown unknowns fails to apply because, anyone who is in the know, knows that unknown unknowns are purely a deception otherwise known as an aleatory experience or also known as a lottery. I know that I know this to be a fact and, in this knowledge, I know that I am fully prepared to present my case but, paradoxically, in full knowledge that the unknown unknowns may well apply in view of some adjudicators' lack of knowing what they ought to know through no fault of their own.

"Hippocrates"

Hippocrates

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Re: Bromley Code 34J Being in a Bus Lane, Widmore Road
« Reply #35 on: April 04, 2024, 11:25:02 am »
Grounds for the application

1. From the outset, Mr ***** raised the issue of camera certification and authorisation which was intransigently resisted by the council.
2. The council were fully aware that they, the council, did not possess a valid certificate until they applied for one on 9th August 2023. Yet, they persisted in relying solely upon their manufacturer’s certificate, the terms of which are abundantly clear.
3. The council only adduced as evidence the said manufacturer’s certificate and I say this is wholly unreasonable.
4. The evidence clearly shows that Bromley were one of two councils who were rather tardy in applying for their certificate which they knew post-dated the alleged contravention. Yet, they still resisted Mr ****’s valid issues raised, resulting in far too copious and unnecessary correspondence throughout the unnecessarily prolonged  statutory process.

In light of the above, I consider that the council’s conduct in its pursuit of this case to be wholly unreasonable. I enclose Mr ****'s Witness Statement vis a vis costs post the Notice of Rejection which I consider to be wholly fair and  reasonable under the circumstances.

I also said it was arguable that the provision of just the manufacturer's certificate, but not the council's certificate, was disingenuous. (Pronounced incorrectly as per my Celtic tendency!)  At least I am not as garrulous as I used to be.  ;)

Decision to follow.

Mountain climber do say: To win an appeal is like climbing Mt. Everest. To win costs is like climbing said mountain without oxygen equipment.   But, yesterday, we ran up and down in about 5 minutes!
« Last Edit: April 04, 2024, 03:02:50 pm by Hippocrates »
There are known knowns which, had we known, we would never have wished to know. It is known that this also applies to the known unknowns. However, when one attends a hearing, Mr Rumsfeld's idea that there are also unknown unknowns fails to apply because, anyone who is in the know, knows that unknown unknowns are purely a deception otherwise known as an aleatory experience or also known as a lottery. I know that I know this to be a fact and, in this knowledge, I know that I am fully prepared to present my case but, paradoxically, in full knowledge that the unknown unknowns may well apply in view of some adjudicators' lack of knowing what they ought to know through no fault of their own.

"Hippocrates"