Author Topic: Liverpool City Council, Code 06 – Parked without clearly displaying a valid pay & display ticket or voucher, Chatham Str  (Read 1048 times)

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Background

I received a Penalty Charge Notice (PCN) from Liverpool City Council – number LV20203497 – issued on 30/09/2025 at 16:31 for contravention code 06: Parked without clearly displaying a valid pay & display ticket or voucher. The vehicle is a Vauxhall DN19HPC.

I parked on Chatham Street (L7) in Liverpool City Centre (https://maps.app.goo.gl/Vz9J6k8eHji911wA8) and paid for parking using RingGo on my phone. When entering the location code from the nearby pay-and-display machine, I mistakenly entered 2641511 (Duke Street) instead of the correct Chatham Street code (2641551). The error was one digit, -511 instead of -551.

I paid £2.50 for 30 minutes on Duke Street , which is higher than the £2.00 tariff for the same duration on Chatham Street. I have a RingGo email receipt confirming payment for Duke Street between 16:23 and 16:53 (https://ibb.co/CKJVJkH1 - sorry for the not imgur link, not available in UK anymore).

A Civil Enforcement Officer issued the PCN at 16:31. When I spoke to the officer immediately after, I showed the proof of payment on my phone. He acknowledged the mistake and added my receipt to the case file but said he had no discretion to cancel it on the spot. (PCN Note - Front Side https://ibb.co/LdL33rZx, Back Side https://ibb.co/bMjBkqC6)

I submitted an informal challenge, explaining the one-digit error and attaching my proof of payment. The council rejected my challenge in a letter dated 03/10/2025, stating that I had paid for the wrong location and therefore had “no valid payment or voucher covering the parking session.” They maintained that it was my responsibility to ensure the correct location code was entered. (Rejection Letter - https://drive.google.com/file/d/18EFyN-aRNJ413l4kkSWuQaEmv5HeoiAA/view?usp=sharing)

The letter confirmed that the vehicle was observed between 16:26 and 16:31 and that the payment made was indeed for Duke Street (code 2641511). They have invited me to await a Notice to Owner (NtO) if I wish to make a Formal Representation.

Why I believe the PCN should be cancelled:[/u]
- The error was a minor keying error, a one-digit mistake when entering the RingGo location code.
- I paid for parking in good faith, for the exact period I was parked, and the council received a higher payment than required for Chatham Street.
- There was no loss to the council and no attempt to evade payment.
- The BPA Code of Practice (used by private operators) requires cancellation for minor keying errors of this nature. I understand that councils are not bound by this, but they do have discretion under the Traffic Management Act 2004 to cancel where there are “compelling reasons.”
- I intend to argue under the de minimis principle and proportionality that the contravention was purely technical and did not defeat the intent of the regulations.



I’m looking for advice on:[/u]
Just some general thoughts on it all and wether people with better knowledge than me this i have any leg to stand on and its worth continuing the challenge OR just to leave it and pay the discounted rate.

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So Liverpool are also using 7 digit location codes, which increases the error rate no doubt.

In London, most adjudicators side with councils on wrong code where there is the contravention of not displaying a valid ticket (rather than not paying).

There is also the fact that the contravention makes no mention of a virtual ticket.

Councils do have a duty to act fairly but some such as Liverpool just don't but you can have another go at them at formal stage and put them to this test in the statutory guidance:

Under general principles of public law, authorities have a duty to act fairly and proportionately and are encouraged to exercise discretion sensibly and reasonably and with due regard to the public interest. Failure to act in accordance with the general principles of public law may lead to a claim for a decision to be judicially reviewed.

And ask for their policy:

Authorities should formulate (with advice from their legal department) and then publish their policies on the exercise of discretion. They should apply these policies flexibly and judge each case on its merits. An enforcement authority should be ready to depart from its policies if the particular circumstances of the case warrant it.

An adjudicator could apply the principle of triviality given no loss to the council.

Liverpool do have something of a reputation at playing hard ball, but really they're no different to other large city couuncils who see PCN penalties as a nice little earner, and b**ger the Statutory Guidance.

Are you the owner of the vehicle and if so, is your address up-to-date and the same as it was on 30th September 2025 ?
If the above is a yes, then if you wait for the Notice to Owner, you lose the right to a discount on the penalty, but many councils re-offer it when rejecting formal representations to encourage payment and their need to prepare an evidence pack for an adjudication which for them is a PITA. I don't know if LIverpool do this, but somebody may on this forum.

If they don't re-offer the discount then you can make sure they don't get all of the penalty by taking them to the Traffic Penalty Tribunal. If they win they have to pay the adjudication fee, plus they have to make the effort to produce and evidence pack. Of course, if you win, you pay nothing but they still have to pay the fee.