And there you have it.
My son attends *** school and I take them and pick them up each day. I am aware of the restrictions in Norlington Road itself and my regular practice, along with many other parents, is to drive past the school, turn right into ***, let my son alight on the waiting restrictions - in practical terms maybe a 10-second stop- and then return via Norlington. Seeing other parents' cars outside the school is common. Some ignore the markings and when doing so block the road for others behind who are forced to stop and wait. I would hope that no-one is foolish enough to do this more than once because the council's cameras are able to catch and penalise such practice.
And this is the central point in your defence. The council does not - I'd stake money on it- issue PCNs to cars simply ecause they're forced to stop but only those that do so with intent, even more so when their loved one(s) leap out from their cars.
My situation was no different on the day of the contravention than on hundreds of other days except that my impatient son decided to get out of the car at this point.
I hope you can see that the council's threshold for issuing PCNs is not simply being stopped- if it was then they'd run out of blank PCN forms rapidly- it's when they decide that an offence has occurred and that 'beyond reasonable control' does not apply.
I submit that this is my case. I had no intention of letting out my son at that point but instead doing what I do every other day. The mere fact that there was a hold-up and traffic was stationary is not, as I've set out above, the council's test, presumably it's intent and their only metric is: did a passenger alight?
In my case a passenger did alight, but for the reasons given a contravention did not occur.
Is what I was getting at.....
Do the facts fit?