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Live cases legal advice => Civil penalty charge notices (Councils, TFL and so on) => Topic started by: Justicenow on December 02, 2024, 07:26:27 pm

Title: Re: Bromley council. Charge Certif. PCN code 27, parked on Albemarle road blocked with flower pot.no sig
Post by: Justicenow on March 16, 2025, 06:26:36 pm
It was submitted on 31 January, so it’s within the 56 days.
Title: Re: Bromley council. Charge Certif. PCN code 27, parked on Albemarle road blocked with flower pot.no sig
Post by: cp8759 on March 16, 2025, 06:09:46 pm
Would the same procedure with the charge certificate and order for recovery still followed after this stage of review?
No it does not, the council has 56 days to serve a response and if the response is a notice of rejection, you then have 28 days to pay the full penalty or appeal to the tribunal.

When exactly did you submit the formal representation?
Title: Re: Bromley council. Charge Certif. PCN code 27, parked on Albemarle road blocked with flower pot.no sig
Post by: Justicenow on March 16, 2025, 01:57:50 pm
No, I’m not challenging this evidence. I remembered mistakenly that I was already in the car started to move away.
I accept my responsibility. Would the same procedure with the charge certificate and order for recovery still followed after this stage of review?

Thank you again
Title: Re: Bromley council. Charge Certif. PCN code 27, parked on Albemarle road blocked with flower pot.no sig
Post by: H C Andersen on March 16, 2025, 01:21:10 pm
You posted earlier:
I started to move the car from that spot while the officer was still preparing and printing the ticket. While I was moving the car, he tried to stick the envelope on my moving car’s windscreen but could not do that properly and I didn’t let him take a photo..

However, the bodycam shows you (presumably) removing a PCN envelope from the windscreen and aggressively thrusting this at the CEO.

Are you challenging this evidence?



Title: Re: Bromley council. Charge Certif. PCN code 27, parked on Albemarle road blocked with flower pot.no sig
Post by: Justicenow on March 16, 2025, 10:28:50 am
Thank you for all the advice and explanations. Very much appreciate all your help.
Title: Re: Bromley council. Charge Certif. PCN code 27, parked on Albemarle road blocked with flower pot.no sig
Post by: Incandescent on January 25, 2025, 09:58:04 pm
The plain fact here is that as correctly identified by CP8759, the council failed to follow the legal process after a "drive-away". They served an NtO, not a Reg 10 PCN, (postal pcn). By doing this they committed a procedural impropriety and also robbed the OP of his option to pay the discounted amount.
Title: Re: Bromley council. Charge Certif. PCN code 27, parked on Albemarle road blocked with flower pot.no sig
Post by: H C Andersen on January 25, 2025, 06:21:44 pm
I posited that >50 means not adjacent which if advanced should of course be caveated with a recognition that they should not have parked there. But just as it's a very technical argument to distinguish between the contraventions of a raised carriageway and a dropped kerb, then IMO so it is here, but nonetheless could be advanced at least at the NTO stage to test the authority's position.

OP, you misunderstand the point that's being made:

He might say that I  prevented him from giving me the PCN when he tried to put it on my moving car.

Let's hope the notes DO say this because if so it prevents them serving a NTO. This is procedural.

If a regulation 9 PCN is affixed to the car or handed to the person in control then the next stage is a NTO. However, if the CEO was prevented then the ONLY course available to the authority is the serve a PCN by post.

Title: Re: Bromley council. Charge Certif. PCN code 27, parked on Albemarle road blocked with flower pot.no sig
Post by: cp8759 on January 25, 2025, 05:53:18 pm
The CEO might have put in the notes that the PCN was served, as it says exactly that in the NTO letter that I received recently.

I wouldn't worry about that, at the end of the day the NTO is just a standard templated document, and the CEO isn't going to come to any tribunal hearing to give oral evidence.
Title: Re: Bromley council. Charge Certif. PCN code 27, parked on Albemarle road blocked with flower pot.no sig
Post by: Justicenow on January 25, 2025, 05:50:29 pm
OK, understood, so it does appear that I am skating on a very thin ice here. The CEO might have put in the notes that the PCN was served, as it says exactly that in the NTO letter that I received recently. He might say that I  prevented him from giving me the PCN when he tried to put it on my moving car.  Will definitely avoid this kind of traps in future, it will be a very good lesson to learn (and potentially expensive). Thank you for the explanations.
Title: Re: Bromley council. Charge Certif. PCN code 27, parked on Albemarle road blocked with flower pot.no sig
Post by: cp8759 on January 25, 2025, 03:42:54 pm
That part of the road is not a functioning carriageway anymore, at least in that little bit of the island, since they blocked it, would this regulation still apply here? Just curious to know. Thank you very much once again.
As far as I'm aware any vehicle that isn't mechanically propelled (i.e. a bicycle, pedestrian operated vehicle) and any animal (horses, ponies) can still use that carriageway, and I'm sure an exempt motor vehicle can as well (such as a police motorcyclist). If it isn't a carriageway at all then you'd commit a different contravention of being parked on a part of a road other than a carriageway, which is also a statutory contravention.

