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Live cases legal advice => Civil penalty charge notices (Councils, TFL and so on) => Topic started by: Glitch on April 05, 2024, 05:06:38 pm

Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Hippocrates on July 10, 2024, 12:39:14 pm
How many tattoos?
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Glitch on July 10, 2024, 12:22:12 pm

I'm not going to make a fuss whilst I have Ms Pearce onside  ;D

Just had the Redbridge 'Parking Technician' on the phone asking me to send bank statement for them to make payment.
Didn't realise during the call that it was the same person that signed their witness statement for the Tribunal.

Not even a hint of apology on the call or subsequent email. Best not to let rip at the incompetent little toe rag.  :-X
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Hippocrates on July 10, 2024, 12:08:50 pm
Well I obtained costs vis a vis attendance for at least one appellant.
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Glitch on July 10, 2024, 09:29:44 am
I don't know about the attendance issue.

Seems to be due to the personal attendance being optional - I could have phoned in.

Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Hippocrates on July 10, 2024, 08:36:43 am
I don't know about the attendance issue.
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Glitch on July 10, 2024, 07:06:42 am
Extract from the costs award:

The threshold of what is "wholly unreasonable," as opposed to "unreasonable," is a high one.

The Enforcement Authority had been cognizant of the Appeal issue from the outset; that issue is one which the Tribunal had been caused to consider in multiple Appeals, the determinations of the Tribunal in such Appeal had been made known to the Enforcement Authority.

I find that the Enforcement Authority's behaviour in its silence throughout the process with regard to the pertinent issue raised by the Tribunal to be negligent in its approach to pursuing the alleged contravention at the very least, or inappropriate in continuing with the case by resisting the Appeal at worst, and thereby amounts to wholly unreasonable behaviour on the part of the Enforcement Authority warranting this award.

I therefore move on to consider quantum: In this respect I have regard to the amount claimed in the Application statement document; attendance at the Tribunal personally is entirely an Appellant's preference, I cannot award costs/expenses for the same.

I do accept the preparatory work claimed at the litigant in person hourly rate.

2 hours at £19 per hour = £38.00

Accordingly, I order that costs be awarded to the Appellant in the sum of £38 payable by the
Enforcement Authority forthwith.

Enough for some 🍻 at the nearest 'Spoons 😁
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Hippocrates on July 07, 2024, 12:03:35 am
Well done. I filmed a beautiful sunrise the same day. There is order in the universe.  :)
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Glitch on July 04, 2024, 11:17:09 am
Thanks as always to @cp8759 and especially @Hippocrates for their amazing knowledge, dedication and assistance.
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Glitch on July 04, 2024, 11:11:41 am
Success at the application for costs hearing.

She ruled out frivolous and vexatious and got me to explain why I thought it was 'wholly' unreasonable. Then said that's fine, you're pushing against an open door.

She had invited Redbridge to attend today but they didn't even bother to reply 🙄

Wouldn't allow costs for attending the tribunal but awarded a couple of hours for research.

It wasn't about the money. It's the principle of not allowing Redbridge to get away with their incompetence!
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Hippocrates on June 14, 2024, 11:38:44 am
Excellent!  I will email you. If successful, another tattoo?  ;D
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Glitch on June 14, 2024, 09:34:06 am
Application for costs accepted. Hearing on 4th July. 😁
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Hippocrates on June 10, 2024, 09:20:55 am
Fingers crossed that a hearing will be accepted. IMO her decision clearly states her concerns.
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: cp8759 on June 10, 2024, 12:13:38 am
My heart sank when I saw it was Belinda Pearce. Third time in four appearances I've had her.
She's not refused an appeal of mine for many years now.
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Hippocrates on June 06, 2024, 12:07:53 am
Spot on!

What do I need to do with this?

I will email you. 
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Glitch on June 06, 2024, 12:04:22 am
Spot on!

What do I need to do with this?
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Hippocrates on June 05, 2024, 10:54:46 pm
Dear Sirs

Following the decision of Adjudicator...............I make this application for costs in a timely manner as I consider the council's pursuit of this case to be wholly unreasonable from the outset.

