Dear Bromley
Ref: PCN VRM
I make these formal representations against the Enforcement Notice as follows:
1. I never received a PCN so that I was unable to submit an informal challenge.
2. I was travelling in the right hand lane and was presented with two signs, a blue one to require me to turn left, and a red one prohibiting me to turn right. Both these signs confused me particularly as they were both respectively placed on the opposite sides of the road to where one would expect them to be.
3. The alleged incursion is so de minimis as to be quite trivial under the circumstances.
4. The video footage does not show any previous warning signage such as the sign to diagram 958. Indeed, I did not even see the sign to diagram 959 as I was concentrating on the signage at the end of the right hand side of the road and the no turn right sign.
5. I further bring a collateral challenge on the basis that the PCN is unenforceable because the taken without consent ground clearly fetters to theft by its very wording that a crime report be provided. Therefore, this inaccurate reflection of the statutory ground does not take into account that a relative, or friend, may have taken the vehicle without the owner's permission so that the owner would not necessarily, if at all, report the matter to the Police in such circumstances.
In view of the above please cancel the PCN and EN. Should you not agree to do so, I am quite prepared to take the matter to adjudication.
Yours faithfully
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