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https://imgur.com/a/9f3U1el
I have drafted a appeal for the above pcn please advise if ok or anything else I can add to strengthen the case many thanks

Grounds of Representation – PCN HGB204686A

Alleged contravention: 24/06/2025

PCN issued: 16/09/2025 (almost 3 months later)

Under the Traffic Management Act 2004, a postal PCN must normally be served within 28 days. This delay is a procedural impropriety.


Additional circumstances:

I am a PCO driver (TfL Private Hire).

Passenger had mobility difficulties – could not walk properly.

Station Rd / Balgores Rd is a very busy road; stopping elsewhere would have been dangerous.

I stopped at the bus stop stand only to allow a safe drop-off.

The stop was under 10 seconds, as can be seen in the video. I moved away immediately.

I had no intention to park or obstruct.

Yes the vehicle is hired so only received the notice now

So the PCN is in your name, yes?

If so, then prima facie it is void because it has been served out of time, that is to say that the alleged contravention occurred on 24 June and the PCN was issued/served on 16/18th September respectively an elapsed period of 87 days whereas the maximum permitted period is 28 days.

There is nothing on the face of the PCN which would indicate that any of the circumstances which amend the 28-day period applies therefore the PCN is void and must be formally cancelled.

However, if the authority believes that any of the exceptions applies then in any rejection it is obliged to provide proof. Should this, for example, be that the registered keeper claimed that they are a 'vehicle-hire firm' and that the vehicle was hired under a 'hiring agreement' then, as a minimum, this proof must include:

A copy of the 'hiring agreement';
A copy of any statement of liability in which the hirer acknowledges their liability in respect of any penalty charge notice served in respect of any relevant road traffic contravention involving the vehicle during the currency of the hiring agreement;
Details of the grounds advanced by the keeper; and
A copy of the authority's Notice of Acceptance of the same.

I should be grateful if in its reply the authority would not belabour the details of the contravention itself and the public policy reasons for such a restriction but instead deal with the substantive issue which is that on the face of it the PCN is void by virtue of having been served out of time.

https://cdn.imgpile.com/f/IV3DDtu_xl.jpg


My appeal has now been rejected by the council and the case is being escalated to the tribunal. I have prepared some key points for the tribunal stage, which I’d be grateful for you to review. Any guidance or suggestions you can offer would be very much appreciated. Many thanks.


Ground: Procedural Impropriety — PCN served out of time

I appeal on the ground that the PCN was served out of time, amounting to a procedural impropriety.

The alleged contravention occurred on 24 June 2025.
The PCN served on me was issued on 16/18 September 2025, an elapsed period of 87 days.

Under the Traffic Management Act 2004, and the Civil Enforcement of Parking Contraventions (England) Representations and Appeals Regulations, the maximum permitted period for serving a Regulation 10 PCN is 28 days unless one of the limited exceptions applies.

In its Notice of Rejection, the council claims:

> “The initial PCN went out to the registered keeper… they came back to say the vehicle was on hire.”



This appears to be an attempt to rely on the “vehicle-hire firm / transfer of liability” exception.

However, the council has provided none of the legally required evidence that must be produced before the exception can apply. The law requires:

1. A copy of the hiring agreement;


2. A copy of any signed statement of liability by the hirer;


3. A copy of the original keeper’s representations;


4. A copy of the council’s Notice of Acceptance to the keeper.



None of these documents were supplied with the Notice of Rejection, nor at any point previously.

Without these mandatory documents, the council cannot rely on the hire-vehicle provisions. Accordingly, the PCN served on me is out of time, and therefore void.

I respectfully request that the adjudicator direct the council to cancel the PCN.

Without prejudice to the above, I also note that I was a licensed PCO driver and briefly stopped for under ten seconds solely to allow a mobility-impaired passenger to exit safely. However, I do not rely on this point unless necessary, as the PCN must be cancelled due to late service.

the case is being escalated to the tribunal

Have you registered an appeal? (always choose personal.)
Have you a date for the hearing?

hi any update on this asap many thanks

ok many thanks