Grounds

1. My formal representations  were legally and incontrovertibly correct.
2. The council's failure to accept them demonstrates not only incompetence in terms of their knowledge of the law pertaining to yellow box junctions, but also their wholly unreasonable conduct which forced me to take the matter to adjudication at this honourable Tribunal..
3. The Adjudicator accepted my submissions and was critical of, and concerned by, the council's evidence as expressed in paragraphs 4 to 6.

In light of the above, I ask for a personal hearing to determine my application which I believe is entirely reasonable under the  prevailing circumstances. I attach my Witness Statement and claim costs accordingly i.e. from the receipt of the Notice of Rejection.

Yours faithfully
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Hippocrates on June 05, 2024, 08:13:42 pm
Game on. μολὼν λαβέ.
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Glitch on June 05, 2024, 02:28:54 pm
@Hippocrates lets go for it!

I'll DM you the details to view the evidence pack.

PCN should never have been issued.
NoR is lies
CCTV Operator Witness Statement is lies
Parking Technician's Council Summary is lies

3 named people have lied despite being so called 'professionals'.
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Hippocrates on June 05, 2024, 01:30:21 pm

Disingenuous bar stewards.

That's my phrase: Stewards of the Bar. ;D
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Hippocrates on June 05, 2024, 01:26:46 pm
I must have just missed you as I walked past the said lady as I was going to the Tribunal down Furnival Street about 1.20 p.m. I would say yes.*

*5. I am concerned that either:-

i) the Enforcement Authority was privy to evidence which it has omitted to furnish to the Tribunal
and/or
ii) the Enforcement Authority has failed to duly consider the evidence available to it.



I am happy to draft an application for you and would appreciate the whole evidence pack if you agree. £19 per hour post receipt of the NOR. Be a good opportunity to meet at last too.  ;) Though you would not need to attend in person.  14 days to file an application.
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Glitch on June 05, 2024, 08:07:16 am
Thanks as always for the sound advice.

Is there enough in this to claim costs? - a token 1p, just to make the point that Redbridge should never have taken this to Tribunal.


Quote
Adjudicator's Reasons

The Appellant attended a Personal Appeal Hearing before me today, 4th June 2024, to explain his
contention personally.

1. The Enforcement Authority assert that the said vehicleentered and stopped on a location subject to
an operative restriction denoted by yellow cross-hatching, such demarcation indicating a prohibition
against a vehicle remaining stationary within the defined area due to the presence of stationary
vehicles.
2. The Appellant denies liability for the ensuing Penalty Charge Notice on the basis of the challenges
as indicated in his written representations, which he reiterated and comprehensively detailed at the
Hearing.

I am grateful to the Appellant for his thorough research and the manner of presentation of his
contention.  ;D

3. The Enforcement Authority who assert that the said vehicle was so driven contrary to the operative
restriction are obliged to adduce evidence to the requisite standard to substantiate that assertion:-
The evidence upon which the Enforcement Authority rely comprises the certified copy Penalty Charge
Notice together with photographic evidence: CCTV footage and still frames taken there-from revealing
the said vehicle in situ and the applicable carriageway markings notifying motorists of the prohibition.

4. The contemporaneous photographic capture was examined (repeatedly) to evaluate the allegation
in conjunction with the Appellant's representations.
At the commencement of the footage the said vehicle is already positioned on the cross-hatching;
despite the Enforcement Authority's references in its Notice of Rejection ("the driver would have been
aware when entering the box junction that they would not be able to exit") and Case Summary ("you
will see from the CCTV footage the vehicle enters whilst the appellants exit is not clear") there is no
evidence before me of the said vehicle entering the cross-hatched area.
In light of the nature of the restriction, which is echoed in the wording on the Penalty Charge Notice
("alleged traffic contravention:- Enterinq and stoppinq in a box junction when prohibited") the evidence
crucial to determination as to the occurrence of a contravention or otherwise i.e. the situation at the
said vehicle's point of entry, is absent.

5. I am concerned that either:-

i) the Enforcement Authority was privy to evidence which it has omitted to furnish to the Tribunal
and/or
ii) the Enforcement Authority has failed to duly consider the evidence available to it.

6. I am not satisfied by the evidence in this Case; I do not find a contravention proved.

The evidential burden does not pass to an Appellant unless and until that evidential burden is
discharged satisfactorily by the Enforcement Authority.

