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NOTICE OF REJECTION OF INFORMAL CHALLENGE
The Traffic Management Act 2004 s78
Penalty Charge Notice Number: WP10696770
Date of Contravention: 30/04/2026 at 14:27
Location: Wood Street, Wakefield

Parking in Permit Holders Bay

Dear Sir / Madam,

Thank you for the letter dated 12th June 2026 - Notice of Rejection of Representations.
I strongly disagree with the allegation made in the letter - “parking in a permitted space without displaying a valid permit” and there are quite a few reasons why the vehicle was genuinely believed to be lawfully parked having displayed an eligible permit on Wood Street within the permit holders bay.

On the day of the PCN issuance, the car did have a valid Blue Disability Badge permit on clear display and it was at all times our understanding that such a permit is eligible throughout the Wakefield town centre given the nature of the road restriction and language used on the signage. The road markings and signage on Wood street itself was worn unclear and therefore ambiguous.

Given the attached evidence articles and references in relation to the Wakefield Pedestrian Zone, it can be seen that there is a similar restriction in operation (see photo of the sign order restriction). The restriction states explicitly: “Pedestrian Zone. No vehicular access except for buses, permit holders and loading.” Myself along with many other Blue Disability Badge permit holders have accessed and navigated the Pedestrian Zone for at least the past 5 years - the only way of doing so is by driving in the zone itself; but solely on the advice of the local traffic wardens and their own understanding of the local sign restrictions and orders and they independently have confirmed their understanding of the term "Permit Holders." To be clear the local traffic wardens have on a multitude of occasions advised on the scope of "Permit Holders" in relation to the Pedestrian zone and generalisation of Wakefield town centre. Furthermore within the Pedestrian Zone itself there are dedicated parking spaces specifically for Blue Disability Badge permit holders (see photo of the signs). This would ensure that a car navigating within the Pedestrian Zone is lawful and permitted in accordance with the road signs restriction orders and markings.

Attached are various examples of vehicles displaying the relevant Blue Disability Badge permit whilst parked compliantly on Lower Warrengate, Westmorland Street and the Springs located within the Pedestrian Zone (see photos). These vehicles are parked here within the Pedestrian Zone under the granted exemption of qualifying under the eligible permit holders language used in the restriction order. The only way to navigate a vehicle into these streets is to actively drive a car into the street on the basis of the road signage and explicit exemption permissible for permit holders (in this case a Blue Disability Badge permit).

My understanding is that having consulted with a multitude of the patrolling local traffic wardens over the past 5 years; that an eligible permit holder does include local residents with relevant issued permit, business premise owners within the zone, contractors performing duties with the relevant permit and Blue Disability Badge permit holders.
Therefore the local patrol wardens understand that wherever the road restriction signage uses “Permit Holders” then an eligible permit includes the Blue Disability Badge. This is why there have been zero PCNs issued in relation to inappropriate use of a Blue Disability Badge permit within the Pedestrian Zone to date by any traffic warden and confirmed by the Wakefield Council enforcement team and furthermore via a Freedom of Information Act request (see attached email).
Furthermore, Wakefield Cathedral (a government owned entity) has similar guidance on parking matters in the context of eligibility of Blue Disability Badge permit holders and corroborates the permit eligibility status (see website image - this guidance clearly states that parking access is permitted within the Pedestrian Zone given the use of a Blue Disability Badge permit). Please also see the email from the Wakefield Council Legal team following a Subject Access Request to seek information on the upholding of the Road Traffic Act and local planning laws within Wakefield centre. Clearly, an eligible permit does include a Blue Disability Badge permit for the cases outlined and appears to be the case within the local planning laws.

If Wakefield Council were to enforce the PCN it potentially would be a matter of inconsistent application of the Road Traffic Act regulations given the evidences, emails and sources of information provided as outlined above and uneven application of the law.
If the term “permit holders” apply to one particular set of roads and for the eligibility to include Blue Disability Badge permit holders and then for another road only 50 meters away for the same to not then apply - this is a direct conflict and 2 tiered legal framework. The road signs should be made much more clear and unambiguous given my understanding of these circumstances because there are contradicting narratives being provided by Wakefield Council itself, the signage used and the sources of information contained within my appeal.
This means that application of the legal terms would not be uniformly consistently applied across Wakefield town centre and therefore it would have subjective meaning across the entirety of Wakefield (which I hope would not be applicable).

