Author Topic: Greenwich - 47J - Stopped on a restricted bus stop or stand (Camera enforcement)  (Read 2651 times)

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It's a parking not a moving traffic contravention.

The bus stop is a lay-by so it's a bit of a stretch to say it is a traffic situation but best try really.

That Greenwich don't provide the tribunal with evidence for a lot of appeals is a gamble as I said - we don't know if they'll be more on the ball next year.

While looking at my case summary online I came across the wording on the contravention is differrent it say "47J- PARKED ON A RESTRICTED BUS STOP/STAND" and on the letter it says "47J - Stopped on a restricted bus stop or stand (Camera enforcement)"




I dropped the PCN in ChatGPT and below is the response I recieved. Pastmybest observations seems to be match according to ChatGPT.

Thank you — these images are extremely important, and they confirm exactly the issue I suspected:
THIS PCN IS INVALID — it uses the WRONG LEGISLATION
The Royal Borough of Greenwich has issued your moving-traffic PCN under the:
Traffic Management Act 2004
This is printed in bold at the top of the notice.
That is unlawful for a 47J (bus stop) contravention in London.
For all London boroughs, including Greenwich:
  • Moving traffic contraventions (like 47J – stopping on a bus stop)
  • Must be enforced under the London Local Authorities and Transport for London Act 2003
  • Not under Part 6 of the Traffic Management Act 2004
London is specifically excluded from using the TMA 2004 moving-traffic enforcement regime.
This is not a minor error — it is a jurisdictional defect.

Why that makes your PCN unenforceable
A PCN must:
1️ Be issued under the correct enabling legislation
London boroughs cannot enforce 47J under the TMA 2004.
2️ Contain the statutory wording required by the correct Act
The wording required by the 2003 Act is completely different.
Your PCN:
  • Uses the wrong Act
  • Uses the wrong statutory text
  • Refers to the wrong definitions
  • Uses TMA 2004 deadlines instead of 2003 Act deadlines
  • Invites TMA-style representations instead of 2003 Act representations
This makes the PCN a nullity — invalid from the moment it was issued.
The London Tribunals have allowed many appeals on this exact point when councils mess up the statutory basis.

Strongest Appeal Point You Can Use
Here is the argument that wins:

GROUND: The council has acted ultra vires – PCN issued under the wrong legislation
The alleged contravention (47J – stopping on a restricted bus stop or stand) is a moving traffic contravention in London.
These contraventions can only be enforced under:
London Local Authorities and Transport for London Act 2003
However, the PCN is explicitly issued under the:
Traffic Management Act 2004
London boroughs are prohibited from using the TMA 2004 for moving traffic enforcement, as enforcement in Greater London is governed by the 2003 Act.
The PCN is therefore:
  • issued without proper legal authority (ultra vires)
  • contains none of the mandatory statutory wording required by the 2003 Act
  • uses deadlines, rights, and procedures that apply only outside London
Accordingly, the PCN is invalid and must be cancelled.

NEXT STEP
If you want, I will:
write the complete formal representations wording
reference the exact statutes
prepare the full argument for the Notice of Rejection
prepare your London Tribunals appeal wording (if needed)
Just say “write my appeal letter” and I will produce a ready-to-send text.

Don't use AI for one thing Stamfordman pointed out this is actually a parking PCN so the TMA2004 is correct legislation


Use this only

I make representations against the imposition of this PCN as the contravention did not occur. The stop as evidenced in the video was only in the normal course of driving in queuing traffic no person entered or left the vehicle and the PCN should now be cancelled

Don't use AI for one thing Stamfordman pointed out this is actually a parking PCN so the TMA2004 is correct legislation


Use this only

I make representations against the imposition of this PCN as the contravention did not occur. The stop as evidenced in the video was only in the normal course of driving in queuing traffic no person entered or left the vehicle and the PCN should now be cancelled

Thanks.. Will appeal as per you suggestion.

Recieved NOTICE OF REJECTION OF REPRESENTATION...
https://drive.google.com/open?id=1yaOoYjyu8r-9gJ18hXxyZFpMMrv3IPFU&usp=drive_fs


I guess its time to pay the fine... losing at the appeal would cost me double...

Any further suggestions?

Recieved NOTICE OF REJECTION OF REPRESENTATION...
https://drive.google.com/open?id=1yaOoYjyu8r-9gJ18hXxyZFpMMrv3IPFU&usp=drive_fs


I guess its time to pay the fine... losing at the appeal would cost me double...

Any further suggestions?
Or nothing to pay if you win.