Free Traffic Legal Advice
Live cases legal advice => Civil penalty charge notices (Councils, TFL and so on) => Topic started by: TMOCONTRACTLAW on October 10, 2025, 12:46:36 pm
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I have a tribunal date in June 2026.
Would it be advisable to upload the Council's Enforcement Protocol (https://www.camden.gov.uk/documents/d/guest/enforcementprotocol0925view), which states that contravention code 30 only applies in parking bays and not yellow lines (on page 15)?
The reason I wanted to upload it, just in case an adjudicator doesn't understand how that contravention code can't apply on yellow lines.
As recently, I read a tribunal decision and the adjudicator noted 'The decisions of this Tribunal do not establish precedent and an Adjudicator is not bound by a decision in a previous case. I am not persuaded the decision relied upon is one to be followed.'
Therefore, I wanted to cover all the bases in case they do not look at or agree with the referenced case I used for the formal reps.
Though there is some time away, do let me know your thoughts.
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I've put the ETA appeal in and got a case ref no.
I've submitted the following:
Ground(s)for appeal:
-The contravention did not occur
-EA Procedural Impropriety
Reason for appeal: Contravention did not occur and there was a Procedural Impropriety.
Attending hearing: Yes
I take it the reason for appeal can be edited at a later date once the tribunal date is set?
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I plan to put the ETA Appeal in the next few days. The NOR was issued on 02 Dec 2025.
I just wanted to confirm the following steps:
1) I tick contravention did not occur and procedural impropriety
2) Do I need to write why I believe the above two points are relevant? If so, what should I write in particular?
3) The hearing should either be telephone or online, NOT on paper
4) Do I need to screenshot the process?
If there is anything else that I need to do, pl let me know.
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The case I posted earlier today is a full register record although I blanked the appellant's name.
London Tribunals is open to the public and you can actually still observe cases I think although most are now done online or on the papers.
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Correct.
Just look at any case on the register: https://londontribunals.org.uk/ords/pwslive/f?p=14952:70::INITIALISE::70:P70_CAS_REFNO,P70_PCN_REFNO,P70_RETURN_PAGE,P70_AST_CODE:1699047,3107858,60,APPEAL&cs=30ihADQLg9qdMEupImCELcaVqnIFm1Y3JVgvp6Il3PR3eYEb5Go6RWn7_SMIIJYTm3AXLc172qpj0P_O5w8hCXQ
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Another +1 here
there's a chance you'd get Mr Stanton-Dunne as the adjudicator, which would be immensely entertaining.
I hope Mr Stanton-Dunne is on duty as it will be interesting indeed. Whoever it is, I just hope they understand why I believe the contravention didn't take place.
I've made a note for next week to come back and put the appeal in for the ETA.
In the meantime I wanted to know the following:
1) I take it the following information will be public indefinitely: my name, VRM, Contravention Location, Details of the case and outcome
2) the following wouldn't be publicised: Mobile No, Email and vehicle keeper address
Pl, do let me know and I plan to put the appeal in next week (will come back to the forum for assistance).
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Yes it would be good if Mr Stanton-Dunne is on duty.
Earlier I posted a case where this contravention was upheld by adjudicator Natalie Goffe.
Here's another, by Michael Burke, who seems to have had an alarm bell ringing but turned it off.
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Case reference 2250155189
Appellant xxxxxx
Authority London Borough of Barnet
VRM LP72UYO
PCN Details
PCN AG47484147
Contravention date 26 Dec 2024
Contravention time 09:26:00
Contravention location Beverley Gardens
Penalty amount GBP 80.00
Contravention Parked for longer than permitted
Referral date -
Decision Date 25 Jul 2025
Adjudicator Michael Burke
Appeal decision Appeal refused
Direction Full penalty charge notice amount stated to be paid within 28 days.
Reasons The allegation in this case is that the vehicle had been parked for longer than permitted at 9.26am on 26.12.24. The Appellant disputes this. She says the Civil Enforcement Officer told her the PCN was issued because the Blue Badge displayed had expired. She says that it should be obvious she did not arrive at 4.00 as shops would not have been open at that time.
A vehicle may be parked in a restricted street during prescribed hours for up to 3 hours providing there is clearly displayed a valid Blue Badge together with the time clock set at the time of arrival.
The Enforcement Authority have provided photographs taken by the Civil Enforcement Officer which confirm that the time clock displayed with the Blue Badge was set at 4.00. The vehicle was parked on a double yellow line. As the Highway Code makes clear, the double yellow line indicates ‘No waiting at any time’. It does not require an adjacent time plate.
The better course in these circumstances would be to issue the PCN for contravention code 01, being parked in a restricted street during prescribed hours. However, it is also true to say that the vehicle was parked for longer than permitted as, unless an exemption applies, any time parked on a double yellow line is longer than permitted.
I have no reason to doubt that the Appellant made a genuine error but this amount only to mitigation. The Enforcement Authority may cancel a PCN as a matter of their discretion but Adjudicators have no power to direct cancellation on the basis of mitigating circumstances.
