On 25th December 2025, the vehicle that I was registered keeper in was seen driving in a bus lane.
I appealed informally and formally but received a Notice of Rejection.
"In your representation you have referenced court cases and FOI to support your claim that the bus lane is not enforced on
Christmas day at the above location. You also mention confusion over the legislation pertaining to bus lane enforcement
and how long a registered keeper has to make payment for a PCN.
Please be advised that the photographs provided on the PCN are primarily used to demonstrate your vehicle was at the
location on the date of the contravention. All CCTV contraventions are recorded on digital storage media and are obtainable
from Transport for London upon request.
We issued the PCN because your vehicle was observed travelling within a bus lane in EAST INDIA DOCK RD E-BND
FROM UPPER NORTH ST on 25/12/2025 at 15:54. Travelling within a bus lane during its operational hours constitutes a
contravention. The sign states : Buses, Dial-a-Ride Buses, Pedal Cycles, Taxis and Solo Motorcycles Mon - Sun At Any
Time. There is a solid white line running along the right-hand edge of the bus lane for its full length.
The onus is on the driver to be aware of the bus lane and its restrictions. Drivers are not permitted to drive in a bus lane
during its period of operation. We have checked and the signage and markings meet all the statutory requirements as set
down in the Traffic Signs Regulations & General Direction 2016. Please note the onus is on the driver to be aware of road
signs as laid out in the Highway Code, section 120: "Bus and Tram Lanes... are shown by road markings and signs. You
must not drive or stop in a bus lane during its period of operation unless the signs indicate you may do so." (Law RTRA scts
5 &
.
You can only drive in a bus lane outside the stated operational hours, so it is important to carefully check the signs on each
bus lane before driving or parking in it. Where the time restrictions are not on the sign, the bus lane is enforced 24 hours a
day, 7 days a week."
"Whilst we may not have issued PCNs in previous years for bus lane contraventions on Christmas Day due to operational
impacts we are now able to do so because of upgraded camera technology which makes the detection and assessment of
bus lane contraventions possible and easier. The defined restriction in the traffic order and supporting signage in place
confirm the restriction applies 'At All times'. This means that your vehicle was not permitted to use the bus lane at any time,
including Christmas Day. TfL bus lanes operate 24 hours a day 7 days a week. The motorist was therefore adequately
informed by the road markings and signage placed in accordance with the Traffic Signs Regulations and General Directions
2026 and the Traffic Signs Manual that they were not permitted to enter or use the bus lane. By doing so the motorist has
caused the contravention detected. The restriction applies whether there is any impact to public transport or not.
Motorists are required to observe and adhere to road traffic markings, signs and lines at all times, whether travelling on new
or familiar roads. The CCTV footage on this occasion shows the vehicle in the bus lane when not permitted which is why
the PCN was lawfully issued for the contravention.
We have considered your representation in accordance with legislative requirements but consider that you have not
established a statutory ground of representation or good suitable reasons for the penalty charge to be cancelled. This letter
is issued as a formal Notice of Rejection of your representation.
Each PCN issued follows a defined enforcement procedure. From the date of the PCN, there is a 14-day discount payment
period to pay the PCN at the discounted rate of 50% as stated on the PCN otherwise, the full amount should be paid within
28 days. Entitlement to pay at the discounted amount is lost if payment is not made and received by TfL within the discount
payment period. The PCN recipient may make a written representation within 28 days.
We may apply discretion and accept discounted penalty charge payments received outside the discount period if there are
sufficient reasons provided for failing to make payment within the discounted period. We consider the statutory discount
payment period allows for any postal delays or short absences from the postal address used to be taken into consideration,
notwithstanding that payment of the penalty charge can be made in real time through our website. Therefore, as you failed
to make payment within the discount payment period, we maintain that the issue, enforcement and amount now payable in
respect of the PCN is correct.
When considering representations and appeals, we fully consider all the circumstances present including any mitigating
factors and whether it would be appropriate to apply our discretion over the enforcement of a PCN. In this instance we have
decided not to exercise that discretion.
You should now make full payment for the outstanding PCN(s) within 28 days of the service of this Notice. The amount
currently due for each PCN is set out below. For those PCNs held at the discounted penalty charge amount, we will provide
you a further 14 days beginning with the date of this notice to pay and close the PCN at that rate. If the PCN(s) remain
unpaid after this 14-day period, the penalty charge due will revert to the standard penalty charge amount as stated on the
PCN.
You may appeal to an Environment and Traffic Adjudicator at London Tribunals, an independent adjudication service,
against this decision on specified grounds within 28 days of the date of service of this letter. The adjudicator will consider
your appeal and make an independent decision, which Transport for London will comply with. Please do not send your
appeal to us and be aware an Adjudicator can only decide an appeal on statutory grounds. Further information is available
on the London Tribunals website.
If you want to appeal to an Environment and Traffic Adjudicator at London Tribunals please ensure you read the enclosed
form carefully, in particular the Appeal Procedure, and then complete, sign and send the attached form within 28 days of the
date of service of this letter to London Tribunals, PO Box 10598, Nottingham, NG6 6DR.
You should be aware that in prescribed circumstances, the Adjudicator may award costs against you if the appeal is
considered frivolous or vexatious or that the making, pursuing or resisting of the appeal was wholly unreasonable. Equally
costs may be awarded against Transport for London if the adjudicator considers that the disputed decision was wholly
unreasonable.
If you do not follow any of the prescribed actions within 28 days of the date of service of this Notice, a Charge Certificate
may be served. This increases the penalty charge due by 50% of the standard penalty charge. If the increased penalty
charge is not paid, then Transport for London may apply to the County Court to recover any outstanding charges due which
will incur a further charge of £10 per Penalty Charge Notice.
PCN Number: GX32176692 Outstanding Balance: £160.0"
1) I quoted the legal principle of legitimate expectation where TfL said in 2017 that they do not enforce bus lane contraventions on Christmas Day. FOI data shows they never issued any PCNs until December 2024. TfL must publish unequivocally publish a statement saying they retract their statement in 2017 and say they enforce bus lanes on Christmas Day for them to issue PCNs. If they haven't, you can rely on this. It's an abuse of process if I had relied on a statement TfL made and then they go against their own words.
2) I believe they used an AI automated response saying that the Freedom of Information Request referred to taxi ranks? It was completely hallucinated response. This was in their informal appeal which I'm trying to find - they sent this by post. Clearly they have failed to consider my response properly by using AI gibberish. Two statutory grounds already met. Procedural improperiety.
3) The third ground is that their Notice of Rejection has a fatal fault regarding the word "may" when it comes to the time needed to respond to the NoR. It doesn't meet the requirement of the legislation.
They had insisted that they had never made that claim despite literally quoting verbatim their FOI response from their own website. TFL were being economical with the truth.
Case Reference: 2260219459
Please quote this in any correspondence you
send us
Dear MR RAHMAN
SAIFUR RAHMAN
-v-
Transport for London
(the Enforcement Authority)
Vehicle Registration Number: PX17UML
Penalty Charge Notice(s): GX32176692
The Enforcement Authority has informed the Tribunal that it will not contest your appeal against the
Penalty Charge Notice(s) stated above.
The Adjudicator has therefore allowed your appeal without considering the evidence or any details of
the case. You are not liable for any further charge(s) against the Penalty Charge Notice(s) stated
above and, where appropriate, any amounts already paid will be refunded by the Enforcement
Authority.
If you have appealed against any other Penalty Charge Notice(s) not listed above, then your appeal
against those Penalty Charge Notices will proceed, as previously notified.
Please do not hesitate to contact this office if you have any queries about this.
