Free Traffic Legal Advice

Live cases legal advice => Civil penalty charge notices (Councils, TFL and so on) => Topic started by: YoungDigga on February 22, 2024, 03:06:18 pm

Title: Re: 2x PCN Royal Greenwich Millennium Way 47J - Stopped on a restricted bus stop or stand- Lease/Hire
Post by: Hippocrates on August 03, 2024, 10:15:49 am
The Authority’s case is that the Appellant’s vehicle was stopped in a restricted bus stop or stand when prohibited in Millennium Way on 26 December 2024 at 23:00.  :)
Title: Re: 2x PCN Royal Greenwich Millennium Way 47J - Stopped on a restricted bus stop or stand- Lease/Hire
Post by: cp8759 on August 03, 2024, 01:01:59 am
Outcome (https://drive.google.com/file/d/1kP5brQ_FbPyeVifoQ5eTCu-0I1Psgyfb/view).
Title: Re: 2x PCN Royal Greenwich Millennium Way 47J - Stopped on a restricted bus stop or stand- Lease/Hire
Post by: cp8759 on May 15, 2024, 10:49:03 pm
@YoungDigga you have two argument then, that the camera isn't approved and that the vehicle is on lease to you but there is no proof of a transfer of keepership because the terms of the lease are not before the adjudicator. The pitfall with that argument is that the lease is for several years and many adjudicators would say it's long enough for them to infer a de-facto transfer of keepership, as shown by this case:

Hakan Sefiloglu v London Borough of Ealing (2210427465, 9 October 2021) (https://drive.google.com/file/d/15iOG44PcGCWMF9m_bwD42dW2ZVcpXZuq/view)
Hakan Sefiloglu v London Borough of Ealing (2210427465, 24 October 2021) (https://drive.google.com/file/d/1gaqKvU-3FMB6vINJ6PPe-BlLYRAAGvSx/view)

I'm not sure the same adjudicator would make the same decision today, but there is a risk. It would be best to post up the terms and conditions of your lease so we can check if the argument can be bolstered, if any of the terms and conditions show that the registered keeper maintained a significant degree of control over the vehicle that would strengthen this ground.

There is no notice of acceptance from the council to the hire company, so there was no power to serve a further penalty charge on you. This should be a straightforward argument but it needs to be articulated correctly. Cases which can be cited on this point are Wasim Ismail v London Borough of Redbridge (2200346764, 10 October 2020) (https://drive.google.com/file/d/1xwFb3iSglbSYLKvcrfCPis6P0i_M1ZnU/view), Mohamad Rafik Gani v London Borough of Newham (221024696A, 14 June 2021) (https://drive.google.com/file/d/1TRqvyLrxRoNvFcwTQCFwPqDm-CXB9s2m/view) and Modou Sanneh v London Borough of Newham (2210340629, 17 July 2021) (https://drive.google.com/file/d/18t9WauALiCjJnwP_FLwcGEHqpaxk_iZw/view), but really this requires an argument that takes the adjudicator through the statutory provisions.

The relevant provisions are regulation 10(6) to 10(9) of The Civil Enforcement of Road Traffic Contraventions (Approved Devices, Charging Guidelines and General Provisions) (England) Regulations 2022 (https://www.legislation.gov.uk/uksi/2022/71/regulation/10) and regulation 6(8) of The Civil Enforcement of Road Traffic Contraventions (Representations and Appeals) (England) Regulations 2022 (https://www.legislation.gov.uk/uksi/2022/576/regulation/6).

The key question therefore is whether you want to have a bash at writing an argument yourself, or whether you'd rather be represented. If you want to represent yourself then have a go at writing a draft based on the above and I will also email you the FOI response with the camera make and model details, so that you can put it forward as evidence.

