Draft reps:
Dear London Borough of Lewisham,
I challenge liability for PCN ZY06516373 on the grounds that the penalty demanded exceeds the amount due in the circumstances of the case. In this instance the penalty charge wrongly asserts that a charge certificate may be issued after 28 days from the date of the notice, rather than 28 days from the date of service of the notice (as it should).
I draw your attention to the decision in Robert Atlas v London Borough of Barnet (2170053479, 24 April 2017), which comprehensively deals with this point, and was recently followed in Edmundson Electrical Ltd v City of London (2220061290, 07 March 2022) and Goode Durrant Administration Ltd v City of London (2230004045, 01 February 2023).
In light of the above the penalty charge must be cancelled.
Yours faithfully,
Send the representations online and get a screenshot of the confirmation screen. Don't worry about the discount, you will almost certainly have to appeal to the tribunal but we will help with that. And you will almost certainly prevail in the end.
