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Please don't bloat-quote, it makes the thread unnecessarily long and hard to follows.

Here is a draft:


I will PM you some links to put in the representation, they will redirect to https://drive.google.com/uc?id=1EoqML5pVDJePtRNZ11St3yHfKbSK8IuZ and https://drive.google.com/uc?id=1Y-zAgsVsNR2FfYMyfTBvSCzejsS2lEaB but if you give them the links I'll PM you, we can use the click count to confirm whether they've looked at them or not (obviously do not click on the links I PM you as we want the click count to remain at zero). If they don't click on them, we can then prove they've failed to consider all of the evidence. If they say in the rejection that they've considered all the evidence, we've got them for lying as well.

Please don't bloat-quote, it makes the thread unnecessarily long and hard to follows.

Here is a draft:

Dear Reading Borough Council,

I challenge liability for PCN RG91813766 on the basis of a procedural impropriety, I refer you in particular to the decisions in Anthony Hall v Kent County Council (with Tunbridge Wells BC) (KU-00042-1810, 07 December 2018) at LINK1 and Nigel Houlton v Reading Borough Council (RG00028-2002, 22 June 2020) at LINK2.

In light of those decisions the PCN should be cancelled.

Yours faithfully,

I will PM you some links to put in the representation, they will redirect to https://drive.google.com/uc?id=1EoqML5pVDJePtRNZ11St3yHfKbSK8IuZ and https://drive.google.com/uc?id=1Y-zAgsVsNR2FfYMyfTBvSCzejsS2lEaB but if you give them the links I'll PM you, we can use the click count to confirm whether they've looked at them or not (obviously do not click on the links I PM you as we want the click count to remain at zero). If they don't click on them, we can then prove they've failed to consider all of the evidence. If they say in the rejection that they've considered all the evidence, we've got them for lying as well.

Many thanks and sorry for the slow reply - I was travelling for work last week.

This is excellent & I received the separate links. I was thinking of making written representations by post, also harder for them to casually click a link. Do you advise either way?

Many thanks.

They've considered the first case we gave them but not the second, so there is arguably a failure to consider.

There is also the substantive merit of the will / may argument, which finds favour with some adjudicators at the TPT.

The questions is now whether you want to carry on with the full penalty in play, if you want to pursue this I'm happy to represent you.

DNC'ed.