If you'd like me to represent you, just follow the instructions in the PM I sent you previously.
Title: Re: 2x PCN Royal Greenwich Millennium Way 47J - Stopped on a restricted bus stop or stand- Lease/Hire
Post by: YoungDigga on May 15, 2024, 10:25:21 pm
@cp8759

Just checked today and see that the council has uploaded their representation now. Could someone help to take a look at this most of it is what I've already shared previously. It appears the lease company did not share a copy or my lease agreement and greenwich just took word that the car is on a lease to me to transfer ownership of liability. So seems like this is good enough ground to appeal. I have redacted my name and address. Let me know if any other information is needed.
 
https://ibb.co/ftW0GC8
https://ibb.co/tBYQRXb
https://ibb.co/x2RbD86
https://ibb.co/wd4bFFK
https://ibb.co/xmtLM7Y
https://ibb.co/PDWjDYz
https://ibb.co/YhJ1y3r
Title: Re: 2x PCN Royal Greenwich Millennium Way 47J - Stopped on a restricted bus stop or stand- Lease/Hire
Post by: cp8759 on May 13, 2024, 10:33:49 pm
Nothing from the council yet from what I can see in the portal. They haven't uploaded any evidence whatsoever. What is the latest I should leave this to expect a hearing to either take place or not?
@YoungDigga You want to check the portal every day in the 7 days prior to the hearing. If something gets uploaded during the last 7 days, you can call the tribunal call centre and request a reschedule (I'd suggest postponing the case as much as possible in this scenario, you can move the case by up to 28 days). If on the afternoon of the day before the hearing they haven't uploaded anything, you'll normally get a call from the tribunal confirming that the hearing is cancelled.

The one thing you don't want to do if the evidence comes in the last week is try and prepare for the hearing in a massive rush, if it comes to it just move the hearing.
Title: Re: 2x PCN Royal Greenwich Millennium Way 47J - Stopped on a restricted bus stop or stand- Lease/Hire
Post by: YoungDigga on May 13, 2024, 10:19:49 pm
@cp8759

Quote
Did you send your request to the lt.reception mailbox as stated on the scheduling letter?

Yes. See the confirmation attached where they confirm it will happen via phone.

Quote
Has the council contested the case?

Nothing from the council yet from what I can see in the portal. They haven't uploaded any evidence whatsoever. What is the latest I should leave this to expect a hearing to either take place or not?

[attachment deleted by admin]
Title: Re: 2x PCN Royal Greenwich Millennium Way 47J - Stopped on a restricted bus stop or stand- Lease/Hire
Post by: cp8759 on May 10, 2024, 11:53:08 pm
@YoungDigga I've got this from the council:

(https://i.imgur.com/wVvIefH.png)

Has the council contested the case?
Title: Re: 2x PCN Royal Greenwich Millennium Way 47J - Stopped on a restricted bus stop or stand- Lease/Hire
Post by: cp8759 on April 28, 2024, 05:16:10 pm
I have submitted a request to have it done virtually/telephone if possible so hopefully this makes it easier for someone to represent.
Did you send your request to the lt.reception mailbox as stated on the scheduling letter?
Title: Re: 2x PCN Royal Greenwich Millennium Way 47J - Stopped on a restricted bus stop or stand- Lease/Hire
Post by: YoungDigga on April 24, 2024, 10:18:59 pm
Quote
@YoungDigga did you write to the hire and if so did you get a response?

I did write to them but got no reply even after chasing it up a few times. Nothing. As far as a copy of my representation I don't actually have a copy but it wasn't too far off from this draft