Given that this is my first PCN and combined with the evidences provided I would like to think that Wakefield Council would be willing to cancel this for a first time offender of such a restriction.
My understanding was and always has been that whenever the term “Permit Holders” is used under the Road Traffic Act and Local Planning Law restrictions within Wakefield, then that would include a Blue Disability Badge permit holder as being eligible. I am generally a considerate person and do engage with the local traffic wardens over the years and they each did independently confirm the same perspective on the eligibility scope of "Permit Holders." If they are mistaken or they have conveyed incorrect information then I can only apologise.

Kind Regards,

Apologies, a bit misleading initial post. That post was actually the Tribunal representations in the initial post.

My informal challenge was rejected by Wakefield Council - probably because I was being a bit brash with them because their online document upload process is entirely not functional:

"Hello,

Missing evidence as your website is corrupted, has an error, not functional and not fit for purpose.
If there are inadequate road markings, causing known interpretation problems because the road markings are unclear and not marked properly and especially for a person with a known disability then that's the Council's own fault for being incompetent at maintaining the road.

Regards"

To give more wider context, and not to go off on a tangent too much, this alleged offence is somewhat interrelated with another PCN (which was cancelled by the Police) because there appears to be conflicting road restrictions specifically in the Pedestrian Only Zone: part of which is owned by the Police and the other part owned by the Council and "nobody wants to own up to it." Dare I say it that due to the Police cancelling the PCN they have admitted that the road signage is incorrect. One party is assigning blame to the other party.
Since there appears to be a road signage error, like on an exam paper where you get "Error Carried Forward" this is affecting other parts of the Road Traffic Order restrictions, specifically on the definition of "Permit Holders."

I know this doesnt help you and the other experts, but I dont have the full PCN actual document with me right now. Can I try to describe the nature of the PCN in question itself?

Ok, I will upload the documents when I am able to be hopefully over this weekend (just they aren't physically with me at present as I didn't take photos of them yet).

But, you have hit the crux of the matter:

(Police) Civil Law Fixed Penalty Notice For violation of restriction: “Pedestrian Zone. No vehicular access except for buses, permit holders and loading.”  - This FPN was cancelled because of the road signage error.

(Council) Restriction Permit Holders Only offence “parking in a permitted space without displaying a valid permit”  - This PCN is still under dispute.

So there is an apparent conflict over the common term used here "Permit Holders" which is reflected on the road signage restrictions, namely you cannot have such signage on display and have it have different scope because it would be determined in the local authority TRO if I am not mistaken (i.e. a common generic term)? If there is a precedent set for the definition scope of "Permit Holders" it must be consistent? Otherwise it would be ambiguous. The way how they would reduce the potential for ambiguity would be like they do in London where they would qualify the exact type of Permit on the road signage itself (for example type M, P1, L etc for residents whom reside in a specific geographical postcode) - something which in this case Wakefield Council didn't do on the road sign in question (its generically stated Permit Holders Only (without qualifying the permit type))

Yes there was an adjudication hearing yesterday.

Thanks for your replies.
May I ask what is the UK legal definition of a permit (or that which usually applies in England & Wales)? My understanding is that sometimes a Blue Disability Badge is a permit and sometimes it is a badge - it depends on the scheme that the local authority has adopted and effected in its local TRO?

However, if observationally speaking there are multiple frequent contradictions of such definitions (namely what was expected formally written in the TRO definition versus the actual reality of the situation due to frequent violations of the road signage in practice "which go unpunished yet compliant" (because in fact the road signage is incorrect and an error carried forward)), a conflict has seemingly occurred because a new precedent has been set in law (due to observation) since the facts contradict the definition? Sorry if this is unclear but I can give you a clear example by what I mean if necessary.

+1, but for your benefit:

Traffic Orders create restrictions;
Reg. 18 of this requires such restrictions to be signed adequately:

Part V (specifically s64) of this specifies 'traffic signs':

These are the applicable regulations (with limited exceptions) for Great Britain as regards prescribed signs, their definitions, size, format, variations and directions as regards siting etc:

In addition, the Secretary of State may authorise traffic signs. 

Typo from above apologies and clarification:

((Police) Criminal Law) Statutory Civil Fixed Penalty Notice For violation of restriction: “Pedestrian Zone. No vehicular access except for buses, permit holders and loading.”  - This FPN was cancelled because of the road signage error (on the basis of eligibility of the permit (Blue Disability Badge Permit))

((Council) Civil Law) Restriction Permit Holders Only offence “parking in a permitted space without displaying a valid permit”  - This PCN is still under dispute.