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What you are really trying to achieve is cancellation of the PCN so you pay nothing, because that avoids the £160 charge, the loss of the discount, and the later enforcement route if it is ignored. Ealing says you must challenge the PCN first, and if they reject it the next stage is an appeal to London Tribunals; if you go that far you are dealing with the full charge, not the discount.

On what you have shown me, this is not really a red light case. The notice says 32JD, meaning the council allege you failed to follow a blue mandatory direction sign and went the wrong way. If the CCTV shows a clear right-turn-only sign and your car going straight, the core defence is weak. "I did not realise" and "I thought going straight was safer" explain the mistake but usually do not defeat the PCN. The real issue for an adjudicator, meaning an independent tribunal judge, is whether, on the balance of probabilities, meaning what is more likely than not, the council can prove the signed direction was clear and that your vehicle did not follow it.

Your best point is evidence, not sympathy. Ask immediately for the full CCTV and check the junction yourself. Was the blue arrow plainly visible, unobscured and positioned so a driver in that lane would actually see it? Were the road markings worn, confusing or inconsistent? Does the video clearly show your vehicle disobeying the sign, or only part of the manoeuvre? I am assuming you are also the owner, meaning the person legally pursued for payment; if you were not the owner, or the vehicle was sold, hired, taken without consent or the PCN was served late, the position changes materially.

My candid view is arguable only if the signage or video is genuinely poor; otherwise prospects are weak. The council's best answer will be simple: clear sign, clear CCTV, driver error. To reduce that risk, make a representation, meaning a formal written challenge, within 28 days, focus on signage, visibility, lane markings, camera angle and any defect in the PCN, and do not waste space on not knowing a PCN could be issued. How far are you willing to push this if the discount is lost, what dated independent material do you have, and would you accept paying the discounted amount if the video is plainly against you? The next milestone is to obtain the video and page 2, then decide quickly whether there is a real evidence point or whether this is one to pay at the discount.

Hi, yes, I had taken picture of the first page (not the second page) before I misplaced it.

This is arguable but probably not for a DIY appellant.

Hi, Thanks for all the replies so far, What do you advise to put in the representation ? i need to file one soon.

Hello Experts,

Any advice on this one? I think the deadline for filing representation is today.

Thanks for clarifying, date on the notice was 26th March and when we add 28 days, it comes to 22/23rd April. Do we also need to account for postal time to find out the date of service of the notice?

Thanks for your guidance @Hippocrates , I have submitted below representation and kept screenshots, hope this looks ok?


I make representations against this Penalty Charge Notice on the following grounds.

The PCN fails to comply with mandatory statutory requirements

The PCN does not correctly convey the statutory time periods required under Schedule 1 to the London Local Authorities and Transport for London Act 2003.

The legislation requires that a Penalty Charge Notice clearly state that the penalty charge must be paid before the end of the period of 28 days beginning with the date of the notice. However, the wording used in this PCN instead refers to, or conflates, the “date of service” and the “date of the notice”, which are legally distinct concepts.

This creates ambiguity as to the applicable time period. A recipient cannot be expected to infer the correct legal position where the notice itself is unclear. The statutory requirements are mandatory, and a failure to properly state them renders the PCN invalid.

Further, the PCN uses wording such as “pay or make representations,” which improperly combines two separate statutory rights. The right to make representations and the obligation to pay are distinct, and the wording used fails to accurately convey this, creating further uncertainty.

The wording relating to any increase in the penalty charge is also unclear and does not properly reflect the statutory sequence required by the Act.

It is well established that a PCN must strictly comply with the requirements of the enabling legislation. Any ambiguity or misstatement amounts to a procedural impropriety and renders the notice unenforceable.

The alleged contravention did not occur due to inadequate signage

Without prejudice to the above, I submit that the alleged contravention did not occur because the signage at the location was not adequate to clearly convey the restriction.

The enforcing authority is put to strict proof that the signage complied with the requirements of the Traffic Signs Regulations and General Directions 2016 and was sufficient to inform a reasonably diligent motorist of the restriction.

The signage was not sufficiently clear, prominent, or comprehensible when approached in normal driving conditions. Any restriction must be conveyed in a manner that allows a driver adequate time to read, understand, and safely comply. If signage is obscured, positioned too late, or otherwise confusing, it fails to meet this requirement.

If the authority contends that the signage was compliant, I require strict proof in the form of contemporaneous photographs, a site layout plan, and evidence demonstrating that the signage was correctly positioned, visible, and maintained.

In the absence of such evidence, the authority cannot discharge its burden of proof, and the alleged contravention cannot be established.

In light of the above, I request that the Penalty Charge Notice be cancelled.