Free Traffic Legal Advice

Hi all.

I gave my car to a car rental company who hired the car out to a third party.
due to this i have received a few pcn's from tfl and other london councils as well private car parks.

when appealing i unknowingly appealed as the hire company and uploaded only the agreement between the hire company and the third party client.

turns out the hire agreement was missing some time stamps of when the hire started and ended. due to this tfl and camden council have rejected transferring of liability to the third party hirer.

i am now as a last resort appealing via the london tribunal and have drafted the following with the help of ai.

i just wanted to double check this double check this by someone.

______________________________________________________________________________________________________________________________________________________________

Updated Appeal Text for the Adjudicator
Subject: Formal Appeal Against PCN [Insert PCN Number] – Rectification of Representation Error and Proof of Custody Chain
I am appealing this Penalty Charge Notice as the Registered Keeper  [source: 1]. I object to Transport for London’s (TfL) decision to hold me liable, as the vehicle was entirely out of my physical custody and operational control during the material time.
1. Clarification of the Initial Representation
I wish to clarify an administrative error made during the initial representations to TfL. Upon receiving the notice, I unknowingly submitted the appeal under the name of my vehicle management operator, , using the documentation they provided me [source: 1, 4]. This prompted TfL to reject the representation and demand a letter from an accountant or solicitor to verify corporate authority. I am now lodging this formal tribunal appeal in my proper legal capacity as the individual Registered Keeper, which renders TfL’s demand for third-party professional certification completely redundant.
2. Evidential Break in the Chain of Custody
The enclosed documentation provides an absolute, uninterrupted paper trail showing I had no access to the vehicle during the contravention dates in June 2026:
Primary Commercial Tier: On 8th June 2026, I entered into a formal contract transferring "full operational custody, management, and commercial control" of vehicle LS19 YXP to Sainex Motor Group Ltd [source: 1].
Secondary Consumer Tier:  subsequently sub-hired the vehicle to an end-user, , for the specific period of 09/06/2026 to 30/06/2026 [source: 5]. All alleged contraventions occurred firmly within this window.
3. Technical Defect in Sub-Hire Agreement
The consumer hire agreement lists the correct dates but omits the exact start and end times [source: 5]. Because the Congestion Charge is a time-restricted scheme, a consumer hire contract must feature precise timestamps to legally shift liability to the driver under Schedule 2 of the Road Traffic (Owner Liability) Regulations 2000. Because the sub-hire contract is technically flawed, TfL cannot hold the end-driver liable. However, their lawful recourse is to hold the intermediate commercial operator (S liable as the primary corporate custodian of the asset [source: 1], rather than penalising the remote registered keeper.
I respectfully request that the Adjudicator allow this appeal and direct TfL to cancel this notice against me.

It's nonsense.

Starting at the beginning, what are your grounds of appeal?

If they are they you are a 'vehicle hire company' and that the vehicle was hired under a 'hiring agreement' to someone who had signed a 'statement of liability', then we know where we are.

So, are you a vehicle hire company and does your agreement with the car rental company include the following mandatory elements(as regards penalty charges) and did they sign a statement of liability and have these been presented in evidence?

https://www.legislation.gov.uk/uksi/2000/2546/schedule/2/made

If not, then you will not succeed under the grounds of hiring etc.

But as we don't know your grounds of appeal, then .......!

From what I've seen so far in many posts 'the help of AI' is an oxymoron!

It is irrelevant, except from the point of view of misrepresentation(read the statement of truth you signed), what the 'car rental company's' Ts and Cs are, they are not the registered keeper and therefore by default not the person liable for penalties.

But all might not be lost. If, as seems very likely, you fail at adjudication you would have at least attempted to mitigate your losses and therefore if you were to sue the car rental company, you would have at least done your bit.

Im personally not a hire company. I got into an agreement with a hire company who hire out the car and split the profits.

The grounds of appealing i guess would be that i wasnt in posession of the car at the time of the contravention.

the car hire agreement between the car rental company and the customer does have start and end dates but not times.

The owner is liable though. Was there any paperwork or discussion about PCNs, NIPs etc with this arrangement?

this is my contract with the car rental company.
https://postimg.cc/y3dWGDwx

they have in turn their own car hire agreement with the hire who incurred the contraventions.

It seems to me that despite your agreement with the hire company, you are still liable, as the owner of the car, and you hold the V5C.

Best to test your case at adjudication.

There are 40 odd pcns.

Is it worth appealing at the tribunal or should i cut my losses and chase the rental company