Evidentially I cannot find that the alleged contravention occurred.
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Glitch on June 04, 2024, 11:54:47 am
My heart sank when I saw it was Belinda Pearce. Third time in four appearances I've had her.

However, she was very cheerful and pleasant  this time.
I didn't need to say anything. She threw it out for lack of evidence.

I made the point that Redbridge think they've seen me entering the box and say that in the NoR, CCTV witness statement and council summary. They also think that we can clearly see it.

Disingenuous bar stewards.

Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: cp8759 on May 28, 2024, 09:31:07 am
Personal hearing next week. 4th June.

Do I need to upload a statement at all?
You don't have to provide any statement, all you need to make is a legal submission along the lines of reply 18 above.
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Glitch on May 28, 2024, 08:26:17 am
The golden rule about making statements is: the less you write, the less on which you can be cross-examined.

@Hippocrates
Makes sense. Without knowing how best to play it I did a brain dump in that statement trying to play through how the hearing would go but I have been concerned about falling into an Adjudicator trap! Thankfully I haven't uploaded it.
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Glitch on May 28, 2024, 07:56:07 am
Or is the burden of proof with Redbridge to prove the contravention rather then me pitch my explanation of events?
@Glitch most people get this wrong: the correct position is that the council has to prove its case. Until it does so, you don't have to say or prove anything.

When is your hearing due? You don't want to rush things.

I think what you've written is far, far too long. All you really need to say is that the video does not show your vehicle entering the box junction, so there is no evidence of any contravention occurring at the time alleged, or at all.

@cp8759 Thanks for replying and clarifying. thankfully I haven't uploaded it.

Personal hearing next week. 4th June.

Do I need to upload a statement at all?
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Hippocrates on May 27, 2024, 11:44:25 pm
The golden rule about making statements is: the less you write, the less on which you can be cross-examined.
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: cp8759 on May 27, 2024, 11:03:50 pm
Or is the burden of proof with Redbridge to prove the contravention rather then me pitch my explanation of events?
@Glitch most people get this wrong: the correct position is that the council has to prove its case. Until it does so, you don't have to say or prove anything.

When is your hearing due? You don't want to rush things.

I think what you've written is far, far too long. All you really need to say is that the video does not show your vehicle entering the box junction, so there is no evidence of any contravention occurring at the time alleged, or at all.
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Glitch on May 27, 2024, 10:17:19 am
I plan to upload this as my 'evidence' today.

I am familiar with this box junction and with all box junctions I am very cautious. I follow Rule 174 of the Highway code, i.e., You MUST NOT ENTER the box until your exit road or lane is clear.
On this occasion I recall ensuring I had a clear exit before I enter the box. My exit was impeded by circumstances beyond my control, some but not all of which are captured in the limited Redbridge video evidence.

It is my understanding that the Videalert-RDS CCTV camera used at this junction is unattended and automatically captures images of a stationery vehicle and the system subsequently produces the evidence for review.

The CCTV Operator (Nahid Adnan) in his witness statement believes that the captured footage confirms the contravention of ‘entering and stopping whilst prohibited’. I believe he has only been able to review the automatically produced video that they have provided to me on their website and the very same video in their evidence pack and that he did not witness the alleged contravention in real-time.

The Parking Technician (Shaz Aziz) writes in the Council’s Summary of Representation that they are confident the contravention has occurred, they state:
 ‘as you will see from the CCTV footage the vehicle enters whilst the appellants exit is not clear.’
 
The assertions of the CCTV Operator and the Parking Technician are not evident in the Redbridge video footage. If there is an extended version of the video it has not been provided.

The “prohibition” is that of  “causing a vehicle to enter..” followed by the consequence. It is the entering into the box junction which constitutes the contravention, once the vehicle has had to stop. 

The video evidence does not cover the entry to the box, or me coming to a halt. The key evidence is missing. I cannot understand how the CCTV Operator or the Parking Technician can be ‘confident’ and assert the contravention occurred if they don’t have evidence of the state of the traffic as I decide to enter the box.

