FORMAL REPRESENTATION AGAINST PENALTY CHARGE NOTICE
I am writing to formally contest the above Penalty Charge Notice issued on 23/07/2025 for an alleged contravention of Code 53J - "Failing to comply with a restriction on vehicles entering a pedestrian zone" at High Street North E6 / Skeffington Road E6 at 16:38 on 11/07/2025.
GROUNDS FOR REPRESENTATION
Ground 1: Collateral Challenge - PCN Fails to State Mandatory Information
I challenge this Penalty Charge Notice on the ground that it is defective and invalid as it fails to comply with the mandatory requirements set out in Section 4(
(v) of the London Local Authorities and Transport for London Act 2003, which states that a penalty charge notice must include:
"the grounds on which the enforcing authority believes that a penalty charge is payable with respect to the vehicle"
Specific Defects:
• The PCN merely states "camera enforcement" without specifying the legal grounds
• No reference to the specific Traffic Management Order establishing the restriction
• No details of the time periods when the restriction applies
• Fails to specify what specific restriction was allegedly contravened
Legal Authority: Section 4(
(v) London Local Authorities and Transport for London Act 2003
Ground 2: Collateral Challenge - Contradictory Timeline Information
I make a further collateral challenge as the PCN contains contradictory and conflicting information regarding the deadline for action under the "What should you do?" section:
Specific Contradictions Identified:
1. Point 1) states: "Make payment before the end of the period of 28 days beginning with the date of this notice"
2. Point 2) states: "Make representations before the end of the period of 28 days beginning with the date of service of this notice"
These create two different starting dates for the 28-day period:
• "Date of this notice" = 23/07/2025
• "Date of service" = Unknown/different date
This fundamental contradiction creates legal uncertainty and prejudices my statutory rights by making it unclear which deadline applies.
Ground 3: Additional Legal Defect - Inadequate Penalty Information
The PCN states the penalty as £160.00 but fails to provide clear information about:
• The statutory basis for this penalty amount
• Whether this is the correct amount for this specific contravention
• Clear explanation of the discount structure
Ground 4: Primary Challenge - No Contravention Occurred
I challenge this penalty on the substantive ground that no contravention occurred due to:
a) Absence of Advanced Warning Signage
• There was no adequate advance warning signage visible from my direction of approach
• The location contains excessive and confusing signage making it impossible to identify the specific pedestrian zone restriction
• This fails to meet Department for Transport guidelines for proper traffic signage
b) Exceptional Circumstances
• At the time of the alleged contravention, I was driving with a distressed infant passenger requiring my attention for safety reasons
• Combined with inadequate signage, it was impossible to identify any restriction
c) Request for Evidence I request the council provide:
• Copies of all relevant Traffic Management Orders
• Photographic evidence of signage from all approach directions
• Evidence of compliance with statutory signage requirements
• Details of the specific time restrictions that apply
CONCLUSION
I respectfully submit that this Penalty Charge Notice should be cancelled immediately on the following grounds:
1. The PCN is legally defective and fails to comply with mandatory requirements under Section 4(
(v) of the London Local Authorities and Transport for London Act 2003
2. The PCN contains contradictory deadline information creating fundamental legal uncertainty about statutory timeframes
3. Additional legal defects regarding penalty information and statutory basis
4. No contravention occurred due to inadequate signage and exceptional circumstances
