Free Traffic Legal Advice

Hi everyone,

I’m in the middle of appealing a council PCN and it has now reached the adjudicator stage. I just want a final sense check before I submit my appeal.

KEY FACTS / TIMELINE

* PCN date: 05/03/2026
* I paid for the vehicle: 07/03/2026 (bank transfer proof available)
* DVLA keeper update processed: 11/04/2026
* DVLA Subject Access Request (SAR) shows a transaction timestamp of 11/04/2026

MY SITUATION

I bought the vehicle via Facebook Marketplace. The important point is that I did not acquire or pay for the car until 07/03/2026, which was after the PCN was issued.

The council's position is essentially that DVLA shows me as the registered keeper, so I am liable. They have repeatedly asked me for details of the previous keeper, but I do not have those details because it was a private Facebook Marketplace sale.

My understanding is that liability depends on whether I was actually the owner/keeper at the time of the contravention, not simply whether DVLA later recorded me as the registered keeper.

EVIDENCE I HAVE

* Bank transfer showing payment for the vehicle on 07/03/2026
* Facebook Marketplace messages showing arrangements to meet the seller and photographs of the vehicle
* DVLA confirmation email dated 11/04/2026
* DVLA SAR showing a transaction timestamp of 11/04/2026
* The PCN dated 05/03/2026

MY ARGUMENT

My position is straightforward:

I could not have been the owner or keeper on 05/03/2026 because I did not acquire the vehicle until 07/03/2026.

The DVLA record reflects a later registration process and does not change the fact that the alleged contravention occurred before I purchased the vehicle.

QUESTIONS

1. Does this sound like a strong appeal to an adjudicator?

2. Are there any tribunal appeal templates that would suit these circumstances?

3. Has anyone had experience of a council continuing to rely on DVLA records despite evidence showing the vehicle was purchased after the contravention date?

I have already appealed twice using the evidence above and both appeals were rejected, which is why I am now at adjudicator stage.

Any thoughts or advice would be greatly appreciated.

Thanks in advance.

What is the PCN for, and what paperwork did you get.

The PCN was issued because the the car was seen parked in a permit bay without a permit or a voucher issued for that parking place.

I got paperwork from the Royal borough of Greenwich stating the following -

We refer to the representations made by you in connection with the issue of the above Penalty Charge Notice (PCN) and Notice to Owner.

The PCN was issued to you because your vehicle was seen parked in a permit bay without a permit or a voucher issued for that parking place.

We have investigated the circumstances raised in your correspondence and have made the decision to not cancel your notice. The reasons for our decision are set out below, along with the options available to you at this stage.

You have explained that you were not the owner of the vehicle at the time of the incident.
The DVLA sent us your details as being the registered keeper of the vehicle on the date of the contravention. Under the above legislation, the registered keeper / owner of the vehicle is responsible for the PCN.

If the DVLA records show that you were the registered keeper of the vehicle on the date of the contravention, then even though you may not have owned the vehicle at the time, it still remains your responsibility to ensure the DVLA record is updated (so as to avoid future PCNs) and to obtain written proof to show that you were not the owner of the vehicle at the time.

In our previous letter to you we requested that you provide us with the relevant proof of the full details of the keeper which includes their address to prove your statements, which you have been unable to provide. We are therefore, not prepared to accept this point in your representation.

Quote

They have repeatedly asked me for details of the previous keeper, but I do not have those details because it was a private Facebook Marketplace sale.

So how did you handle the V5C transfer process, which requires you to fill in the new owner details ? Also see Section 12 of the V5C on what you must do as a registered keeper.

The vehicle was purchased through Facebook Marketplace and the V5C I received did not  match the details of the person I dealt with. I therefore did not have reliable details for any previous keeper.

However, I don't think that changes the key issue in this case. The alleged contravention occurred on 05/03/2026 and I did not purchase the vehicle until 07/03/2026, as evidenced by my bank transfer.

Regardless of any later DVLA registration issues or the accuracy of the V5C details, I was not the owner or keeper on the date of the contravention. That is the point I am relying on before the adjudicator.

And was 05 March 2026 the date of the parking contravention or the date of issue of the PCN?

You've said both in different posts

Do you not know why Greenwich seem to be convinced that you were RK on the date of the contravention when you say you only became RK wef 07 March 2026, and that that is what the DVLA shows? 

"... The DVLA sent us your details as being the registered keeper of the vehicle on the date of the contravention..."

What does it say on your V5C as to the date you acquired the car?

The date I transferred the car to myself was 11/04/2026

Quote from: janss1234 on June 11, 2026, 09:54:49 pm

Quote from: ManxTom on June 11, 2026, 09:27:42 pm

And was 05 March 2026 the date of the parking contravention or the date of issue of the PCN?

You've said both in different posts

Do you not know why Greenwich seem to be convinced that you were RK on the date of the contravention when you say you only became RK wef 07 March 2026, and that that is what the DVLA shows? 

"... The DVLA sent us your details as being the registered keeper of the vehicle on the date of the contravention..."

Yes, 05 March 2026 was the date of the PCN and I bought the car on 07 March 2026, The DVLA sent us your details as being the registered keeper of the vehicle on the date of the contravention I dont understand how this is possible when I bought the car after the PCN was received, I did do a SAR on the car and it shows I was the RK on the 11/01/2026, a whole two months before I even went to see the car. The car was likely in trade, is it possible to place a person as RK even before buying the car if the car is in trade?

Ah... you didn't mention that earlier...  No idea how you would have been showing as RK nearly three months before you bought it?

You had no earlier connection to the car?

What was the date of the contravention?

And when will your appeal be in front of the adjudicator?

I had 0 connection to the car before I went to buy it, the contravention date was 05 March 2026 and I got a week or so left before I the appeal window closes.

Is it possible that the person who you bought the car from has given your details to the council, either purposely to avoid the charge, or absent-mindedly thinking it wasn't them hence why they are chasing you?

I had 0 connection to the car before I went to buy it, the contravention date was 05 March 2026 and I got a week or so left before I the appeal window closes.

However,
I did do a SAR on the car and it shows I was the RK on the 11/01/2026,

The regs:
Person by whom a penalty charge is to be paid
6.—(1) Where a relevant road traffic contravention occurs, the person by whom the penalty charge is to be paid is to be determined in accordance with this regulation.
.......

4) In a case not falling within paragraph (2), the penalty charge is payable by the person who was the owner of the vehicle involved in the contravention at the material time.

From the Act:

“owner”, in relation to a vehicle, means the person by whom the vehicle is kept, which in the case of a vehicle registered under the Vehicle Excise and Registration Act 1994 (c. 22) is presumed (unless the contrary is proved) to be the person in whose name the vehicle is registered

You have to rebut(to use the legal term) the presumption that even though (for reasons you've not or cannot explain) you were the registered keeper on the day of contravention you did not keep the vehicle.

The authority had DVLA's record of RK, so they're not to blame. IMO, just because you bought the vehicle on day X does not mean you had not kept it before, for all anyone knows you had it on approval for months before and were testing it, or whatever.

IMO, focus on 'I had 0 connection to the car before I went to buy it' and collect everything in your mind to prove this e.g. did you have another car etc.