It looks like they have just got in before the 56 day limit.
I will send my appeal as below unless you good folk advise otherwise. Many thanks.
Dear Sir/Madam,
I make representations on the following grounds: The contravention did not occur. As the authority will see from their evidence (the CEO's photos) the restriction in effect is given in the traffic sign which states: Pay by phone or Text or Pay at the machine and display ticket. Clearly, displaying a ticket is an optional matter for a motorist and therefore the contravention grounds of 'Parked without displaying a ...ticket or voucher' cannot be correct or even permissible contravention grounds because, among other matters, they deny the owner the defence of having purchased parking rights By Phone or Text. Contravention grounds must be correct and comprehensive in order to alert an owner to their possible applicable defences. If the authority believes that use of these grounds where payment By Phone or by Text or by purchasing and displaying a ticket are valid then they must explain the legal basis for this assertion when London Councils' Schedule of Contravention Descriptions already lists the correct grounds i.e. Parked without payment of the parking charge. I would also like to draw your attention to the following case Lydia Russo v Plymouth City Council (PL00004-2401, 12 March 2024) which was argued on similar grounds and the adjudicator concluded the contravention did not occur.
In addition, by the councils own admission they did not consider the Lydia Russo vs Plymouth case cited above. Therefor as in the case of Ivan Bachkov v London Borough of Newham (2250079444, 20 June 2025) they have failed to consider all the evidence provided with the representations, so there has been substantial non-compliance with the requirements of paragraph 1(7) of Schedule 1 of the London Local Authorities and Transport for London Act 2003.
Kind Regards,
