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Live cases legal advice => Civil penalty charge notices (Councils, TFL and so on) => Topic started by: hirerspcn on October 05, 2023, 05:36:35 am

Title: Re: City of Westminister - Code 01 Parked in a restricted street
Post by: cp8759 on July 09, 2024, 10:33:08 pm
Outcome (https://drive.google.com/file/d/1lNGEMZQLOQj1fB8TcYVMjc6APCJcA8Fy/view).
Title: Re: City of Westminister - Code 01 Parked in a restricted street
Post by: cp8759 on April 07, 2024, 01:24:12 pm
Well the obvious next step is to appeal on the ground that you are not the owner of the vehicle, on a properly argued appeal this is basically bound to succeed.

I will drop you a PM in case you'd like to instruct me as your representative.
Title: Re: City of Westminister - Code 01 Parked in a restricted street
Post by: hirerspcn on April 07, 2024, 12:56:49 pm
My notice of Rejection arrived, whats my next step. I have uploaded the letter below.



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Title: Re: City of Westminister - Code 01 Parked in a restricted street
Post by: cp8759 on February 18, 2024, 11:11:37 pm
Thank you for your response. I will send off my appeal.
No you won't, at this stage it's just a representation. The appeal comes at the tribunal stage.

Edit: Can I write that from the images, the driver (me) is in the vehicle. To support that I was temporarily stopped and not parked?

Edit2: Could I also include my Private Hire license to show that I am a private hire driver and had no reason to park, only to temporarily stop to pickup passengers?
You can add that but my advice would be not to: your temporary stop amounted to waiting within the meaning of the legislation, on this point see the case of City of Bradford Metropolitan District Council v Obaid [2001] EWHC 536 (Admin) (https://www.bailii.org/ew/cases/EWHC/Admin/2001/536.html). TLDR: you were in the wrong and the civil enforcement officer was entitled to issue a penalty charge (but that doesn't change the fact that we can get the PCN cancelled on appeal to the tribunal).
Title: Re: City of Westminister - Code 01 Parked in a restricted street
Post by: hirerspcn on February 13, 2024, 02:12:57 am
Thank you for your response. I will send off my appeal.

Edit: Can I write that from the images, the driver (me) is in the vehicle. To support that I was temporarily stopped and not parked?

Edit2: Could I also include my Private Hire license to show that I am a private hire driver and had no reason to park, only to temporarily stop to pickup passengers?
Title: Re: City of Westminister - Code 01 Parked in a restricted street
Post by: cp8759 on February 12, 2024, 11:54:00 pm
Well we have to go through the motions to get to the tribunal, this will do for now:

Dear City of Westminster,

My vehicle was temporarily stopped but was not parked, please would you cancel the PCN.

Yours faithfully,

Let us know when you get the rejection and we'll explain the next steps. Make the representation online at https://appeals.westminster.gov.uk/ and keep a screenshot of the confirmation page.
Title: Re: City of Westminister - Code 01 Parked in a restricted street
Post by: hirerspcn on February 11, 2024, 01:59:17 am
Please may i get some advice on this case.

Many Thanks
Title: Re: City of Westminister - Code 01 Parked in a restricted street
Post by: hirerspcn on February 07, 2024, 02:54:57 am
Nearly after 3 months I have received the NTO. The hire company transferred liability to me and I have finally received the letter in my name.

I have to note that I did NOT receive a PCN or a reminder letter from when my hire company transferred liability to me. This is the first letter (NTO) I have received from City of Westminster for this PCN.


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Title: Re: City of Westminister - Code 01 Parked in a restricted street
Post by: cp8759 on October 16, 2023, 11:50:44 pm
If my use is very restricted then I will return the vehicle and hire from another company.
Well that's not really a matter for this thread, the significant limitation I can see is that you cannot use the vehicle for personal use, so for example you can't use it to go and meet friends in the evening, or to go and buy your weekly shop or anything else like that. You can only use it for work and only for private hire work, so if you're not happy with that, then it would seem sensible to hire from another company.

If my PCN is in regards to my work, why is the T&Cs required?
Because we can use the T&Cs to prove to the tribunal that the council was not entitled to transfer liability to you.
Title: Re: City of Westminister - Code 01 Parked in a restricted street
Post by: H C Andersen on October 15, 2023, 08:46:54 am

But very extra-procedural for the authority to consider an application by someone who was not the registered keeper to be the keeper and ultimately be granted the right to appeal. The NTO must by law be issued to the RK who may rebut the presumption of being the keeper.