Having considered all the evidence I am satisfied that the contravention occurred and that the PCN was properly issued and served. I am not satisfied that any exemption applies.
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Another +1 here
Not just because you'll probably win but also because there's a chance you'd get Mr Stanton-Dunne as the adjudicator, which would be immensely entertaining.
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+1.
I would go for:
Contravention did not occur
Procedural impropriety.
We'll expand later, but at present all you've got to do is register.
IMO, it is a PI because the authority failed to consider your reps. The law requires a cogent and reasoned response. Whatever they moght think of the Stanton-Dunne decision, their statement that ..this has no bearing on the matter in hand' is flippant at best and a dereliction of their duty and PI at worst.
As for '..therefore no exemption can be applied in this instance', this is a non sequitur of enormous proportions.
Bring it on!
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You should register the appeal with the tribunal and opt for an online or phone hearing.
There's no discount on offer so this is a no brainer.
They will probably attend to argue that this is a legitimate alleged contravention but why is beyond me as there is the perfectly legal code 01 higher level to apply.
It's true there are adjudicators who have ruled that code 30 does apply but they are wrong and the appellants in those cases had no knowledge of what really applies.
(https://i.ibb.co/hJPTSsHV/Notice-of-Rejection-Redacted.jpg)
(https://i.ibb.co/n8qKYncV/Notice-of-Rejection-Redacted-2.jpg)
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Unfortunately, my formal reps have been rejected.
Notice of Rejection (Redacted) (https://drive.google.com/file/d/1Scf8SKgAkszReL3QqTdNTz3D6_3cD9mT/view?usp=drive_link)
They've also included the 4 page 'TMA - Your right to a appeal' document.
I understand that if I were to take this to ETA, not all adjudicators will understand as to why I believe that no contravention occurred?
Also, is the Council not acting in a 'wholly unreasonable manner' in trying to chase this PCN. As, there was already an adjudicator case where the PCN was cancelled and in Camden owns Parking Protocol Document, the alleged contravention can only take place in a bay rather than SYL.
Pl, do let me know what you think in the meantime.
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Just the PCN is fine.
I would include the case number up-front and say London Tribunals:
... rely upon the decision of adjudicator Stanton-Dunne at London Tribunals when allowing an appeal for case no. 2240520470 on 18 February 2025 ...
Thank you. Below is my final draft, I'll submit the following reps:
Dear Camden Parking Ops Team,
PCN **********
I refer to the above and NTO issued on 11 November 2025. I hereby make formal representations on the following grounds:
Contravention did not occur.
Rather than rehearse my informal representation in everyday motorists' terms, I shall instead reproduce verbatim and rely upon the decision of adjudicator Stanton-Dunne at London Tribunals when allowing an appeal for case no. 2240520470 on 18 February 2025 on identical grounds, coincidentally against Camden which was actually represented at the hearing.
“This PCN was issued for the alleged contravention of “being parked for longer than permitted blue (badge holder).”
The CEO’s images show that Mr Searle’s car was parked on a single yellow line displaying a blue badge with the clock set at 8.30am so that the three hour blue badge parking exemption had ended. The Council’s evidence is that Fordwych Road is part of a CPZ with controlled hours of 8.30am to 6.30pm Mondays to Fridays.
There is no contravention of a blue badge holder being parked for longer than permitted. The contravention of being parked for longer than permitted occurs when a vehicle is parked in a parking place where there is a permitted period of parking which is exceeded. Mr Searle’s car was not parked in a parking place where there was a permitted period of parking. It was parked in a restricted street during prescribed hours where there is an exemption for blue badge holders to park with the display of a clock. When the vehicle became parked beyond the period of the exemption, a PCN could have been issued for being parked in a restricted street but it was not. The PCN was issued for the wrong contravention, indeed a contravention which does not exist.”
I don't think I could add to his reasoning and therefore I am content to let his words form my representations.
The PCN must be cancelled.
Yours faithfully,
TMO CONTRACT LAW
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Just the PCN is fine.
I would include the case number up-front and say London Tribunals:
... rely upon the decision of adjudicator Stanton-Dunne at London Tribunals when allowing an appeal for case no. 2240520470 on 18 February 2025 ...
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The PCN must be cancelled.
Do I need to edit the above and say "The PCN and NTO must be cancelled"?
If not, pl let me know as I plan to submit the formal reps today.
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Updated draft to be used for formal reps:
Dear Camden Parking Ops Team,
PCN **********
I refer to the above and NTO issued on 11 November 2025. I hereby make formal representations on the following grounds:
Contravention did not occur.
Rather than rehearse my informal representation in everyday motorists' terms, I shall instead reproduce verbatim and rely upon the decision of Adjudicator Stanton-Dunne of the Environment and Traffic Adjudicators when allowing an appeal on 18 February 2025 on identical grounds, coincidentally against Camden which was actually represented at the hearing.
