Free Traffic Legal Advice

Live cases legal advice => Civil penalty charge notices (Councils, TFL and so on) => Topic started by: george74 on March 24, 2024, 09:05:53 pm

Title: Re: LBBD, code 12 parked in resident's bay, Halbutt Street RM9 5AH
Post by: george74 on July 26, 2024, 09:50:36 am
I received the decision today.

I should also add the adjudicator said:

"I was not satisfied that the council had considered that aspect of the appellant's representations as it was under a duty to do"
Title: Re: LBBD, code 12 parked in resident's bay, Halbutt Street RM9 5AH
Post by: george74 on July 25, 2024, 04:26:27 pm
I attended the hearing via phone today. The ticket has been cancelled as the council did not provide the attachments in my challenge.
Title: Re: LBBD, code 12 parked in resident's bay, Halbutt Street RM9 5AH
Post by: cp8759 on July 07, 2024, 09:47:59 pm
I received the evidence pack from the council. I noticed that while they have included my online reps - they do not include the attachments sent in with the reps i.e. in my formal challenge, I simply wrote "see attached" and attached my challenge in a pdf along with diagnosis letters and appointment letters - but those attachments have not been included, so my formal challenge is also not included.

Can it be dismissed on these grounds?
Yes, failure to provide a true copy of the representations should be an instant win. Look at the cases on rows 697 to 724 here (https://docs.google.com/spreadsheets/d/1pVrE76_RYY6bNmEpYGbsZkxtpfIeud_BT3SKfg7TzQM/edit?gid=642784037#gid=642784037&range=A697), also see Rent 2 Buy Your Car London Ltd v London Borough of Hounslow (2190507965, 27 December 2019) (https://drive.google.com/file/d/14Irnu9Rv2Dua1JuIkcXbGiUbxL1eAAFO/view), Gurdish Kapur v Bristol City Council (BS44, 13 November 2000) (https://drive.google.com/file/d/1wlSwFZBnbYuwcBJMAj0uQvMU3C2m6EdR/view) and Benjamin Weedon v London Borough of Barking and Dagenham (2230197958, 18 May 2023). (https://drive.google.com/file/d/1zHSqzQT9wHB9VdI6m_Kc0hZ4T4Gp1u5P/view)

The lead authority on the subject is Vanessa Price v Nottingham City Council (NG00044-2201, 7 March 2022) (https://drive.google.com/file/d/1YAg82YBKfVyHTSQmdOI229Yt5QccDKFt/view), that dealt with the copy of the PCN having to be a true copy but the same principle applies to the representations.

You don't need to provide copies of London Tribunals cases, but any cases from the Traffic Penalty Tribunal you will have to upload to the tribunal portal.

If the point is argued properly, you basically can't lose.

When's the hearing?
Title: Re: LBBD, code 12 parked in resident's bay, Halbutt Street RM9 5AH
Post by: george74 on July 06, 2024, 02:06:05 pm
I have a case report file in the evidence pack which is a report produced from DVLA which gives details of the car and history - my name is listed.
Title: Re: LBBD, code 12 parked in resident's bay, Halbutt Street RM9 5AH
Post by: george74 on July 06, 2024, 12:40:12 pm
The v5c is held by motability by default. I can request it and may be able to access it through my account but no access due to system upgrades or something - it'll have to wait until Monday.
Title: Re: LBBD, code 12 parked in resident's bay, Halbutt Street RM9 5AH
Post by: John U.K. on July 06, 2024, 12:26:15 pm
Have you physically checked the V5C?

For an informal challenge, the Council address the correspondent. To post the NtO, the Council obtain the name and address from the DVLA.
Title: Re: LBBD, code 12 parked in resident's bay, Halbutt Street RM9 5AH
Post by: george74 on July 06, 2024, 12:11:37 pm
 Ok I get it now.

My wife would be the RK.

For the informal reps, we challenged in my wife's name - so the first rejection was addressed to her.

The NTO however was addressed to me. I have had private parking invoices that come addressed in my name, not my wife's - I am not sure why exactly.

For the formal reps, we challenged in my name - so the rejection was addressed to me.
Title: Re: LBBD, code 12 parked in resident's bay, Halbutt Street RM9 5AH
Post by: H C Andersen on July 06, 2024, 11:08:07 am
OP, this is a legitimate and essential procedural issue and is wholly relevant.