I needed to be in the left hand lane at the lights up ahead. On entry the exit was clear but I recall at least one car up ahead moving from the left hand lane to the right hand lane. It then became apparent to me that there was a stricken vehicle in the left hand lane and these vehicles are moving to avoid the stricken vehicle. Whilst carefully assessing the situation two cars have approached from the left.
 
The driver of the blue car has taken my hesitation as an invitation to proceed, the orange car also proceeds to leave the side road and on seeing the broken down car decides to stop and block the exit from the box.

I reversed very slowly and carefully to avoid blocking the junction. My intent was to reverse out of the box but a car behind arrives and blocks my exit.

I have not impeded the flow of traffic in any direction as evidenced in the CCTV video and decided it was safer to stop until the traffic ahead has cleared.

The video evidence does not prove the contravention and does not match the words used by Redbridge. On these grounds I ask for the appeal to be allowed.
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Glitch on May 24, 2024, 06:52:32 pm

Does the lack of a full video deny me the opportunity to prove the contravention did not occur?

Do I still have to put forward my explanation and we wander off into balance of probability?

Or is the burden of proof with Redbridge to prove the contravention rather then me pitch my explanation of events?
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Glitch on May 24, 2024, 06:19:42 pm
Redbridge have uploaded their evidence.

It's the same video that starts with me in the middle of the box. No evidence of entering the box.

The following statement in the pack from them is as a minimum, disingenuous and most likely a downright lie!

 
Quote
GROUNDS FOR CONTESTING THE APPEAL
 I am confident that the convention has occurred, as you will see from the CCTV footage the
 vehicle enters whilst the appellants exit is not clear. The Highway Code advises "You MUST NOT
 enter the box until your exit road or lane is clear"
The appellant is traveling in a lane that is full to its capacity before the yellow box, the appellant
 could not exit this, he is then reversing in the yellow box which is a very dangerous practice, the
 appellant should not have entered and waited.
 I can confirm that the findings are that; the driver should have anticipated/ waited and assessed
 the situation, before entering the yellow box and only entered if their exit was clear and only if the
 vehicle cleared the yellow box. As the vehicle did not fully exit the yellow box the PCN remains
 valid. lt has also been confirmed that the vehicle was stopped/ stationary within the yellow box
 whilst not permitted.
 The appeal has been considered; however, the Council is not prepared to cancel the charge, I
 would therefore respectfully request that this appeal be refused 

1. There is no evidence of the state of the exit at the time I enter the box.
2. There is a clear exit on the left hand side.
3. Having seen the broken down vehicle in the LH lane I slowed down to assess the situation after which two vehicles come out of the side road, one of which I decide to allow out and the other proceeds to block my exit. I'm pretty sure there was a vehicle or two behind the broken down vehicle which moved over to the right.
4. I reversed a small amount very slowly and carefully to allow traffic to flow but had to stop due the vehicle behind me.
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Glitch on May 22, 2024, 10:03:08 am
Less than two weeks before Tribunal.

Nothing uploaded by Redbridge yet but I guess that could go to the wire.

I have stuck with 'No contravention' and no other explanation.

I don't recall exactly what happened, only that I would not have entered the box without a clear exit and would not be lined up on the right.

Is this a case of going straight in with 'the video does not show me entering the box, therefore the contravention cannot be proved.' Sit back and keep quiet.

Or do I start with 'I wouldn't have entered the box without a clear exit. I needed to turn right at the lights up ahead. The exit was clear but the broken down car up ahead has caused other cars to block my route....but the video fails to show the issue at the time I entered the box and eventually came to a stop.

Could an adjudicator say, 'yes, but you have clearly stopped in the box and on the balance of probability....'?
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Glitch on April 30, 2024, 07:39:36 am
Date came through last night.
Tuesday 4th June - perfect for me.
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Glitch on April 29, 2024, 10:35:58 pm
Yes I've requested a face to face hearing.
No rush on my part. I'll need to fit it in between a number of trips.
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: cp8759 on April 29, 2024, 10:21:26 pm
Have you requested a hearing?

You won't get a hearing that soon, there has to be at least a 21 day gap between the appeal being filed and the case being decided.
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Glitch on April 28, 2024, 08:03:23 pm

I assume I just say I rely on my formal repesentations and wait to see what Redbridge submit as evidence?