The long and the short of it remains that while we can almost certainly get this PCN cancelled on procedural grounds, it is actually illegal to park there and if you park there again and the council does everything by the book, you might not be able to get out of it.
Title: Re: Bromley council. Charge Certif. PCN code 27, parked on Albemarle road blocked with flower pot.no sig
Post by: cp8759 on January 25, 2025, 03:38:45 pm
No, that's not my point. Rather, the issue for me is that IMO you were clearly in contravention of one of two mutually exclusive statutory prohibitions i.e. if you were >50cm then this is a contravention in itself, and if you weren't then this is being 'parked adjacent to'.

You're giving a very, very narrow reading to the words "parked adjacent to", it is pretty obvious that on a purposive interpretation this means on the side of the road where the dropped kerb is. Honestly I would be concerned in advancing this argument because the adjudicator might think the appellant is taking the proverbial.
Title: Re: Bromley council. Charge Certif. PCN code 27, parked on Albemarle road blocked with flower pot.no sig
Post by: H C Andersen on January 25, 2025, 01:30:35 pm
No, that's not my point. Rather, the issue for me is that IMO you were clearly in contravention of one of two mutually exclusive statutory prohibitions i.e. if you were >50cm then this is a contravention in itself, and if you weren't then this is being 'parked adjacent to'.

IMO, you were >50cm therefore you would be fortunate in that the CEO's grounds won't fly.

I highlighted the relevant part of the statutory* prohibition. 

cp's reasoning is predicated on your account and that there aren't photos of the PCN having been affixed to the car. The rules regarding service are:

a)fixing a penalty charge notice to the vehicle, or

(b)giving a penalty charge notice to the person appearing to the civil enforcement officer to be in charge of the vehicle.

We haven't seen the CEO's notes, but if they do not support (b)(which wouldn't need photos) then there is no reason why the procedural grounds should not succeed. My argument, if accepted by an adjudicator, doesn't rely upon a PCN being served anyway.

But even if you were to succeed on the narrow point of procedure in this case, IMO you were in contravention of one of two statutory prohibitions and subject to the yellow line waiting restriction if this was in effect at the time.

In short, don't park there because for any competent CEO this would be open house.

*- being statutory it doesn't require signs nor an understanding of SEAs on the part of the motorist.
Title: Re: Bromley council. Charge Certif. PCN code 27, parked on Albemarle road blocked with flower pot.no sig
Post by: Justicenow on January 25, 2025, 12:52:58 pm
Thank you for this advice. I appreciate it very much and understand that for the PCN to be considered served in person at the spot, it should have been attached on a stationary car and stay on it. But as it wasn’t the council should have posted the PCN to my address before issuing the NTO. The CEO should not throw himself on a moving vehicle risking an injury. I submit my appeal as suggested on the basis that the PCN wasn’t served properly. Let’s see what the council will respond with.

 However, @H C Andersen, in your comment you are asking if my car was parked less than 50 cm to the dropped kerb in a special enforcement area? And if it was then it’s a contravention? There are no signs there to say it’s a special enforcement area, shouldn’t it be clearly signposted? That part of the road is not a functioning carriageway anymore, at least in that little bit of the island, since they blocked it, would this regulation still apply here? Just curious to know. Thank you very much once again.
Title: Re: Bromley council. Charge Certif. PCN code 27, parked on Albemarle road blocked with flower pot.no sig
Post by: cp8759 on January 24, 2025, 10:27:42 am
Easy peasy lemon squeezy:

Dear London Borough of Bromley,

I challenge liability on the basis of a procedural impropriety: no regulation 9 PCN was served, so the council was not authorised to serve a Notice to Owner.

I did see the CEO when I returned to my car, I started to move the car from that spot while the officer was still preparing and printing the ticket. While I was moving the car, he tried to stick the envelope on my moving car’s windscreen but he was unable to do so and I drove off.

