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Live cases legal advice => Civil penalty charge notices (Councils, TFL and so on) => Topic started by: duncedunce on May 08, 2024, 01:52:01 pm

Title: Re: Time limit to serve PCN? - Sutton (London) - Failing to comply with a restriction on vehicles entering a pedestrian
Post by: cp8759 on June 07, 2024, 11:27:13 pm
@duncedunce I think you must have some additional terms and conditions about the car lease itself, such as things telling you not to misuse the car, and detailing what happens about servicing, insurance, treating the car with due car and all that standard stuff you'd expect.

In fact I'm not sure the variation of contract you've posted is part of the leasing contract at all.

I also don't think the lease is with you, it seems to me the lease is with your employer, so there was no proper basis to transfer liability to you in the first place.

Anyway, the decision you now need to make is whether you want to appeal, I will drop you a PM in case you'd like to be represented on appeal to the tribunal.
Title: Re: Time limit to serve PCN? - Sutton (London) - Failing to comply with a restriction on vehicles entering a pedestrian
Post by: duncedunce on June 03, 2024, 08:15:40 pm
I have received the rejection letter for my reps:

(https://i.ibb.co/8jmMhnr/20240531-Reps-Response-redacted-1.png) (https://ibb.co/ZhfdZRB)
(https://i.ibb.co/Rvd3pvM/20240531-Reps-Response-redacted-2.png) (https://ibb.co/8KtrDKR)

I'm still awaiting a response from the lease company for the documents. I expect this to take a few days.
Title: Re: Time limit to serve PCN? - Sutton (London) - Failing to comply with a restriction on vehicles entering a pedestrian
Post by: duncedunce on June 03, 2024, 06:30:48 pm
Hello everyone

Here are the lease documents. I hope I've redacted what I need (and not too much):

(https://i.ibb.co/8bdV26h/20240529-Lease-redacted-1.png) (https://ibb.co/jzWFGgp)
(https://i.ibb.co/nmF3c04/20240529-Lease-redacted-2.png) (https://ibb.co/vqSsPBf)
(https://i.ibb.co/n3dsFsR/20240529-Lease-redacted-3.png) (https://ibb.co/Jx6R9RC)
(https://i.ibb.co/MgS8CL4/20240529-Lease-redacted-4.png) (https://ibb.co/wdgJz1X)
(https://i.ibb.co/TPk8fDF/20240529-Lease-redacted-5.png) (https://ibb.co/fr2pgVP)
(https://i.ibb.co/Ycbtt3b/20240529-Lease-redacted-6.png) (https://ibb.co/48Jjj7J)
(https://i.ibb.co/qnjx9Ss/20240529-Lease-redacted-7.png) (https://ibb.co/7zCbVfW)
Title: Re: Time limit to serve PCN? - Sutton (London) - Failing to comply with a restriction on vehicles entering a pedestrian
Post by: duncedunce on May 31, 2024, 02:37:26 pm
Thank you for your responses @Enceledus and @cp8759. I have been on holiday for a few days, so sorry for the time taken to respond.

Apologies also for not spotting it was a charge certificate and not the PCN. I should have realised it wasn't a PCN, but I am new to this and was rushing to get it uploaded rather than going through it.

@Enceladus, I agree that the wording and timelines evident from the charge certificate raise questions. However, I doubt I would ever get a useful response. This is a NHS Fleet Hire car, paid through salary sacrifice. NHS Fleet Hire acts as an intermediary between the leasee and the lease companies they use, and all my requests are going through them. But the contract is between Lex Autolease and myself.

@cp8759 I have a copy of the lease agreement now, and will upload it (suitably redacted) later. I have now made a request for:
I've also requested any other correspondence held by Lex Autolease about this matter.

