Hi all
I received the following attached PCN. [ Guests cannot view attachments ]
This happened at Sutton, Code 46 Stopped where prohibited (red route), O/S 46 - 50 High Street SM3/TFL, Red Route Loading/Parking Bay.
I have drafted up the following appeal:
Dear Sir/Madam,
I write to formally challenge the above-referenced Penalty Charge Notice (PCN) issued by Transport for London (TfL) on 28/04/2025
The PCN alleges that my vehicle was parked in a white bay on a Red Route. I respectfully submit that this PCN should be cancelled on the following grounds and precedent:
Under the applicable legislation and enforcement guidance for Red Routes, stationary vehicle contraventions that involve parking within designated bays — especially where loading/unloading or stopping for permitted purposes may occur — should, in principle, be enforced by Civil Enforcement Officers (CEOs) rather than by Approved Devices (i.e., CCTV cameras).
In the decision of Commercial Plant Services Ltd & others v Transport for London (2230060716, 25 May 2023) it was confirmed that where a contravention involves parking or stopping in a marked bay, it is inappropriate to enforce solely by CCTV without a clear justification for doing so. The Panel emphasized that enforcement by Approved Device in such circumstances can amount to procedural impropriety if the authority does not explain why CEO enforcement was not practical or appropriate.
In my case, TfL has provided no such justification. The absence of any attempt to deploy a CEO renders the issue of this PCN by camera procedurally improper. Accordingly, it should be cancelled.
Additionally, the signage relating to the Red Route restrictions was not properly positioned to face oncoming traffic and was, therefore, difficult — if not impossible — to observe and comprehend while driving lawfully and safely.
The Traffic Signs Manual and enforcement best practice require that regulatory signs must be visible, clearly positioned, and facing the direction of travel so that motorists can reasonably ascertain the restrictions applying to the roadway or bay.
In this instance, the sign was angled away from the line of travel, making it non-compliant with visibility requirements. This failure to provide adequate and proper signage is a further procedural impropriety and denies TfL the right to enforce the alleged contravention.
For the reasons set out above — namely, the improper issuance of the PCN by Approved Device without justification, and the failure to erect compliant signage — I respectfully request that the PCN be cancelled forthwith.
I understand that there was a judicial review overturning the CCTV thing.
Do I have any grounds for an appeal here?
I would greatly appreciate any help. Thanks in advance!
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