In the circumstances a postal PCN could have been served under regulation 10, but a Notice to Owner cannot be served in these circumstances.

It follows that the PCN must be cancelled.

Yours faithfully,


Send this online and take a dated & timed screenshot of the confirmation page.
Title: Re: Bromley council. Charge Certif. PCN code 27, parked on Albemarle road blocked with flower pot.no sig
Post by: H C Andersen on January 24, 2025, 09:41:00 am
Interesting legal issue here IMO:

86Prohibition of parking at dropped footways etc.
(1)In a special enforcement area a vehicle must not be parked on the carriageway adjacent to a footway, cycle track or verge where—
...(the rest is not germane)

So is > 50cm adjacent?

Title: Re: Bromley council. Charge Certif. PCN code 27, parked on Albemarle road blocked with flower pot.no sig
Post by: Justicenow on January 24, 2025, 04:03:05 am
@Justicenow did you see the CEO? Or did you come back to your car and not see anything untoward at all?
But photos of any kind are not a legal requirement, so the absence of a PCN yellow envelope is not definite proof of non-service.
If the matter is raised it is for the council to prove that the PCN was served, it is not for the motorist to prove that it wasn't, the standard of evidence is the balance of probabilities. At this stage I'm simply trying to establish what evidence Justicenow can give us.

Thank you for looking into the details. I did see the CEO when I returned to my car, after being parked there only for a couple of minutes. I started to move the car from that spot while the officer was still preparing and printing the ticket. While I was moving the car, he tried to stick the envelope on my moving car’s windscreen but could not do that properly and I didn’t let him take a photo. I was confident that there was no contravention because there aren’t any signs there at all. I parked on the left side where there is no yellow line, but it is a dropped curb on both sides though. Previously, I spoke with other road users who had successfully appealed their parking tickets, being parked in that same spot, who shared with me that, apparently, because of the changes in the road layout and flower pot blocking it, the general rules do not apply (which might not be true). 
Title: Re: Bromley council. Charge Certif. PCN code 27, parked on Albemarle road blocked with flower pot.no sig
Post by: cp8759 on January 23, 2025, 11:31:18 pm
@Justicenow did you see the CEO? Or did you come back to your car and not see anything untoward at all?
But photos of any kind are not a legal requirement, so the absence of a PCN yellow envelope is not definite proof of non-service.
If the matter is raised it is for the council to prove that the PCN was served, it is not for the motorist to prove that it wasn't, the standard of evidence is the balance of probabilities. At this stage I'm simply trying to establish what evidence Justicenow can give us.
Title: Re: Bromley council. Charge Certif. PCN code 27, parked on Albemarle road blocked with flower pot.no sig
Post by: Incandescent on January 23, 2025, 11:26:34 pm
edited
Title: Re: Bromley council. Charge Certif. PCN code 27, parked on Albemarle road blocked with flower pot.no sig
Post by: cp8759 on January 23, 2025, 11:25:53 pm
@Severndroog parking in this way is at least two if not three contraventions: obstructing a dropped kerb, contravening a single yellow line waiting restriction (during prescribed hours), and possibly parking more than 50 cm from the carriageway. While we may well be able to help Justicenow get his PCN cancelled, parking in this way is clearly unlawful.
Title: Re: Bromley council. Charge Certif. PCN code 27, parked on Albemarle road blocked with flower pot.no sig
Post by: Severndroog on January 23, 2025, 11:17:14 pm
I use that road regularly and have spotted vehicles parked on that stub. It clearly is a stub, rather than a nonfunctional road.  The kerb is yellow lined. In order to park there the driver has to ignore the bollard, but I don’t think it has a keep left sign on it. It’s hard to see that parking there causes any sort of obstruction to road traffic but it does inconvenience pedestrians with wheelchairs/walking frames/buggies wishing to cross the road using the dropped kerbs.

Will be fascinating to see the outcome.
Title: Re: Bromley council. Charge Certif. PCN code 27, parked on Albemarle road blocked with flower pot.no sig
Post by: cp8759 on January 23, 2025, 10:35:22 pm
Photos:

(https://i.imgur.com/66G3Yxz.jpeg)

(https://i.imgur.com/NEix64q.jpeg)

The most blatantly obvious ground of appeal is that the PCN was not served, hence service of a Notice to Owner is a procedural impropriety.

