If he wins overall, all monies paid are recoverable, including bailiff's fees...may take some time but all must come back to him.
Pay now and claim back later is valid at this stage, if only to prevent further escalation of costs or enforcement action such as cars being clamped.
More to the point is what bruvver is going to achieve.
He has to provide a truthful statement that he did not receive one of the Notices that the procedure calls for.
Can he actually truthfully say that or is it more a case of he ignored the post that was being delivered. Does he know himself? (Don't answer these questions but be aware it is a criminal offence to lie on that statement)
He also has to provide an Out of Time request...basically a request for the statement to be accepted late and providing a good excuse.
Even the best of reasons can be objected to by the Authority, who normally do. An objection often finds the request denied.
Which means a request to a District Judge to decide... that s over 100 notes on a decision on papers or over 250 for a hearing... costs not normally recoverable.
Only when that lot is done can the PCN itself be appealed, at the moment it is about process not the rights or wrongs of the PCN.
It is about where the process went wrong and whether brother was blameless.