Motobility are not the registered keepers of their vehicles, the keepers are the persons with whom they have their contract for the supply of the vehicle. If your wife is able to conduct her affairs, then this would be her.

In which case the NTO would have been addressed to her and only she can appeal to the adjudicator. She may authorise someone else in writing - fairly commonplace- but this authority must exist.

We just don't want to see her getting to adjudication, in the guise of you, only to be told you cannot represent her for want of proper authority.

The registered keeper is the person whose name is registered with the Driver & Vehicle Licensing Agency in Section 5 of the vehicle's log book or V5C. In the case of Motability Scheme cars, this is the customer.
Title: Re: LBBD, code 12 parked in resident's bay, Halbutt Street RM9 5AH
Post by: John U.K. on July 06, 2024, 10:27:48 am
Quote
We do not own the car, so is Motability (the company) the RK?

Whose name & address is on the V5C?
Title: Re: LBBD, code 12 parked in resident's bay, Halbutt Street RM9 5AH
Post by: george74 on July 06, 2024, 10:09:48 am
I still don't see the relevance to my question.

It is a motability car, 'hired' by my wife. We do not own the car, so is Motability (the company) the RK? Should they be handling it?

I don't believe we need to be the RK to get permits. We can be insured and that's sufficient. For my previous car that I owned, the permit for that car was still under my wife's name.
Title: Re: LBBD, code 12 parked in resident's bay, Halbutt Street RM9 5AH
Post by: H C Andersen on July 05, 2024, 09:36:01 pm
The NTO from the council was addressed to you and you are the registered keeper?

The relevance is that the driver has not standing in these matters, only the registered keeper. That the permit was in your wife's name(or account as you've expressed it) combined with the council's criteria for holding a permit give reasonable grounds to check who's who.

If you are not the RK then you should not be able to act in your own name.

Title: Re: LBBD, code 12 parked in resident's bay, Halbutt Street RM9 5AH
Post by: george74 on July 05, 2024, 09:27:52 pm
The permit is under my wife's account.

Which would suggest that she is the RK.


To buy a resident permit in Barking in Dagenham you must:

live in the borough
have a permit online account
have your vehicle registered in the borough
provide proof of residence and proof of ownership of the vehicle the permit is for (see the documents you will need under Step 1 - Create an Account)



Who is the registered keeper and in whose name were the reps and the appeal made?

I am not sure I understand the relevance. The car is a motability car for my wife. The letters were addressed to myself.
Title: Re: LBBD, code 12 parked in resident's bay, Halbutt Street RM9 5AH
Post by: H C Andersen on July 05, 2024, 09:09:59 pm
The permit is under my wife's account.

Which would suggest that she is the RK.


To buy a resident permit in Barking in Dagenham you must:

live in the borough
have a permit online account
have your vehicle registered in the borough
provide proof of residence and proof of ownership of the vehicle the permit is for (see the documents you will need under Step 1 - Create an Account)



Who is the registered keeper and in whose name were the reps and the appeal made?
Title: Re: LBBD, code 12 parked in resident's bay, Halbutt Street RM9 5AH
Post by: george74 on July 05, 2024, 07:24:23 pm
I received the evidence pack from the council. I noticed that while they have included my online reps - they do not include the attachments sent in with the reps i.e. in my formal challenge, I simply wrote "see attached" and attached my challenge in a pdf along with diagnosis letters and appointment letters - but those attachments have not been included, so my formal challenge is also not included.

Can it be dismissed on these grounds?

