Free Traffic Legal Advice

@John U.K. - thank you!

Regarding your question about PCN ZN12411827, the code was 16 and reads "Parked in a permit space or zone without a valid virtual permit or clearly displaying a valid physical permit where required". This is essentially the same as code 12r (it seems). I ommited the appendices to save some room, but will make your suggested edits and add them in on the next post.

Regarding the 14th PCN, I can see no option on the Haringey website for making a rep against it. I assumed the out-of-time link/form here that I filled in here would be sufficient to trigger the ability to reopen it. I sent this via post and so assuming this may take time to receive/process..

Are you suggesting (which your edit seems) that I appeal it within this rep (which was intended for PCNs 2-13)?the moment given the status is currently 'PCN Complete'.

@cp8759 I've sent nothing at this point in time as I have no option to send anything for this specific PCN. The only thing that I have done is submitted this out of time TE7 form here.

There is the option to Haringey's website (when entering the PCN) to 'Contact Us'. In there, I can make some appeal. But not sure if this is redundant given the above?

@cp8759 - that last post was referring to the 14th PCN. I cannot make any representation for this as there is no option to do so (unless you're saying there is somewhere?). I've submitted the out of time form in the meantime, so I assume if that is approved, I will get an opportunity to make a rep.

For the other PCN reps, I agree! I will submit the reps in the next few days.

@cp8759 I've sent nothing at this point in time as I have no option to send anything for this specific PCN. The only thing that I have done is submitted this out of time TE7 form here.

@cp8759 - this one here.

EDIT: I might've misunderstood one of your posts in that it wasn't this form that was meant to be filled in, but rather making a separate rep against the 14th PCN? If this is the case, where do I do this? Do I add this to the rep I'm planning to make against PCN 1 or 2-13? If not where else can this be done?

@cp8759 understood!

Here is my draft to make a rep against the 14th PCN. I've tried my best to give context of the events leading upto it:

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Representation against PCN number ZN12536367

I am writing to make a representation against PCN ZN12536367 issued to me on the 31/05/2024 at 08:08AM.

From April 12th to July 12th, 2024, I was out of the country for work. As a Haringey resident for over five years, I've consistently held parking permits (October 2023 - 6 Months, May 2023 - 6 Months, and May 2022 - 1 Year) and have always renewed them promptly. Unfortunately, during my absence, my permit expired on April 25th, and I don't recall receiving the renewal reminder that the council usually sends.

Due to these circumstances, my car remained stationary in the same location for 61 days without a valid permit. In this period, from May 7, 2024, to May 30, 2024, a total of 13 Penalty Charge Notices (PCNs) were issued. Twelve of these PCNs cited contravention code 12(i), while one cited code 16. Both codes essentially refer to the absence of a valid permit, indicating a continuous contravention throughout this time.

As I was abroad during this entire time and received no follow-up emails, text messages, or letters, I was completely unaware of these penalties.

The penalties imposed in this case have been excessive, as the vehicle should have been removed much sooner. The principle of 'continuous contravention' is fundamental, stating that one should not be punished multiple times for the same offence. This principle has been upheld by numerous adjudicators, and I believe the Council may already be familiar with it.

Imposing 13 consecutive penalty charge notices is not only disproportionate but also contrary to this principle. Therefore, the application of these multiple penalties for what is essentially a single, continuous contravention is inappropriate and should be reconsidered.

The car was eventually removed by the council on May 31st, following the issuance of one more Penalty Charge Notice (PCN). It is this final PCN that I am appealing in this representation based on the principle of continuous contravention. This principle suggests that this PCN should not have been issued at all. Instead, alternative methods for removing the car should have been considered and implemented much earlier by the council.

I would also like to highlight procedural improprieties at the impound, which resulted in the submission of this delayed representation. These improprieties prevented me from becoming aware of my right to appeal and obtaining information on how to do so.