@Justicenow did you see the CEO? Or did you come back to your car and not see anything untoward at all?
Title: Re: Bromley council. Charge Certif. PCN code 27, parked on Albemarle road blocked with flower pot.no sig
Post by: Incandescent on January 23, 2025, 10:29:22 pm
OK, so I presume you parked here ?
https://maps.app.goo.gl/DuGrsRFqkcLsmrYs9
The PCN was served because you were parked adjacent to a dropped kerb.  I have captured the GSV view that shows a dropped kerb on each side of the now-unused stub of road. If you were parked obstructing either of those dropped kerbs then the contravention is made out, as far as I can see.

A look at the CEO photos on the Bromley webpages, shows your car parked in the middle of the road stub, and when compared to my GSV view, clearly demonstrates a contravention. It is difficult to see how any car could park in this very small stub of a road and not block the dropped footways, frankly.

There may be a 'technical' appeal which other posters may suggest, so wait a bit to see if anything turns up.  I had a quick look on the Bromley council web pages which lists the statutory grounds for representations, but only allows one to be selected, which is not correct; an appellant can select more than one in accordance with the regulations.

See here, Chapter 2 5(2)(b) (i) and (ii)
https://www.legislation.gov.uk/ukdsi/2022/9780348232752/part/2/chapter/2

Would this failure not fully to follow the above regulation win at the adjudicators, London Tribunals ? One would hope so, but you'd have to risk the full PCN penalty to find out.
Title: Re: Bromley council. Charge Certif. PCN code 27, parked on Albemarle road blocked with flower pot.no
Post by: Justicenow on January 23, 2025, 08:10:46 pm
Please to post up all sides of the NtO, redacting only yr name & address.

Please see the pages of the NTO here https://www.dropbox.com/scl/fi/v9ipq63ruapznqf3zk1ki/NTO-parking-fine.pdf?rlkey=sv1vavs284n77viepg7fnsdhg&st=35a52wgl&dl=0
Title: Re: Bromley council. Charge Certif. PCN code 27, parked on Albemarle road blocked with flower pot.no sig
Post by: John U.K. on January 23, 2025, 06:43:52 pm
Please to post up all sides of the NtO, redacting only yr name & address.
Title: Re: Bromley council. Charge Certif. PCN code 27, parked on Albemarle road blocked with flower pot.no sig
Post by: Justicenow on January 23, 2025, 05:15:22 pm
You can do nothing at all to fight the PCN until you have got the process reverted to the Notice to Owner stage. So from this point on you need to be proactive as per the info in the link posted by cp8759.

@cp8759 @stamfordman
Hello again,
I’m following up on my earlier case. As you advised before, I followed the process to get to the stage of receiving the Notice to owner and want to get it right from here on. Please can you kindly advise how should I proceed further. I want to appeal the code 27 contravention as this road is not a functioning road and there are no signs or any lines/restrictions on the road and I know that other people successfully appealed this kind of contravention allegations and had the parking tickets cancelled. Please could you help further? Today, I received the NTO with the option to make an appeal. Thank you
Title: Re: Bromley council. Charge Certif. PCN code 27, parked on Albemarle road blocked with flower pot.no sig
Post by: Justicenow on January 16, 2025, 01:02:52 am
Hello, following up again on my earlier post. Have finally got confirmed that debt registered, so I submitted the TE9 form. What next steps need to be followed after this? Need to make sure I don’t miss any important milestones. Thank you for advice
Title: Re: Bromley council. Charge Certif. PCN code 27, parked on Albemarle road blocked with flower pot.no sig
Post by: Justicenow on December 03, 2024, 10:37:39 pm
Yes, of course I will be following those steps exactly as it’s laid out in the guide. Thank you very much for this advice. I am also trying to get a good understanding whether there was a contravention in the first place, it’s seems very confusing (probably on purpose) thank you again.
Title: Re: Bromley council. Charge Certif. PCN code 27, parked on Albemarle road blocked with flower pot.no sig
Post by: cp8759 on December 03, 2024, 08:11:48 pm
I never received the Notice to Owner, which I should have received before the CC, if I haven’t gotten the PCN. Is it fair to request the proof of issuing either of those?
You can ask whatever you want, but you'd be wasting your time. If you want to fight this PCN, please follow the instructions in the guide. I wouldn't ask you to follow those steps if I thought there were an easier or quicker way to do this.
Title: Re: Bromley council. Charge Certif. PCN code 27, parked on Albemarle road blocked with flower pot.no sig
Post by: Incandescent on December 03, 2024, 12:19:44 am
You can do nothing at all to fight the PCN until you have got the process reverted to the Notice to Owner stage. So from this point on you need to be proactive as per the info in the link posted by cp8759.
Title: Re: Bromley council. Charge Certif. PCN code 27, parked on Albemarle road blocked with flower pot.no sig
Post by: Justicenow on December 02, 2024, 11:23:46 pm
Thank you,
The name and address are correct in the CC, however the line with the name is misaligned and printed over another line, which is the letter registration number or smth.
The car V5 is registered to myself, that’s right.
And, yes, I do wish to fight this unfair penalty. I believe that there was no contravention in the first place. The other motorists, who got a parking ticket at that same place successfully appealed on the basis that this is not an active road as it has been blocked by planters, hence the regular rules do not apply.
I never received the Notice to Owner, which I should have received before the CC, if I haven’t gotten the PCN. Is it fair to request the proof of issuing either of those?
The fact that they reduced the originally claimed amount straight away makes me think that they know it’s wrong but ask me to pay anyway, in case if I cave in to avoid the whole palaver.