Quote
I am writing to appeal the two Penalty Charge Notices (PCNs) that I received for contravention 47J - Stopped on a restricted bus stop or stand (camera enforcement) at Millennium Way in Royal Borough Greenwich.
Firstly, I would like to bring to your attention that there is an insane amount of road work going on at the location where I received the PCNs. All the usual pickup/dropoff spots were coned off and there were roadworks in the suggested car park location that the O2 Arena suggests using. As someone who used to live around the area, I recall this so-called "bus stop" being a pickup/dropoff location. Therefore, I was unable to see the double yellow lines either side of this bus stop because they were coned off.
Furthermore, I have never received two PCNs on the same day before, but from what I have read, they should be treated as one due to receiving them both at the same time. From searching online, I see that people usually receive a warning notice first, but this was not the case for me. While I understand that the council is not obliged to issue a warning notice, it is a shame given the circumstances as I am not sure where else I could possibly pickup/dropoff there.
Additionally, my car is on a long-term lease, and the transfer of liability here appears to be invalid. My lease company first notified me of the PCN via email and wrote a letter to RBG with a third-party authorisation letter. However, I do not see a valid hire agreement attached to my PCN, so I believe liability cannot lawfully be transferred to me.
In light of the above, I kindly request that you cancel the two PCNs that I received. I look forward to hearing back from you soon.
Thank you for your time and consideration.

To be honest reading it back now it seems pretty weak of a representation but I know I needed to submit something which they would have rejected anyways.

Happy for one of you to represent me. We will see what happens as we get closer to the time. Still appears that the council haven't responded yet. Let me know if anything else is needed in the meantime from my side. I have submitted a request to have it done virtually/telephone if possible so hopefully this makes it easier for someone to represent.
Title: Re: 2x PCN Royal Greenwich Millennium Way 47J - Stopped on a restricted bus stop or stand- Lease/Hire
Post by: cp8759 on April 21, 2024, 04:55:06 pm
Okay so I got the notice of rejection is there a template or another post you can point me to in order to best challenge the transfer of liability at tribunal?
@YoungDigga did you write to the hire and if so did you get a response?

Also I'm not sure we've seen a copy of your representations to the council?

In all honesty if the council contests the appeal your best bet is to ask one of us to represent you.

In the meantime I'm also going to try and find out if their CCTV cameras are properly certified.
Title: Re: 2x PCN Royal Greenwich Millennium Way 47J - Stopped on a restricted bus stop or stand- Lease/Hire
Post by: Incandescent on April 17, 2024, 11:21:26 am
I think most London Tribunals adjudications are done over the phone now, although others on here may have the exact figures. The Traffic Penalty Tribunal now do video adjudications using MS Teams so I suppose you could say London Tribunals are behind the times.  However at least London Tribunals offer an on-line searchable register of decided cases, called the "Statutory Register", where you can look for cases similar to yours.
Title: Re: 2x PCN Royal Greenwich Millennium Way 47J - Stopped on a restricted bus stop or stand- Lease/Hire
Post by: YoungDigga on April 17, 2024, 07:21:08 am
Okay so I have a date for my appeal 23rd May 2024 at 15:30 at London Tribunals, Chancery Exchange, Ground Floor North, 10 Furnival Street, LONDON, EC4A 1AB

It looks like I can receive the evidence up to three days prior to the hearing which is cutting it fine. Do councils usually wait this long before deciding they don't want to contest or submitting?

Also it didn't give me the option to attend virtually but I might request to attend via telephone as my partner is pregnant and due on the 19th May so don't want to chance having to attend this in person. Is there any reason why I wouldn't want to do this?

See pdf attached:
[attach=1]

[attachment deleted by admin]
Title: Re: 2x PCN Royal Greenwich Millennium Way 47J - Stopped on a restricted bus stop or stand- Lease/Hire
Post by: YoungDigga on March 27, 2024, 09:27:38 am
Thanks taffer. Just submitted appeal online with the one liner "I rely on my formal representations and will provide further detail on review of the council evidence bundle" as suggested. It also asked me to select grounds for appeal and only logical one that made sense was "I was not the owner of the vehicle". Will update here once I hear back.
Title: Re: 2x PCN Royal Greenwich Millennium Way 47J - Stopped on a restricted bus stop or stand- Lease/Hire
Post by: taffer87 on March 25, 2024, 12:06:57 pm
Okay so I got the notice of rejection is there a template or another post you can point me to in order to best challenge the transfer of liability at tribunal?

