Free Traffic Legal Advice

Updated draft to be used for formal reps:

Dear Camden Parking Ops Team,

PCN **********

I refer to the above and NTO issued on 11 November 2025. I hereby make formal representations on the following grounds:

Contravention did not occur.

Rather than rehearse my informal representation in everyday motorists' terms, I shall instead reproduce verbatim and rely upon the decision of Adjudicator Stanton-Dunne of the Environment and Traffic Adjudicators when allowing an appeal on 18 February 2025 on identical grounds, coincidentally against Camden which was actually represented at the hearing.

“This PCN was issued for the alleged contravention of “being parked for longer than permitted blue (badge holder).”

The CEO’s images show that Mr Searle’s car was parked on a single yellow line displaying a blue badge with the clock set at 8.30am so that the three hour blue badge parking exemption had ended. The Council’s evidence is that Fordwych Road is part of a CPZ with controlled hours of 8.30am to 6.30pm Mondays to Fridays.

There is no contravention of a blue badge holder being parked for longer than permitted. The contravention of being parked for longer than permitted occurs when a vehicle is parked in a parking place where there is a permitted period of parking which is exceeded. Mr Searle’s car was not parked in a parking place where there was a permitted period of parking. It was parked in a restricted street during prescribed hours where there is an exemption for blue badge holders to park with the display of a clock. When the vehicle became parked beyond the period of the exemption, a PCN could have been issued for being parked in a restricted street but it was not. The PCN was issued for the wrong contravention, indeed a contravention which does not exist.”

I don't think I could add to his reasoning and therefore I am content to let his words form my representations. I have attached the ETA Case No. should you wish to verify the above - 2240520470 .

The PCN must be cancelled.

Yours faithfully,
TMOCONTRACTLAW
-----

I feel the above would be good in the sense that no files need to be attached and no issues regarding the formatting of the referenced case. Just hope there's no character limit. Do let me know if any adjustments should be made.

Just the PCN is fine.

I would include the case number up-front and say London Tribunals:

... rely upon the decision of adjudicator Stanton-Dunne at London Tribunals when allowing an appeal for case no. 2240520470 on 18 February 2025 ...

Unfortunately, my formal reps have been rejected.

Notice of Rejection (Redacted)

They've also included the 4 page 'TMA - Your right to a appeal' document.


I understand that if I were to take this to ETA, not all adjudicators will understand as to why I believe that no contravention occurred?


Also, is the Council not acting in a 'wholly unreasonable manner' in trying to chase this PCN. As, there was already an adjudicator case where the PCN was cancelled and in Camden owns Parking Protocol Document, the alleged contravention can only take place in a bay rather than SYL.

Pl, do let me know what you think in the meantime.

+1.

I would go for:

Contravention did not occur
Procedural impropriety.

We'll expand later, but at present all you've got to do is register.

IMO, it is a PI because the authority failed to consider your reps. The law requires a cogent and reasoned response. Whatever they moght think of the Stanton-Dunne decision, their statement that ..this has no bearing on the matter in hand' is flippant at best and a dereliction of their duty and PI at worst.

As for '..therefore no exemption can be applied in this instance', this is a non sequitur of enormous proportions.

Bring it on!

Yes it would be good if Mr Stanton-Dunne is on duty.

Earlier I posted a case where this contravention was upheld by adjudicator Natalie Goffe.

Here's another, by Michael Burke, who seems to have had an alarm bell ringing but turned it off.

-----------------

Case reference   2250155189
Appellant   xxxxxx
Authority   London Borough of Barnet
VRM   LP72UYO
   
PCN Details
PCN   AG47484147
Contravention date   26 Dec 2024
Contravention time   09:26:00
Contravention location   Beverley Gardens
Penalty amount   GBP 80.00
Contravention   Parked for longer than permitted
   
Referral date   -
   
Decision Date   25 Jul 2025
Adjudicator   Michael Burke
Appeal decision   Appeal refused
Direction   Full penalty charge notice amount stated to be paid within 28 days.
Reasons   The allegation in this case is that the vehicle had been parked for longer than permitted at 9.26am on 26.12.24. The Appellant disputes this. She says the Civil Enforcement Officer told her the PCN was issued because the Blue Badge displayed had expired. She says that it should be obvious she did not arrive at 4.00 as shops would not have been open at that time.
A vehicle may be parked in a restricted street during prescribed hours for up to 3 hours providing there is clearly displayed a valid Blue Badge together with the time clock set at the time of arrival.
The Enforcement Authority have provided photographs taken by the Civil Enforcement Officer which confirm that the time clock displayed with the Blue Badge was set at 4.00. The vehicle was parked on a double yellow line. As the Highway Code makes clear, the double yellow line indicates ‘No waiting at any time’. It does not require an adjacent time plate.
The better course in these circumstances would be to issue the PCN for contravention code 01, being parked in a restricted street during prescribed hours. However, it is also true to say that the vehicle was parked for longer than permitted as, unless an exemption applies, any time parked on a double yellow line is longer than permitted.
I have no reason to doubt that the Appellant made a genuine error but this amount only to mitigation. The Enforcement Authority may cancel a PCN as a matter of their discretion but Adjudicators have no power to direct cancellation on the basis of mitigating circumstances.
Having considered all the evidence I am satisfied that the contravention occurred and that the PCN was properly issued and served. I am not satisfied that any exemption applies.

Correct.

Just look at any case on the register:  https://londontribunals.org.uk/ords/pwslive/f?p=14952:70::INITIALISE::70:P70_CAS_REFNO,P70_PCN_REFNO,P70_RETURN_PAGE,P70_AST_CODE:1699047,3107858,60,APPEAL&cs=30ihADQLg9qdMEupImCELcaVqnIFm1Y3JVgvp6Il3PR3eYEb5Go6RWn7_SMIIJYTm3AXLc172qpj0P_O5w8hCXQ

I plan to put the ETA Appeal in the next few days. The NOR was issued on 02 Dec 2025.

I just wanted to confirm the following steps:

1) I tick contravention did not occur and procedural impropriety
2) Do I need to write why I believe the above two points are relevant? If so, what should I write in particular?
3) The hearing should either be telephone or online, NOT on paper
4) Do I need to screenshot the process?

If there is anything else that I need to do, pl let me know.

I have a tribunal date in June 2026.

Would it be advisable to upload the Council's Enforcement Protocol, which states that contravention code 30 only applies in parking bays and not yellow lines (on page 15)?

The reason I wanted to upload it, just in case an adjudicator doesn't understand how that contravention code can't apply on yellow lines.

As recently, I read a tribunal decision and the adjudicator noted 'The decisions of this Tribunal do not establish precedent and an Adjudicator is not bound by a decision in a previous case. I am not persuaded the decision relied upon is one to be followed.'

Therefore, I wanted to cover all the bases in case they do not look at or agree with the referenced case I used for the formal reps.

Though there is some time away, do let me know your thoughts.