Thanks very much. Here's my draft on rejecting the PCNs on the following grounds:
"1. Procedural Impropriety: PCNs Served Out of Time
The alleged contraventions occurred in November 2025. However, these PCNs were not served until late March 2026 - a delay of over four months.
While I understand this was a hire vehicle, I have confirmed with the rental company that they processed the Transfer of Liability and provided my details to the Council on 21/11/2025. Under the London Local Authorities and Transport for London Act 2003, once the Council receives the hirer's details, they are required to serve a new PCN within a reasonable period (generally 28 days). A delay of nearly five months is excessive, violates the Council's duty to act with reasonable speed, and constitutes a procedural impropriety. As such, the PCNs should be cancelled immediately as they are served "out of time."
2. Inadequate Signage and Failure of Advance Warning
The signage at the junction of the A4 and Rivercourt Road is wholly inadequate and fails the test of "reasonable clarity" required by the Traffic Signs Regulations and General Directions (TSRGD).
Approach from A4: The advance warning signs on the A4 are small, poorly positioned, and frequently obscured by high-volume traffic on this 40mph dual carriageway. A motorist focused on safe lane positioning cannot reasonably be expected to see, read, and comprehend these signs.
Point of No Return: The restriction signs at the entrance to Rivercourt Road itself are positioned such that they only become visible after a driver has already committed to the turn. Because Rivercourt Road is narrow and lacks a safe turning point (the proposed mini-roundabout and two-way layout are not yet implemented), a driver is forced to pass the signs once they have seen them. Attempting to reverse back onto the busy A4 would be a dangerous and illegal manoeuvre.
3. Failure to Consult (Statutory Breach)
I further contend that the Traffic Management Order (TMO) underpinning this restriction may be invalid. Under Regulation 6 of The Local Authorities’ Traffic Orders (Procedure) (England and Wales) Regulations 1996, the Council has a statutory duty to consult with other highway authorities (in this case, Transport for London, as the authority for the A4) before implementing such an order. There is strong evidence to suggest that the Council failed to adequately consult or coordinate with TfL regarding the impact of this scheme on the A4 trunk road.
4. Request for Continuous Contravention Treatment
Should the Council reject the points above, I request that the two PCNs be treated as a continuous contravention. Both charges were incurred within a 24-hour period before I was notified of the first alleged offence. It is a well-established principle at the London Tribunals that a motorist should not be penalised multiple times for a single "error of understanding" before they have had the opportunity to rectify their behaviour.
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Given the extreme delay in service and the notorious inadequacy of the signage at this location, which has led to many similar cases being cancelled or folded by the Council at the Tribunal stage, I request that these PCNs be cancelled forthwith."
Do you think I should include a copy of the email/confirmation from the rental company regarding the date they transferred liability (21/11/2025), or should I wait for the Council to provide their evidence pack if they reject this?
Otherwise, any amendments suggested? Thank you very much for your help here.