Please post the pics of the notice or rejection

Usually you should do the Tribunal appeal online and request in / person or telephone hearing and just say "I rely on my formal representations and will provide further detail on review of the council evidence bundle". Then wait for the evidence bundle as they could just decide not to contest

Plz follow the above if you want to appeal to the tribunal (and lose the discount).

The current appeal you have is incorrect.

After using the standard one line type appeal above - see if the council submits an evidence pack and then upload that here for more detailed advice from seniors

A lot of times the council just doesn't contest at all and does not submit an evidence pack so people don't look at this in more detail until then.
Title: Re: 2x PCN Royal Greenwich Millennium Way 47J - Stopped on a restricted bus stop or stand- Lease/Hire
Post by: YoungDigga on March 24, 2024, 07:36:26 pm
Posted the notice of rejection. Let me know if my template is okay to use as looking to get this send out asap before we head into easter. Nearing the 28 days period
Title: Re: 2x PCN Royal Greenwich Millennium Way 47J - Stopped on a restricted bus stop or stand- Lease/Hire
Post by: YoungDigga on March 22, 2024, 04:58:04 pm
Here is the notice of rejection (https://ibb.co/RSXyKcw)
Title: Re: 2x PCN Royal Greenwich Millennium Way 47J - Stopped on a restricted bus stop or stand- Lease/Hire
Post by: taffer87 on March 22, 2024, 12:51:16 pm
Okay so I got the notice of rejection is there a template or another post you can point me to in order to best challenge the transfer of liability at tribunal?

Please post the pics of the notice or rejection

Usually you should do the Tribunal appeal online and request in / person or telephone hearing and just say "I rely on my formal representations and will provide further detail on review of the council evidence bundle". Then wait for evidence bundle as they could just decide not to contest
Title: Re: 2x PCN Royal Greenwich Millennium Way 47J - Stopped on a restricted bus stop or stand- Lease/Hire
Post by: YoungDigga on March 22, 2024, 12:01:50 pm
This is what I've got so far

Quote
Dear Sir/Madam,
I am writing to appeal the Penalty Charge Notice (PCN) issued to me on 06/02/2024 for 47J - Stopped on a restricted bus stop or stand. I believe that I have grounds for appeal based on the fact that the liability for this PCN should not lie with me, but rather with the owner of the vehicle, [insert name of leasing company].
As the lease holder of the vehicle in question, I contest the transfer of liability to me for the following reasons:
1. Failure to provide evidence: There is no evidence to suggest that I was driving the vehicle at the time the PCN was issued. Without such evidence, it is unfair to hold me liable for the penalty.
2. Breach of contract: The terms of my lease agreement with Mercedes-Benz Finance do not make provision for the transfer of liability for PCNs to the lease holder. Therefore, I believe that the transfer of liability in this case constitutes a breach of contract.
3. Non-compliance with regulations: My lease agreement does not satisfy the requirements set out in The Road Traffic (Owner Liability) Regulations 2000, which state that a statement of liability signed by the hirer must be included in any lease agreement where the owner of the vehicle seeks to transfer liability for PCNs to the lease holder. As such, I believe that the transfer of liability in this case is invalid.
In light of these points, I respectfully request that the PCN be cancelled.
Thank you for taking the time to consider my appeal. I look forward to hearing from you soon.
Yours sincerely,

How does this sound?
Title: Re: 2x PCN Royal Greenwich Millennium Way 47J - Stopped on a restricted bus stop or stand- Lease/Hire
Post by: YoungDigga on March 22, 2024, 11:19:32 am
Okay so I got the notice of rejection is there a template or another post you can point me to in order to best challenge the transfer of liability at tribunal?
Title: Re: 2x PCN Royal Greenwich Millennium Way 47J - Stopped on a restricted bus stop or stand- Lease/Hire
Post by: cp8759 on February 23, 2024, 12:13:49 am
You need to make representations against each PCN individually, but at the tribunal stage you can appeal up to 4 rejections on a single appeal.
Title: Re: 2x PCN Royal Greenwich Millennium Way 47J - Stopped on a restricted bus stop or stand- Lease/Hire
Post by: taffer87 on February 22, 2024, 10:11:03 pm
separately
Title: Re: 2x PCN Royal Greenwich Millennium Way 47J - Stopped on a restricted bus stop or stand- Lease/Hire
Post by: YoungDigga on February 22, 2024, 04:38:05 pm
Awesome thanks! Just sent this to the hire company and will look to do an appeal which as you mentioned will most likely get rejected.