I've done this.

Away for 10 days in May so I'll postpone it until late May if necessary.
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Glitch on April 27, 2024, 09:23:31 pm

I assume I just say I rely on my formal repesentations and wait to see what Redbridge submit as evidence?
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Glitch on April 24, 2024, 01:19:47 pm
Rejection received today. They have carefully considered the points raised in my appeal, which said:

 'The contravention did not occur. Please cancel the PCN'.


(https://i.ibb.co/hdMxMNL/NoR-1.jpg) (https://ibb.co/jw595Yb)
(https://i.ibb.co/cDctBpK/NoR-2.jpg) (https://ibb.co/Yp78CK4)


They are satisfied that I would have been aware the exit was clear before entering the box.

I'm happy to go to Tribunal with this on the basis they have not provided the video of me entering the box junction.
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Glitch on April 08, 2024, 03:04:14 pm
Done!
Will await the rejection  :)

They've sent an email confirmation, unlike Tower Hamlets.
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: cp8759 on April 06, 2024, 11:01:17 pm
The council will reject no matter what you say so I'd go for something very basic:

Dear London Borough of Redbridge,

The contravention alleged did not occur, please would you cancel the PCN.

Yours faithfully,

Keep a screenshot of the confirmation page.
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Glitch on April 06, 2024, 02:08:34 pm
Thanks CP, that's very good to know.

Is the broken down car still relevant? Or just go all in on the flawed evidence?
Initially I was wary about coming up with what I thought I did and an extended video showing something else.
It sounds like we won't know for sure, but don't need to.
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: cp8759 on April 06, 2024, 01:33:59 pm
Video:

https://www.youtube.com/watch?v=y5LBTvHyIWs

The video is not clipped, the camera is designed by someone who knows nothing about the law and simply detects a vehicle stopping and then saves so many frames before and after the detected event. As the stoppage in this case is longer than the pre-programmed number of seconds, the entry into the box was never saved, so there is no "full" video that's been cropped, the video above is everything the council has.
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Incandescent on April 05, 2024, 06:41:24 pm
Thanks Mr Chips.

I guess there's a clue in the contravention wording - ENTERING and stopping in a box junction when prohibited.
You've got it !
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Glitch on April 05, 2024, 05:16:23 pm
Thanks Mr Chips.

I guess there's a clue in the contravention wording - ENTERING and stopping in a box junction when prohibited.
Title: Re: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: MrChips on April 05, 2024, 05:11:34 pm
Very unlikely you'll have to pay anything for this one - the video starts with you already stationary and half way in the box.  The independent adjudicators consistently require the video to show the moment of entry as otherwise there's no evidence an offence occurred at all.

You'll need to challenge this to Redbridge.  They will reject your appeal (very unreasonably).  You'll then need to commence the appeal process with the adjudicators.  Redbridge will either then fold before the hearing or else your case will get heard and you'll win.
Title: Redbridge - George Lane 31J Stopping in a box junction when prohibited
Post by: Glitch on April 05, 2024, 05:06:38 pm
:-[
This was me. Dropped the wife off for a tattoo (at her age? but that's another story)

Don't know how to download the video but that tells the story in more detail.
I do vaguely remember this.

I need to turn left at the top of George Lane but there is a broken down vehicle blocking the lane.
I've seen it late and to avoid getting stuck behind the broken down car I position myself to the right hand lane.
I must have seen the exit clear but then realised the lane is blocked further along.
Cars coming out of Sainsbury's to the left are now also restricting my options.

I've reversed up a bit so I don't block any traffic, but no there's a car behind me so I stop.

The video does not show me entering the box. Surely it should or we don't know the whole story?
I don't know if other cars moved to avoid the broken down car.
I must have seen the exit clear as I entered the box but not clear why I'm already positioned to the right when the video starts.

Sort of (cynically) thinking the video is clipped to help them and not me.


(https://i.ibb.co/B4c7ZC6/Rebridge-PCN-200320-Part-1-of-2.jpg) (https://ibb.co/8zNR57x)
(https://i.ibb.co/F5mB8Vm/Rebridge-PCN-200320-Part-2-of-2.jpg) (https://ibb.co/PcF51QF)