Many thanks to everyone for the support and advice so far.
Title: Re: Time limit to serve PCN? - Sutton (London) - Failing to comply with a restriction on vehicles entering a pedestrian
Post by: cp8759 on May 27, 2024, 08:38:46 pm
Something seems not right here at all, and much more explanation is needed from the lease company about what they did when the PCN was received by them, and why a Charge Certificate was served to them as it states no representations or payment was received within the 28 days allowed on the PCN.
I've seen this a lot, the simple answer is that when a lease company receive a charge certificate and then makes a late representation asking to transfer liability, councils have a propensity to accept the out of time representations. There is nothing to stop a council from accepting representations even though they were made out of time.

The timeline from the documents is clear:

Alleged contravention 20 February 2024.
PCN issued to Lex on 27 February 2024.
Charge certificate issued to Lex on 29 March 2024.
Late representations from Lex on some unknown date.
Fresh PCN issued to duncedunce on 13 May 2024.

So this doesn't really require further explanation, it requires something more solid to use at the tribunal.

@duncedunce, in the first instance please contact the lease company and ask them if, after they made representations, they ever heard back from the council. You need an answer in writing and ideally a copy of any correspondence they received.

We also need to see the terms and conditions of your lease agreement, just redact your personal details but post the actual T&Cs in full.

The traffic order is The Sutton (Traffic Restriction) (Pedestrian and Cycle Zones) (No. 1) Traffic Order 2021 (https://drive.google.com/file/d/1OEiuIeXyPw7oqwgv0IuZMAZrWEWDCFZr/view).
Title: Re: Time limit to serve PCN? - Sutton (London) - Failing to comply with a restriction on vehicles entering a pedestrian
Post by: Enceladus on May 25, 2024, 11:58:53 am
.............
Response from the lease company:
Quote
Good afternoon XXXX,
 
The PCN is valid.
 
The PCN gets issued to your lease company first, then transfers to ourselves, which then transfers to yourself.
 
The counter date resets each time this gets transferred.
 
Kind regards

XXXX

The above seems to imply that the PCN has been served on at least two other parties before it reached you. Not just "your lease company". Some other entity in the chain of three has had the PCN. One might be a finance company and another is the lessor. That seems to make it less likely the PCN was served out of time on any of the three parties.

Who is the "ourselves"?

I suggest that you need to confirm whether Lex Autolease Ltd ever had the PCN at all, and when? Since they're the ones who received the (likely now cancelled) Charge Certificate. Did they submit a late representation that was accepted? That transferred liability to the mysterious "ourselves"?

At time of writing the PCN is sitting at £65, so sitting at the discount rate, which strictly speaking expires tomorrow Sunday.
Title: Re: Time limit to serve PCN? - Sutton (London) - Failing to comply with a restriction on vehicles entering a pedestrian
Post by: Incandescent on May 25, 2024, 12:55:29 am
If you read the CC, you'll see the dates of the contravention and the date of the PCN sent to the lease company.  The CC states that no response was received from the lease company within the 28 day period, and the Charge Certificate was issued. By not responding to the PCN, the lease company lost any option to submit representations, yet somehow they have passed on your name and address to the council who have then issued a PCN to you. 

Something seems not right here at all, and much more explanation is needed from the lease company about what they did when the PCN was received by them, and why a Charge Certificate was served to them as it states no representations or payment was received within the 28 days allowed on the PCN.
Title: Re: Time limit to serve PCN? - Sutton (London) - Failing to comply with a restriction on vehicles entering a pedestrian
Post by: duncedunce on May 25, 2024, 12:34:33 am
Ah, thank you

So, I presume I need to go back to the lease company and ask again for the PCN, pointing out this isn't it ?
Title: Re: Time limit to serve PCN? - Sutton (London) - Failing to comply with a restriction on vehicles entering a pedestrian
Post by: John U.K. on May 24, 2024, 07:53:01 pm
That's not a PCN, that's a Charge Certificate, received by the Lease Company on 4th.April.. Before issuing a CC, the Council have to issue the PCN, 
Title: Re: Time limit to serve PCN? - Sutton (London) - Failing to comply with a restriction on vehicles entering a pedestrian
Post by: duncedunce on May 24, 2024, 07:27:10 pm
Good evening everyone

I submitted the representations via the webform this evening
Quote
REPRESENTATIONS against PCN SU8012499A
PCN dated 13 May 2024
Representations submitted 24 May 2024

Dear London Borough of Sutton

I challenge liability on the basis that the penalty charge notice has been served out of time.