On June 1st, my sister and a family friend recovered the vehicle on my behalf, paying the removal PCN and release fee. The impound staff provided only two documents: the PCN receipt (Appendix 1.1) and a vehicle removal receipt (Appendix 1.2). No information about my rights to appeal or make representations was given, nor was any documentation explaining how to make representations provided. As a result, I remained unaware of these rights until I sought legal advice.

I am willing to provide any additional information that might assist the council in reviewing this aspect of my case. I hope we can reach a fair resolution that takes into account these unique circumstances.

My commments in blue - hope that makes things clearer...

@John U.K. - thank you!

Regarding your question about PCN ZN12411827, the code was 16 and reads "Parked in a permit space or zone without a valid virtual permit or clearly displaying a valid physical permit where required". This is essentially the same as code 12r (it seems). I ommited the appendices to save some room, but will make your suggested edits and add them in on the next post.

I have modified that paragraph as follows:

All PCNs except one (ZN12411827) (what was this one for??? Is this relevant to your reps?) were for contravention code 12(i) at the same location on Cornwall Road, which are all againstappealing to what is essentially the same continuous contravention. While I understand the importance of parking enforcement, I believe this pattern of issuance and the excessive number of tickets are unfair and exorbitant.

Regarding the 14th PCN, I can see no option on the Haringey website for making a rep against it. I assumed the out-of-time link/form here that I filled in here would be sufficient to trigger the ability to reopen it. I sent this via post and so assuming this may take time to receive/process..
CP has suggested above that you send by post. By all means attach a copy of the reps against the 14thPCN and the removal to this rep.

Are you suggesting (which your edit seems) that I appeal it within this rep (which was intended for PCNs 2-13)?the moment given the status is currently 'PCN Complete'.
No, I'm not suggesting anything of the kind, merely painting the full picture and asking that they take that PCN into consideration along with the others. IMHO IF this reaches Tribunal, strong points which may lead to success will be 'failure to consider' 'continuous contravention' and removal against wrong PCN.

On this collective rep, you need to add in Enceladus' point about missing NtOs... probably towards the end.

On your rep for posting, as CP says, needs to be sooner rather than later, so I'll try and goi through your draft for that later today.

@John U.K. - Thanks! I've incorporated your earlier suggested edits

But you haven't   And it took me ages . . . (Please excuse minor rant)

However, I am intrigued: please explain

Why it is no longer clear what you propose to put in the designated box and what you propose for the pdf attachment? (my idea was that you could attach the same pdf for each PCN, only altering what appeared in the box)

Why you have not drafted the list of PCNs in full and appear to have omitted the references to the NtOs with date of issue of each and whether it has been received?

Why have omitted my carefully crafted reference to the 14th PCN?

Why you have moved back the sub-heading 'Summary of Circumstances'?

Why you have gone back to 'I don't recall' from the stronger 'I didn't receive'?

Why you have removed 'Continuous Contravention' from the sub-heading?

Why you needed to alter my point 1 about continuous contravention?

Why you have changed 'pound' back to 'impound' the noun is pound?

Sorry to sound so harsh, but I was trying very hard to make you the strongest possible case, whilst retaining your own style.

I am happy to carry on looking at your drafts, but quite understand if you'd prefer me not to. Incidentall, a small typo in your draft:

All PCNs except one were at the same location on Cornwall Road, which are all again against essentially the same continuous contravention.

On reflection, I think this would better read
All PCNs  were at the same location on Cornwall Road, which are all against for essentially the same continuous contravention, as the vehicle was not moved.

@John U.K. - I do apologise!

No probs - I'm just relieved you took my critique in the spirit in which it was intended.

I'll now work on the rest off-line (I'm still using Lotus WordPro!) and then post the results here.

 I also thought just including the list of PCNs, along with the dates directly is better than attaching a separate document showing this.

AFAIK, when Councils provide a box for reps, there is usually a character limit. Besides, using a pdf attachment means you can pre serve all formatting. See my new draft for you when it arrives.
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Here's my revision of your draft N.B. formatting:



(in the box)

I am making representation against the above NtO issued on (Date). For the reasons outlined in the attached representations, I wish this representation to be considered together with those against the NtOs for the following PCNs (insert list with dates).

