Thank you again for all the time you've spent helping me with this.
Based on the advice I've received, I think the appropriate route now is to write to the Strategic Director responsible for Parking Services and copy in the Head of Law, relying on the evidence disclosed in the SAR rather than the parking enforcement process itself.
I've drafted the letter below. Before I send it, I'd be very grateful if anyone could cast an eye over it and let me know if there's anything you would change, add or remove.
Many thanks again.
**For the attention of:**
Aled Richards
Strategic Director, Environment, Sustainability and Leisure
**Copied to:**
Sarah Feasey
Head of Law
**Re: PCNs JK17263522, JK17298185, JK17309044 and JK17310112 relocation of vehicle by Southwark Council**
Dear Mr Richards,
I write following receipt of Southwark Council's response to my Subject Access Request relating to the above Penalty Charge Notices.
Having now reviewed the material supplied by the Council, it is clear that the factual basis on which these PCNs were issued is fundamentally different from that previously understood.
The Council's own records confirm that:
* my vehicle was lawfully parked in a residents' permit bay on Amelia Street;
* a filming suspension was subsequently introduced on 25 September 2025;
* Council officers attended and photographed the vehicle in the suspended bay;
* the vehicle was then relocated by the Council from Amelia Street; and
* following that relocation, the vehicle was left in a Pay by Phone bay on Crampton Street, where the subsequent PCNs were issued.
These are not matters of recollection or assumption. They are demonstrated by the Council's own suspension records and photographs disclosed under the Subject Access Request.
At no stage was the vehicle under my control when it was relocated. The Council made the decision as to where the vehicle should be placed.
Had I personally parked the vehicle in a Pay by Phone bay and left it there without payment, I would understand why enforcement action followed. However, that is not what occurred.
Instead, the Council chose to relocate a residents' permit holder's vehicle into a location where it immediately became liable to enforcement. The subsequent penalties arose solely because of the location selected by the Council.
I fully acknowledge that my handling of the later enforcement process was less than ideal. In particular, I did not pursue an appeal following the Notice of Rejection relating to PCN JK17263522, and I have now paid that PCN in order to avoid further enforcement action and the substantial additional costs associated with the Order for Recovery process.
However, payment was made solely to prevent further enforcement and should not be taken as an admission that the underlying liability was properly incurred.
The Council's own evidence now demonstrates that the sequence of events began with the Council relocating my vehicle. In those circumstances, I ask the Council to consider whether it is fair or lawful for penalties to have arisen as a direct consequence of that relocation.
I therefore request that the Council:
1. Immediately cease enforcement of any outstanding PCNs arising from the relocation.
2. Cancel any outstanding penalties associated with the vehicle following its relocation to Crampton Street.
3. Refund the payment made in respect of PCN JK17263522.
4. Explain why the vehicle was relocated to a Pay by Phone bay rather than to an equivalent residents' permit bay or another lawful location.
I hope the Council will now review this matter in light of its own records and resolve it without the need for a formal complaint to the Local Government and Social Care Ombudsman or any further escalation.
I look forward to your response.
Yours faithfully,