Side note, I have had many tickets now but never gone to tribunal myself. I am slightly excited to see what happens even if I lose.
Title: Re: LBBD, code 12 parked in resident's bay, Halbutt Street RM9 5AH
Post by: cp8759 on June 23, 2024, 12:07:08 pm
The instructions for appealing are on the notice of rejection, but I'll drop you a PM (https://www.ftla.uk/index.php?action=pm) in case you'd like to be represented.
Title: Re: LBBD, code 12 parked in resident's bay, Halbutt Street RM9 5AH
Post by: george74 on June 20, 2024, 12:00:10 pm
Thank you, I plan to appeal this. I am not familiar with the next steps, anything I should be aware of?
Title: Re: LBBD, code 12 parked in resident's bay, Halbutt Street RM9 5AH
Post by: cp8759 on June 16, 2024, 03:18:16 pm
@george74 well there are several issues here but in a case like this, I think it's important to remember regulation 7(8) of The Civil Enforcement of Road Traffic Contraventions (Representations and Appeals) (England) Regulations 2022 (https://www.legislation.gov.uk/uksi/2022/576/regulation/7):

(8) If an adjudicator—
(a) does not allow an appeal, but
(b) is satisfied that there are compelling reasons why, in the particular circumstances of the case, the enforcement notice should be cancelled,
the adjudicator may recommend to the enforcement authority that it cancel the enforcement notice.

Even if the adjudicator cannot find any legal ground to allow the appeal, I still think virtually all adjudicators would make a recommendation that the penalty be cancelled. In one third of cases the council refuses the recommendation, in one third of cases it accepts it, and in the other third it does not respond, and if there is no response after 35 days then they are deemed to have accepted the adjudicator's recommendation.

Therefore at worst you have a 66% chance of getting the penalty cancelled, and we might also find some statutory ground that the adjudicator accepts, including in particular failure to consider which some adjudicators still accept notwithstanding the Halton judgment, which strictly speaking does not apply to parking cases.

On that ground, my personal recommendation would be to carry on.
Title: Re: LBBD, code 12 parked in resident's bay, Halbutt Street RM9 5AH
Post by: Pastmybest on June 12, 2024, 11:05:49 pm
The NoR whilst not specifically addressing your points in mitigation does do enough to comply with the Halton Council vs the road user charging adjudicator ruling that the adjudicator is bound to follow

Any continuation with this would be trusting to the council cocking up which the often do 
Title: Re: LBBD, code 12 parked in resident's bay, Halbutt Street RM9 5AH
Post by: george74 on June 12, 2024, 10:09:36 pm
Bump
Title: Re: LBBD, code 12 parked in resident's bay, Halbutt Street RM9 5AH
Post by: george74 on June 09, 2024, 04:03:24 pm
How can I challenge this? To me, it seems they have not actually addressed my challenges
Title: Re: LBBD, code 12 parked in resident's bay, Halbutt Street RM9 5AH
Post by: george74 on June 07, 2024, 05:06:42 pm
Rejected

https://ibb.co/rcvrC53
https://ibb.co/mzt5Y2S
Title: Re: LBBD, code 12 parked in resident's bay, Halbutt Street RM9 5AH
Post by: george74 on May 22, 2024, 11:32:50 pm
Thank you CP for providing the challenge above.

I tried to hold out for the letter but there have been delays - I have submitted the challenge above now without the letter (added diagnosis, appointment, and treatment letters).

Will update when I hear back.
Title: Re: LBBD, code 12 parked in resident's bay, Halbutt Street RM9 5AH
Post by: cp8759 on May 03, 2024, 06:36:36 pm
@george74 here you go:

Dear London Borough of Barking and Dagenham,

I ask that this penalty charge notice be cancelled for the following reasons.

The parking permit expired two weeks prior to the PCN being issued, my permit expired 2 weeks before this PCN. The permit is held under my wife's account, having checked I can now she that she did receive a renewal reminder but did not act upon it.

I should explain that sadly my wife is suffering from brain cancer, she is currently undergoing whole brain radiotherapy which causes many side effects including memory loss, I believe this has contributed to the permit renewal not being actioned.

In your previous letter you requested supporting evidence, I therefore attach her diagnosis letters, treatment letters and appointment letters. I have asked the nurse if we could be provided with a letter confirming that the side-effects of the treatment include memory loss but apparently only the oncologist can provide this, we have an appointment to see the oncologist in a couple of weeks and will ask for such a letter at the time and we will promptly forward it to you.

We would ask that you keep the case on hold until we have obtained the letter from the oncologist.

Yours faithfully,

Send this online and make sure to keep a screenshot of the confirmation page. If the text doesn't fit, put the text of the representation in a PDF file (do not cut bits of the text out).