Yours faithfully

XXXXXX

DECLARATION: I confirm that the information contained in my representation is correct to the best of my knowledge. I understand that making a false statement may result in prosecution and a fine not exceeding level 5 on the standard scale.

Name: XXXXX
Signature: (attached)
Date: 24 May 2024

It looks like the lease company were not accurate on their dates when they informed me of the PCN (saying they'd received it that day - it was a month earlier). Here's the PCN:

(https://i.ibb.co/rQKzcJ7/20240511-PCN-Sutton-to-Leasehire-1.png) (https://ibb.co/PrsP98m)

(https://i.ibb.co/nsHmpDY/20240511-PCN-Sutton-to-Leasehire-2.png) (https://ibb.co/8DWskjf)

I can't find a copy of my lease agreement, so I've approached the lease company for a copy.

Many thanks everyone
Title: Re: Time limit to serve PCN? - Sutton (London) - Failing to comply with a restriction on vehicles entering a pedestrian
Post by: cp8759 on May 16, 2024, 11:13:23 pm
I have a copy of the V5C and it has the name and address of the lease company in the Registered Keeper section.
That's excellent, once we have the PCN served on the registered keeper we should be able to confirm this will be open and shut on appeal.
Title: Re: Time limit to serve PCN? - Sutton (London) - Failing to comply with a restriction on vehicles entering a pedestrian
Post by: duncedunce on May 16, 2024, 10:39:27 pm
Thank you @cp8759. Apologies for the additional thread and thank you for tidying it up.

I'll use your suggested representations wording to the Council - following their instructions - at the end of next week. The date of notice was 13th, so in theory I have until 27th to make representations (I thought notices sent by post are deemed served 2 business days later, but that's not an argument I need to get into), but I'll submit late on the 24th.

I'll message the lease company tomorrow asking for a copy of the PCN they received. They responded within a couple of hours last time, so if I don't get a response by midday Monday, I'll chase by phone.

I'll dig through my lease agreement and post a redacted version here.

I have a copy of the V5C and it has the name and address of the lease company in the Registered Keeper section.

Many thanks again.
Title: Re: Time limit to serve PCN? - Sutton (London) - Failing to comply with a restriction on vehicles entering a pedestrian
Post by: cp8759 on May 16, 2024, 08:10:35 pm
@duncedunce please don't make additional threads, we have a one-case-one-thread rule to ensure we can be as efficient as possible when giving advice.

The representation for this is very simple:

Dear London Borough of Sutton,

I challenge liability on the basis that the penalty charge notice has been served out of time.

Yours faithfully,

This will get the discount reoffered and will buy you a few weeks, but there's no rush so I wouldn't send this until the end of next week. As long as the representation is made within the discount period, the discount is almost invariably reoffered when the council issues a rejection. Make sure to submit it online and keep a screenshot of the confirmation page.

In the meantime I think we need to establish exactly what's gone on, so please contact the lease company as follows:

Dear Lease Company,

I am in the process of appealing PCN SU8012499A; in order to support my appeal please could you send me a copy of the penalty charge notice you recieved?

Yours faithfully,

Or if you can call them up and get them to email it to you that works too. My main concern is that we've not actually had sight of the PCN served on the lease company, also it might be that the lease company is not the registered keeper. It's possible the car is registered to a finance company that got the first PCN and then transferred liability to your lease company.

The good thing is the longer the chain back to the registered keeper, the greater the chances of the council having messed things up.