Thank you very much for the info.
Title: Re: Bromley council. Charge Certif. PCN code 27, parked on Albemarle road blocked with flower pot.no sig
Post by: cp8759 on December 02, 2024, 10:35:08 pm
Please can you advise what could I possibly do at this stage?
@Justicenow please read the guide here: https://www.ftla.uk/announcements/charge-certificate-cases-under-the-traffic-management-act-2004-no-original-pcn/
Title: Re: Bromley council. Charge Certif. PCN code 27, parked on Albemarle road blocked with flower pot.no sig
Post by: Incandescent on December 02, 2024, 10:32:14 pm
+1
The council are being their usual obdurate selves, so if you want to fight this, or at least get to a position of only paying the discounted amount, (£55), you have to now ignore their letter of 19th November, and wait for them to register the debt at the Traffic Enforcement Centre. This adds £10 to the CC amount, and they then send you an Order for Recovery.  Accompanying the OfR, will be a form to submit a Witness Statement. You then fill this form in, and send it off to TEC. TEC then cancel the CC and OfR and the process reverts back to the NtO stage. You can then pay or submit representations.  This palaver is totally routine nowadays, so nothing to fear. It is this, or pay the £110 they are demanding.

The PCN would have been served by a CEO to your car, as it is for a parking contravention under the Traffic Management Act 2004. If they get no response to it, they then send a Notice to Owner to the name and address on the V5 Registration Certificate for the car. Presumably this is yourself ?  As Stamfordman asks, is the name and address on the CC correct and identical to the name and address on your V5 ?
Title: Re: Bromley council. Charge Certif. PCN code 27, parked on Albemarle road blocked with flower pot.no sig
Post by: stamfordman on December 02, 2024, 08:58:10 pm
As you don't get the NTO you can wait for the order for recovery and make a witness statement that you didn't get it, which will automatically result in them reissuing the NTO to which you can make reps and you should at least get out of it owing only £55.

Are the name and address on the charge certificate correct?
Title: Bromley council. Charge Certif. PCN code 27, parked on Albemarle road blocked with flower pot.no sig
Post by: Justicenow on December 02, 2024, 07:26:27 pm
@cp8759
Hello, please can you advise kindly? I received a charge certificate from Bromley council for parking on Albemarle road, Beckenham in a part that is blocked with two flower pots,Google map location 51.40762° N, 0.00383° W. https://goo.gl/maps/b9uM5abfgGHuWSr66 Dropped pin. There are no signs or parking restrictions there. I didn’t get a PCN on my car on the day, nor a Notice to Owner through the post. The first communication about it was the charge certificate for £165 after the appeal time has passed. The supporting evidence PCN details on council website shows 2 photos of my car parked but no clear detail (block boxes not visible)and no PCN yellow ticket on the windscreen. After receiving the Charge Cert., I contacted the council through the online form and explained that I have never received no PCN nor Notice to Owner. They responded with a letter in post that I can’t appeal at this stage and have to pay, however they reduced the amount to £110 removing the charge cert surcharge (£55). The letter says I have 14 days to pay or else. I responded again to say there was no PCN, they once again sent me the same letter. I feel this is extremely unfair, first because there was no contravention, second - I have not received any comms about it before the charge certificate arrived. All the letters and photo evidence is
https://ibb.co/f9hbd77
https://ibb.co/t89FgXj
https://ibb.co/JksXfrQ
https://ibb.co/SvHrF72
https://ibb.co/5vnyqtD
https://ibb.co/rfhhqxy
https://ibb.co/BP4qJdK

Please can you advise what could I possibly do at this stage?
Thank you for your help.