(Insert as appropriate: I should point out that this PCN/this NtO was/were not received by me - see attached representations.)


(For the attached PDF)


I am writing to make a representations against the following Notices to Owner (NTOs) that have been issued against my vehicle (YE08 WYG) to me for the following PCNs (insert complete list of PCNs with dates of both PCN and of NtO for each and 'not received' against PCN/NtO as appropriate) The list as below at the moment is not complete- only 11 in list, should be 13.

I ask for the reps against the above NtOs to be considered together.


Before explaining the details, I hope the council will consider being flexible and taking my history as a responsible resident into account, along with the unfortunate circumstances that have led to what I believe is an unreasonable and exceeded penalty.

As a Haringey resident for over five years now, I've held three parking permits (October 2023 - 6 Months, May 2023 - 6 Months, and May 2022 - 1 Year) and have always renewed them promptly.
From April 12th to July 12th, 2024, I was out of the country for work. Unfortunately, during that time, my permit expired on April 25th, and I did not receive the renewal reminder that the council usually sends.

Because of this, my car was without a valid permit for 61 days. This resulted in a continuous stream of parking tickets being issued while I was abroad, without me being aware of this in any way.
The council eventually removed my car on May 31st. On June 1st, my sister and a family friend recovered the car for me, paying the necessary fees for the ticket and the removal.

I understand my car was without a permit, but there isn't much more I could have done here. I feel that potentially having to pay £1690 for being late on my permit renewal is too much. This is especially since I've demonstrated my reliability as a permanent resident with a good permit history and also these essentially all referring to the same continuous contravention.
My car remained in the same place throughout the period these PCNs were issued. Tickets were issued almost daily from 07/05/2024 to 30/05/2024.

All PCNs  were at the same location on Cornwall Road, which are all for essentially the same continuous contravention, as the vehicle was not moved. While I understand the importance of parking enforcement, I believe this pattern of issuance and the excessive number of tickets are unfair and exorbitant.

Upon returning to the country, I emailed (insert name) ___, Head of Highways and Parking, about this situation (Appendix 1.1)(where are the appendices in your draft?). She responded:
"Normally after 3 PCNs the vehicle is flagged for removal... I can see from the PCN issued on 30th May that there were 5 PCNs attached to the vehicle and agree that the vehicle should have been removed sooner."

Given that my car was stationary in the same place during this entire period, I would have hoped the council would have carefully considered whether this was the most appropriate approach, especially when other enforcement methods were available.

I would have expected the council to:

    1. Have considered the principle of 'continuous contravention'. It is a fundamental principle that one may not be punished more than once for the same offence. Therefore imposing 13 further penalties is not merely disproportionate, it was contrary to this fundamental principle as has been upheld by numerous adjudicators as the Council should be aware.
2. Use its power to remove the vehicle more quickly, or
    3. In case of no available space at the pound, communicate with the CEOs to exercise discretion in not issuing more tickets for the same contravention, or
    4. Explore other methods of getting in touch with me or removing the vehicle given these unique circumstances.


The excessive number of tickets issued before the car's removal seems unfair, particularly given Ms (name's) acknowledgment that it should have been removed sooner.


I have now discovered from your website and as can be seen from the list above, I would also like to point out that while the council's website indicates that all 12 NTOs have been issued, as evidenced by the attached screenshots of the Key Events (appendix number) for these PCNs, I have not received all of them through the post.

I would like to inquire why the Key Events for these PCNs show that NTOs have been issued, but they don't appear to have been posted. It's my understanding that NTOs should be posted on the day of issue.

Could the Council please confirm the addresses used for these missing NTOs? This information is crucial to understanding why I haven't received these important documents.


In conclusion, I'm willing to provide any additional information that might assist the council in reviewing this aspect of my case. My hope is that we can reach a fair resolution that takes into account these unique circumstances.

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Still to work on PCN 14.