But it's the RK's decision alone, not the driver's, hirer's or the authority's.
Title: Re: City of Westminister - Code 01 Parked in a restricted street
Post by: hirerspcn on October 15, 2023, 05:50:09 am


These cases give you a good idea of what I mean by permanent disposition:
Rosica Solunova v City of London (2210125386, 12 April 2021) (https://drive.google.com/uc?id=19AI8MLWE-3XQCr3oZYyl7WLdsW9jGSpg)
Daniel Hirai v City of Westminster (2210105607, 26 June 2021) (https://drive.google.com/uc?id=1ccZWR_fafQ-QlR3JbF-1dOnBDwZzXPo6)
Harold Goodrich v City of Westminster (2220668661, 14 August 2023) (https://drive.google.com/uc?id=1kuCsSSwWJGzgs82ld7wEkPOuKa9IM-vS)

There is a good example in Abu Zubae v London Borough of Hackney (2210338842, 19 August 2021) (https://drive.google.com/uc?id=126prs3k8DvF8cI4D2-MSbmyVLEoI4uxE) where the chief adjudicator found that the terms of the agreement were incompatible with a permanent disposition, so liability could not be transferred.

Just in case you're wondering, if we go to the tribunal and win on this ground, the PCN just dies. The council will not issue a new notice to owner to the lease company after losing the appeal.

Normally leasing companies will refund the admin charge if you show them that the PCN has been cancelled but even if they refused, you're better off paying £10 to the leasing company than £65 to the council. I will be happy to represent you at the tribunal.

As a precaution it's always worth telling the leasing company about the notice to owner being on its way, telling them you want to fight the ticket and asking them to transfer liability. This is because some lease companies just pay the notice and try and re-charge you, and that is a scenario we really want to avoid.
[/quote]

I guess i never really digested the Terms even though I have read it. This is an eye opener. Thank you.

If my use is very restricted then I will return the vehicle and hire from another company.

If my PCN is in regards to my work, why is the T&Cs required?
Title: Re: City of Westminister - Code 01 Parked in a restricted street
Post by: cp8759 on October 14, 2023, 04:18:37 pm
Given the number of restrictive items in the agreement i cannot see how a degree of permanence is made out all the leaser can do is drive the car
And only for one a single very restrictive purpose i.e. London PCO work only. He can't drive for deliveroo / just eat, he can't use the vehicle for personal use, it's the most restrictive lease I think we've ever seen.

HCA adjudicator Walsh references the West Wallasey decision Harold Goodrich v City of Westminster (https://drive.google.com/uc?id=1kuCsSSwWJGzgs82ld7wEkPOuKa9IM-vS) and as you see it made no difference to the outcome.
Title: Re: City of Westminister - Code 01 Parked in a restricted street
Post by: Pastmybest on October 14, 2023, 01:44:00 pm
Given the number of restrictive items in the agreement i cannot see how a degree of permanence is made out all the leaser can do is drive the car
Title: Re: City of Westminister - Code 01 Parked in a restricted street
Post by: H C Andersen on October 14, 2023, 01:25:20 pm

What odd decisions, or have I misread them?

'I do not find that the registered keeper has rebutted the legal presumption...' and yet there's nothing in the decision which suggests that the RK's representations to the council, if any, were even considered, the adjudicator referred to the evidence of the hire agreement presented by the appellant and yet there's no reference to the adjudicator being satisfied that this would have been the totality/material substance of the grounds of appeal of the leasing company (the registered keeper), if any, to the council.  I cannot even see where the adjudicators refer to the grounds of the RK's appeal i.e. 'not the owner' or 'we are a vehicle-hire company' etc. The appellant made direct application to the council to treat him as being the owner!

Why the adjudicators didn't cite this decision which refers to 'the proper approach' taken by the Court of Appeal seems odd.

https://www.londontribunals.gov.uk/sites/default/files/keycases/Wallasey22-01.pdf

Title: Re: City of Westminister - Code 01 Parked in a restricted street
Post by: cp8759 on October 14, 2023, 11:39:18 am
I don't think the agreement allows liability to be transferred, as these terms are completely incompatible with a permanent disposition amounting to a change of keepership:

This term allows them to effectively terminate the agreement whenever they want and taking the vehicle back, by simply changing the T&Cs
(https://i.imgur.com/g3xNgFo.png)

This term allows them to take the vehicle back with immediate effect in certain circumstances:

(https://i.imgur.com/cuGE1vx.png)
(https://i.imgur.com/irkJqdX.png)

This term shows they are still going to be responsible for maintenance in-house, so they must routinely take possession of the vehicle:
(https://i.imgur.com/bntfDIL.png)