Is there any way for these to be treated together either through tribunal or to get one cancelled out as they were both issues on the same day? or do I just need to appeal them both waiting for the rejection and go through tribunal for them both independently?
Title: Re: 2x PCN Royal Greenwich Millennium Way 47J - Stopped on a restricted bus stop or stand- Lease/Hire
Post by: cp8759 on February 22, 2024, 03:49:47 pm
The easiest way to get rid of these would be to challenge the transfer of liability. The council will never accept anything you say but if you just make a representation asking them to cancel, that will get the notice of rejection that you need to take it to the tribunal.

As far as we are aware Greenwich doesn't send a notice of acceptance to hire companies, but I would contact them anyway to check:

Dear hire Company,

In respect of PCNs XXX and YYY, please would you confirm if you have received any correspondence from the local authority since requesting a transfer of liability?

Yours faithfully,
Title: 2x PCN Royal Greenwich Millennium Way 47J - Stopped on a restricted bus stop or stand- Lease/Hire
Post by: YoungDigga on February 22, 2024, 03:06:18 pm
Hey seeking for some advise here

I received two PCNs for the following contravention - 47J - Stopped on a restricted bus stop or stand (camera enforcement) at millennium way in royal borough greenwich. For anyone that has driven to north greenwich recently you will know there is an insane amount of road work going on there at the moment. All the usual pickup/dropoff spots are coned off and there are roadworks in the suggested car park location that the 02 suggest you use. I used to live around the area and I recall this so called  "bus stop" being a pickup/dropoff location. I was unable to the double yellow lines either side of this bus stop because they were coned off. I've never received two PCNs on the same day before but from what I've read they should be treated as one due to receiving these both at the same time. From searching the forum I've seen other cases where people received a warning notice first. I guess the council isn't obliged to issue a warning notice but this is a shame given the circumstances as not sure where else I could possible pickup/dropoff there. My car is on a long term lease but not sure I understand the technicality of transfer of liability here with leases. My lease company first notified me of the PCN via email and wrote a letter to RBG with a third party authorisation letter. I don't see a hire agreement attached and not sure if this valid without it as the letter simply says the vehicle is on a long term lease and has contract start and end date. Although they could have well sent the hire agreement and not included it in my copy. Also not sure if they are supposed to include a hire agreement with the PCN that is then sent to me but I never got one but seems like this is specific to private PCNs. Lastly, from what I understand the original PCN should be cancelled and a new one be issued to me. I have a PCN addressed to me that was posted which has the same PCN # etc how can they prove they canceled the original PCN? It seems like they've just reissued the same pcn but addressed to me. I would like to contest the PCN but not sure what angle to contest it on there are few basis I see as a ground for appeal but not sure what the strongest point is. PCN docs listed below. Let me know if there is any other information required.

Also happy to upload copies of the documents including the PCN number and Reg if needed.

PCN1


Notification (https://ibb.co/mR9Z46f)
Original PCN (https://ibb.co/3B6s98V)
Third Party Auth (https://ibb.co/5Ymqgyy)
PCN Reissued (https://ibb.co/r3FjFSr)
Video (https://streamable.com/ahhi9f)

PCN2


Notification (https://ibb.co/6D2T885)
Original PCN (https://ibb.co/mGjJZb2)
Third Party Auth (https://ibb.co/Pxd4ZXr)
PCN Reissued (https://ibb.co/zFnpd4T)
Video (https://streamable.com/r8lu68)