Also, please post up the terms and conditions of your lease agreement, depending on the wording there might be an additional ground of appeal.
Title: SUTTON (London) - 53C FTCW restriction on vehicles entering a pedestrian and cycle zone- Camden Road
Post by: duncedunce on May 16, 2024, 12:24:16 pm
Many thanks for the advice from @Incandescent and @cp8759 on my previous thread here: Time limit to serve PCN? - Sutton (London) - Failing to comply with a restriction on vehicles entering a pedestrian etc (https://www.ftla.uk/civil-penalty-charge-notices-(councils-tfl-and-so-on)/time-limit-to-serve-pcn-sutton-(london)-failing-to-comply-with-a-restriction-on-/msg21825/#msg21825)

I received the copy of the PCN yesterday, addressed to me. Copy below.

(https://i.ibb.co/k507Y00/20240220-PCN-Sutton-redacted-1.png) (https://ibb.co/7jVf7VV)
(https://i.ibb.co/zbJdt38/20240220-PCN-Sutton-redacted-2.png) (https://ibb.co/k01ZPL3)
(https://i.ibb.co/HtMXVwY/20240220-PCN-Sutton-redacted-3.png) (https://ibb.co/9bfGNK2)
(https://i.ibb.co/HNBy9wL/20240220-PCN-Sutton-redacted-4.png) (https://ibb.co/pWbTkV6)

I don't dispute I was the driver, and that the images on the website are of the vehicle. The signage was in place (Streetview is very old so does not show the signs), I was just unfamiliar with the route due to road closures in the area and ended up going down that road in an attempt to get to the route I know, not seeing the signage as I was concentrating on other dangers around the road.

Google streetview (https://maps.app.goo.gl/1iZbCsH1KbPLNZnw8)

Images linked to the PCN (there's a brief video, too, but it doesn't add anything)
(https://i.ibb.co/48MKb9R/PCN1.jpg) (https://ibb.co/3pW4xGm)
(https://i.ibb.co/vLnwQXq/PCN2.jpg) (https://ibb.co/p4F0Rhw)
(https://i.ibb.co/yRzzHSh/PCN3.jpg) (https://ibb.co/0X00HtB)
(https://i.ibb.co/BL6WM9x/PCN4.jpg) (https://ibb.co/4WSvrHG)

However, I do feel aggrieved that the alleged offience was on 20 February 2024, and it has taken the Council two and a half months to serve the PCN on my lease company (last week), who then redirected to me. This seems an excessive time to me and unreasonable.
Title: Re: Time limit to serve PCN? - Sutton (London) - Failing to comply with a restriction on vehicles entering a pedestrian
Post by: cp8759 on May 15, 2024, 07:31:43 pm
@duncedunce you don't need to get into any slanging match with the lease company, if the PCN to the lease company was unlawful then the PCN to you is also unlawful.

Therefore when you get your own PCN, you can challenge it on the ground that the PCN served on the registered keeper was out of time. Frankly it's much better to do this yourself and keep the lease company out of the picture, as lease companies have a propensity to mess things up.

If you look up the PCN on the council website it might give you a clue of whether it's been reissued to you.

Once you have the PCN, let us know and we'll draft a representation for you.
Title: Re: Time limit to serve PCN? - Sutton (London) - Failing to comply with a restriction on vehicles entering a pedestrian
Post by: duncedunce on May 09, 2024, 01:50:15 pm
Ugh

Response from the lease company:
Quote
Good afternoon XXXX,
 
The PCN is valid.
 
The PCN gets issued to your lease company first, then transfers to ourselves, which then transfers to yourself.
 
The counter date resets each time this gets transferred.
 
Kind regards

XXXX

I don't really want to get into a slanging match with the lease company. As I see it, they had a right to challenge that the PCN was valid, but they have decided not to do so.

