+1
The service of an NtO without serving the PCN, is a major procedural impropriety which is normally a slam-dunk win at London Tribunals. There is a clear legal process defined in the Traffic Management Act to deal with so-called "driveaways". This process is for cases where the CEO was in course of preparing a PCN to serve to the car or driver, but the driver drove off before it could be served. The correct procedure is then to serve a postal PCN, which on it explains why the PCN has been served by post. No Notice to Owner is ever served under this process, because the postal PCN covers the role of the NtO.