This term severely restricts your ability to have maintenance done on the vehicle at a garage of your choice, and it imposes severe restrictions on the use you may make of the vehicle (for example by prohibiting any personal use, you can't use the vehicle to go shopping or for a family day out):
(https://i.imgur.com/wRB4tkF.png)

This term confirms the lessor is responsible for the maintenance and roadworthiness of the vehicle:
(https://i.imgur.com/4KZCYrp.png)

This term is again incompatible with a permanent disposition:
(https://i.imgur.com/w4Wzp2g.png)

This term shows they don't understand how transfers of liability work:
(https://i.imgur.com/x25JvFt.png)

This term shows that a third party has very broad rights to access the vehicle as it sees fit:
(https://i.imgur.com/238nCtR.png)

These cases give you a good idea of what I mean by permanent disposition:
Rosica Solunova v City of London (2210125386, 12 April 2021) (https://drive.google.com/uc?id=19AI8MLWE-3XQCr3oZYyl7WLdsW9jGSpg)
Daniel Hirai v City of Westminster (2210105607, 26 June 2021) (https://drive.google.com/uc?id=1ccZWR_fafQ-QlR3JbF-1dOnBDwZzXPo6)
Harold Goodrich v City of Westminster (2220668661, 14 August 2023) (https://drive.google.com/uc?id=1kuCsSSwWJGzgs82ld7wEkPOuKa9IM-vS)

There is a good example in Abu Zubae v London Borough of Hackney (2210338842, 19 August 2021) (https://drive.google.com/uc?id=126prs3k8DvF8cI4D2-MSbmyVLEoI4uxE) where the chief adjudicator found that the terms of the agreement were incompatible with a permanent disposition, so liability could not be transferred.

Just in case you're wondering, if we go to the tribunal and win on this ground, the PCN just dies. The council will not issue a new notice to owner to the lease company after losing the appeal.

Normally leasing companies will refund the admin charge if you show them that the PCN has been cancelled but even if they refused, you're better off paying £10 to the leasing company than £65 to the council. I will be happy to represent you at the tribunal.

As a precaution it's always worth telling the leasing company about the notice to owner being on its way, telling them you want to fight the ticket and asking them to transfer liability. This is because some lease companies just pay the notice and try and re-charge you, and that is a scenario we really want to avoid.
Title: Re: City of Westminister - Code 01 Parked in a restricted street
Post by: hirerspcn on October 13, 2023, 03:54:29 am
Finally the website is back online :)

I've attached the T&Cs below

[attachment deleted by admin]
Title: Re: City of Westminister - Code 01 Parked in a restricted street
Post by: cp8759 on October 08, 2023, 11:33:55 pm
The agreement is over six months, so it's classed as a long-term lease rather than a short-term hire.

This being the case, we need to see the full terms and conditions, can you post those please?

I can't see any mention on the document you've posted about a £10 charge, but most hire companies refund such charges if you show that the PCN has been cancelled. The full terms and conditions of hire should help us clarify this.
Title: Re: City of Westminister - Code 01 Parked in a restricted street
Post by: hirerspcn on October 08, 2023, 06:51:22 pm
You might be able to pursue a technical defence, do you know what the hire company's policy is when it comes to PCNs?

Basically in order to pursue this, you need the hire company to challenge the notice to owner on the ground that the vehicle was on hire. The council will then cancel the hire company's notice to owner and issue another one directly to you.

Also, can you show us a copy of the hire agreement, and the hire terms and conditions?

When my hire company receives PCN, they will charge me £10 and transfer liability to me in my name and address.

Rental Agreement (https://i.ibb.co/n0VG2Yp/Rental-Agr-Latest-Redac-Img.png)
Title: Re: City of Westminister - Code 01 Parked in a restricted street
Post by: hirerspcn on October 08, 2023, 06:49:16 pm
Quote
Another question: If I had to pickup a passenger at a DYL, does that mean if the passenger is not at the DYL that I am not allowed to wait there?
Single or double-yellow lines is the same, exceot that single-yellows only apply for certain time periods and certain days. 
In theory, no, you cannot wait for a passenger to turn up at the roadside, but waiting for a short time and having proof of the booling would be powerful evidence to refute a PCN.

Consider a customer ordering your taxi for 10.00 am.  If you turn up at 09.50 and wait,  you are on dodgy ground, whereas turning up at 09.57 would normally be considered OK. Of course you don't want to be late, so sometimes you have to just tootle around if the customer is not there when you arrive.

Well that would be impossible for me and other private hire drivers. I, like many other receive jobs on demand, so when a passenger requests a private cab we go to the pickup location and we may have to wait.