Grrr

Any thoughts while I'm waiting for the PCN to come to me?
Title: Re: Time limit to serve PCN? - Sutton (London) - Failing to comply with a restriction on vehicles entering a pedestrian
Post by: duncedunce on May 09, 2024, 12:49:14 pm
Thank you @Incandescent

I've emailed my lease company back explaining the PCN was out of time and therefore not a lawful PCN. I've asked them to put that challenge to the council.  I've asked to be copied into or forwarded the follow up email to the council.

Hopefully, the lease company will do that. But they may not.

I'll update this thread on whether they do or don't contact the council about it being an out of time PCN.
Title: Re: Time limit to serve PCN? - Sutton (London) - Failing to comply with a restriction on vehicles entering a pedestrian
Post by: Incandescent on May 08, 2024, 11:08:01 pm
I suggest, while you wait for a PCN to be served, that you contact the lease company to point out that the PCN was served Out-of-Time, therefore it was an unlawful PCN, and they should again contact the council to point this out and request the PCN is cancelled.
The basic principle of English law is that one cannot break the law when enforcing it.
Title: Re: Time limit to serve PCN? - Sutton (London) - Failing to comply with a restriction on vehicles entering a pedestrian
Post by: duncedunce on May 08, 2024, 06:51:18 pm
Not sure what you mean by this: -
Quote
"they received *today* (8 May) a representation for a parking penalty charge"
Surely they just received a PCN which they responded to.
Thank you for responding @Incandescent. It was the wording used by the leasing company. Here it is in full:

Quote
Dear XXXX

For your information we have today received and processed a representation for a parking charge involving your lease vehicle.

To avoid any risk of the cost escalating we recommend that you review the PCN details and evidence via the London Borough of Sutton website with the details below:

PCN Number: XXXX
Vehicle Registration Number: XXXX

Should you be satisfied with the details of the charge, please settle this directly with the issuer via their website.

In line with your contract we have provided your name and postal address to London Borough of Sutton who will write to you directly. If you would like to appeal the charge, please wait until you receive the notice through the post in your name before submitting your appeal. If you have not received this notice within 3 weeks of this email, please contact us via email at XXXX.

If the address below is incorrect, please let us know as soon as possible.
XXXX
XXXX
XXXX
XXXX

Please be advised [we] do not hold these PCN details on file and will be unable to provide further information on the specific offence details at this time.

I, too, guess they've just responded to a PCN by providing my details (as the leasee), for the council to pursue.

[EDIT: though it isn't a "parking charge" as set out in the email, it's a penalty charge, but that makes little difference. Looking it up, the penalty code is likely to be 53 "Failing to comply with a restriction on vehicles entering a pedestrian and cycle zone." but the website doesn't give that detail, so I will only know once the council contact me]
Title: Re: Time limit to serve PCN? - Sutton (London) - Failing to comply with a restriction on vehicles entering a pedestrian
Post by: Incandescent on May 08, 2024, 05:30:31 pm
There is a time limit, but it would seem the lease hire company did not submit representations on the basis of "PCNserved out of time", but merely submitted their usual lease company representation.

Not sure what you mean by this: -
Quote
"they received *today* (8 May) a representation for a parking penalty charge"
Surely they just received a PCN which they responded to.
Title: Time limit to serve PCN? - Sutton (London) - Failing to comply with a restriction on vehicles entering a pedestrian etc
Post by: duncedunce on May 08, 2024, 01:52:01 pm
Hi
I've just been informed by my lease hire company that they received *today* (8 May) a representation for a parking penalty charge for failing to comply with a restriction on vehicles entering a pedestrian and cycle zone on 20 February 2024. I've not seen the PCN yet, but they've let the council know I was the driver.

Is there a time limit for the council to serve such a PCN? This seems to be over 2 months since the alleged offence.

It's annoying. I didn't see/take on board the signs, and it was 10 mins before the end of the restricted period (it's one of the school ones and I don't normally go that way, so didn't realise). But I'm bang to rights unless there's a time limit to serve the PCN, I guess.

Thanks for reading

[Edit: getting the "P" right in PCN!]