If there's a limit on the number of attachments, use https://www.ilovepdf.com/merge_pdf to stitch all the supporting letters together into a single file.
Title: Re: LBBD, code 12 parked in resident's bay, Halbutt Street RM9 5AH
Post by: george74 on May 02, 2024, 10:42:53 am
Sorry for the delay.

Unfortunately the nurse said I'd have to ask the oncologist instead. The nurse can write some things but not this.

Appointment with oncologist is in a couple weeks. We still have diagnosis letters, appointment letters etc.
Title: Re: LBBD, code 12 parked in resident's bay, Halbutt Street RM9 5AH
Post by: cp8759 on April 28, 2024, 11:41:53 pm
I can gather

  • diagnosis letters
  • treatment
  • appointment letters (monthly)
  • Could get a letter from the nurse explaning radiotherapy side effects if needed
We have a bit of time to prepare the representations, I think a letter from the nurse would be compelling so it's worth getting. How quickly do you think you could get that?
Title: Re: LBBD, code 12 parked in resident's bay, Halbutt Street RM9 5AH
Post by: george74 on April 27, 2024, 04:50:13 pm
I have the NTO



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Title: Re: LBBD, code 12 parked in resident's bay, Halbutt Street RM9 5AH
Post by: Hippocrates on April 01, 2024, 04:26:53 pm
That sounds about right.
Title: Re: LBBD, code 12 parked in resident's bay, Halbutt Street RM9 5AH
Post by: george74 on April 01, 2024, 03:56:48 pm
I can gather

Title: Re: LBBD, code 12 parked in resident's bay, Halbutt Street RM9 5AH
Post by: cp8759 on April 01, 2024, 01:09:48 am
@george74 here are:

The London Borough of Barking and Dagenham (Charged-For Parking Places) Consolidation Order 2016 (https://drive.google.com/file/d/19CC2bsFAW0A9wCVxJcvbHv0Bnhj2eYZn/view)
Map tile W14 (https://store.traffweb.app/barking-dagenham/documents/parkmap/msched/W14_rv6_1.pdf)
GSV: https://maps.app.goo.gl/YXNut6PUeq9idbXj9

It's not true that you'd necessarily be risking the full penalty if you carry on: as long as you challenge the notice to owner within 14 days, the discount is almost invariably reoffered.

That being said you have some extremely compelling mitigation, so I would suggest you put together some medical evidence (diagnosis paperwork, appointment letters etc). Don't post private medical information on here, but please give us a list of what you can put together.

When you have the notice to owner I will draft a formal representation for you.
Title: Re: LBBD, code 12 parked in resident's bay, Halbutt Street RM9 5AH
Post by: george74 on March 30, 2024, 04:35:57 pm
I was able to locate the original PCN but I can't retrieve the reps I made.

The permit is under my wife's account. Looks like she did receive a renewal reminder but she missed it.

She's has whole brain radiotherapy so has some memory loss and it affects her in many areas of life including this. I put this in the reps and it looks like they may consider with more evidence but not sure where to submit more unless they mean in a new challenge.



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Title: Re: LBBD, code 12 parked in resident's bay, Halbutt Street RM9 5AH
Post by: Incandescent on March 24, 2024, 11:43:49 pm
Sorry, but without the PCN, and sight of your representations, it is very difficult to give considered advice. However, you admit you let your permit run out and didn't renew it, so if it were me, I think I'd pay the discount. From this point on, you'd be risking the full penalty.  Without sight of the PCN we can't assess it for fatal errors that can win on their own.
Title: LBBD, code 12 parked in resident's bay, Halbutt Street RM9 5AH
Post by: george74 on March 24, 2024, 09:05:53 pm
I received a PCN for parking in a resident's/shared bay without a valid permit.

I parked in a parking space on the road I live but much further along from where I live. My permit did expire and it's my fault though I did not receive any reminders. Additionally, my permit expired 2 weeks before this PCN. In that time I have been parking outside my house on the same road as normal without any PCNs being given, I suppose it does not matter in the sense that I would have gotten a PCN one way or another, I just didn't realise and surprised I didn't get one sooner.

I have lost the original PCN unfortunately - I did make an initial appeal stating the above but it was rejected. The rejection itself is confusing though - it asks for more evidence but at the same time doesn't explicitly mention my challenges.



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