Sometimes the passenger is ready at the pickup, sometimes we will have to wait 2-4 minutes until the passenger is ready.

If this is the case then all other cab drivers (i’m guessing also black cab drivers) are all liable for PCNs. Making our job harder to do and nearly impossible.
Title: Re: City of Westminister - Code 01 Parked in a restricted street
Post by: cp8759 on October 06, 2023, 12:24:10 am
You might be able to pursue a technical defence, do you know what the hire company's policy is when it comes to PCNs?

Basically in order to pursue this, you need the hire company to challenge the notice to owner on the ground that the vehicle was on hire. The council will then cancel the hire company's notice to owner and issue another one directly to you.

Also, can you show us a copy of the hire agreement, and the hire terms and conditions?
Title: Re: City of Westminister - Code 01 Parked in a restricted street
Post by: Incandescent on October 06, 2023, 12:18:03 am
Quote
Another question: If I had to pickup a passenger at a DYL, does that mean if the passenger is not at the DYL that I am not allowed to wait there?
Single or double-yellow lines is the same, exceot that single-yellows only apply for certain time periods and certain days. 
In theory, no, you cannot wait for a passenger to turn up at the roadside, but waiting for a short time and having proof of the booling would be powerful evidence to refute a PCN.

Consider a customer ordering your taxi for 10.00 am.  If you turn up at 09.50 and wait,  you are on dodgy ground, whereas turning up at 09.57 would normally be considered OK. Of course you don't want to be late, so sometimes you have to just tootle around if the customer is not there when you arrive.
Title: Re: City of Westminister - Code 01 Parked in a restricted street
Post by: hirerspcn on October 05, 2023, 08:39:13 pm
Now that I learnt I wasn’t allowed to wait, even if I were to move after the passenger hadn’t showed up, there is a small chance that I would have to turn back around again and wait for another passenger.

Even though I am not 100% certain, there still was a chance.

On how I was served. I was given this PCN by hand.
—————
Another question: If I had to pickup a passenger at a DYL, does that mean if the passenger is not at the DYL that I am not allowed to wait there?
Title: Re: City of Westminister - Code 01 Parked in a restricted street
Post by: H C Andersen on October 05, 2023, 05:56:08 pm

If you have a pre-booked fare at this location then on your arrival you would be allowed a reasonable period to ascertain the fare's whereabouts, reasonable is not defined, but it does not allow you to wait because you had no expectation that the fare would arrive, you simply 'kept on waiting for another booking'.

Now for your account which doesn't make sense, I'm afraid:

I ask him who says and he says to me that he says so (CEO 6915). He tells me if i don't move that he will give me a ticket and i tell him fine and I go about my business.

So that's how I ended up with a PCN for allegedly 'parking'


Not really, unless you just stayed there (you refer to going 'about your business') and were issued with a PCN either by hand or put on the vehicle.

You need to be much clearer about how you came to be served with this type of PCN.
Title: Re: City of Westminister - Code 01 Parked in a restricted street
Post by: hirerspcn on October 05, 2023, 05:28:20 pm
Thanks for your advice, I learnt something then.

So am I better off paying this off or appealing?
Title: Re: City of Westminister - Code 01 Parked in a restricted street
Post by: Incandescent on October 05, 2023, 10:07:21 am
Yellow lines means "No Waiting" so the CEO was correct. There is an exemption for boarding or alighting passengers, so that would be your argument against the PCN, if the passenger had turned up, but carrying on waiting there for another booking to come through  is not exempt. 
Title: City of Westminister - Code 01 Parked in a restricted street
Post by: hirerspcn on October 05, 2023, 05:36:35 am
To start off, I am a Private hire driver and I am using a hire vehicle.

So tonight I am baffled, I was waiting for a passenger on dyl but they never showed up. I kept on waiting for another booking to come through, a CEO knocked on my window and made a gesture as if to tell me to move on. Not even 5 mins later his colleague (CEO 6915) comes through and knocks on my window again, he tells me that I'm not allowed to park here (dyl) and park on the left street. I tell him I'm not parked, then he goes to say that I am not allowed to wait here.

I ask him who says and he says to me that he says so (CEO 6915). He tells me if i don't move that he will give me a ticket and i tell him fine and I go about my business.

So that's how I ended up with a PCN for allegedly 'parking'.

The PCN in question: https://i.ibb.co/Nj7M37d/IMG-3163-Edited.jpg
You can very clearly see me inside the vehicle

The location in question: https://maps.app.goo.gl/fqmpv473pZFS3DtKA
I was waiting on the left opposite the KFC

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