“This PCN was issued for the alleged contravention of “being parked for longer than permitted blue (badge holder).”
The CEO’s images show that Mr Searle’s car was parked on a single yellow line displaying a blue badge with the clock set at 8.30am so that the three hour blue badge parking exemption had ended. The Council’s evidence is that Fordwych Road is part of a CPZ with controlled hours of 8.30am to 6.30pm Mondays to Fridays.
There is no contravention of a blue badge holder being parked for longer than permitted. The contravention of being parked for longer than permitted occurs when a vehicle is parked in a parking place where there is a permitted period of parking which is exceeded. Mr Searle’s car was not parked in a parking place where there was a permitted period of parking. It was parked in a restricted street during prescribed hours where there is an exemption for blue badge holders to park with the display of a clock. When the vehicle became parked beyond the period of the exemption, a PCN could have been issued for being parked in a restricted street but it was not. The PCN was issued for the wrong contravention, indeed a contravention which does not exist.”
I don't think I could add to his reasoning and therefore I am content to let his words form my representations. I have attached the ETA Case No. should you wish to verify the above - 2240520470 .
The PCN must be cancelled.
Yours faithfully,
TMOCONTRACTLAW
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I feel the above would be good in the sense that no files need to be attached and no issues regarding the formatting of the referenced case. Just hope there's no character limit. Do let me know if any adjustments should be made.
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It's not further to their rejection of informal reps, that's past.
To flesh out a bit, I would suggest perhaps:
Dear Sir,
PCN **********
I refer to the above and NTO issued on ******. I hereby make formal representations on the following grounds:
Contravention did not occur.
Rather than rehearse my informal reps in everyday motorists' terms, I shall instead reproduce verbatim and rely upon the decision of Adjudicator Stanton-Dunne of the Environment and Traffic Adjudicators when allowing an appeal on 18 February 2025 on identical grounds, coincidentally against your council which was actually represented at the hearing.
'This PCN ......not exist'.
I don't think I could add to his reasoning and therefore I am content to let his words form my representations. I have attached the ETA Case No. should you wish to verify the above - *************.
The PCN must be cancelled.
Yours,
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Does the form not allow for attachments? If it do, you can attach a pdf and so keep the formatting.
If the form does allow for attachments then I was thinking of the following draft (if it doesn't allow it, I will get back to you):
Further to your rejection of my informal challenge I have researched the alleged contravention and found that it does not exist in law.
The council must be aware that there is no contravention of a blue badge holder being parked for longer than permitted in any location, including on a yellow line.
In this case, the 3 hour exemption accorded to blue badge holders is for parking in a restricted street during prescribed hours; after 3 hours, the only contravention is being parked in a restricted street during prescribed hours (code 01).
The PCN was issued not only for the wrong contravention but one that does not exist.
I have summarised this from the decision in tribunal case 2240520470, which was in Camden, and which I reproduce in full below for your information as attached in the PDF file. (https://drive.google.com/file/d/1U2IASHz7sN3AiQHYcL6HnB4M1gQe8nm9/view?usp=drive_link)
The PCN must be cancelled and I look forward to your early confirmation of such.
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If anyone wants to make adjustments then pl let me know. I will try to submit the reps next week as to give time for responses.
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I added that the tribunal case was in Camden.
The important thing is not to just give a link but show them something, in this a case they ought to know.
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Does the form not allow for attachments? If it do, you can attach a pdf and so keep the formatting.
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I'll wait for others to respond.
Would it be ok to send a screenshot of the case summary instead of pasting it into the reps online form? As, it might not let me paste all of into the reply box and the formatting will look off.
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Needs to be a bit longer.
I would say the below but wait for others.There is no rush.
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Further to your rejection of my informal challenge I have researched the alleged contravention and found that it does not exist in law.
The council must be aware that there is no contravention of a blue badge holder being parked for longer than permitted in any location, including on a yellow line.
In this case, the 3 hour exemption accorded to blue badge holders is for parking in a restricted street during prescribed hours; after 3 hours, the only contravention is being parked in a restricted street during prescribed hours (code 01).
The PCN was issued not only for the wrong contravention but one that does not exist.
I have summarised this from the decision in tribunal case xxxxx, which was in Camden, and which I reproduce in full below for your information.
The PCN must be cancelled and I look forward to your early confirmation of such.
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I would wait for the NTO. Who is the registered keeper and are the logbook name and address correct.
I've received the NtO today which includes the representation letter/form. The notice is dated 11/11/25.
Should I submit formal reps indicating "The alleged contravention did not occur" and state the following:
I believe the contravention did not occur as I refer you to London Tribunals case 2240520470 which you attended and invite you to cancel the PCN/NtO.
Do let me know what you think and if I should include the case summary in the reps.
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The online status now states the "NtO/Enf. Notice Sent." I am just waiting for it to show up in the post.
In the meantime I wanted to draft up my formal reps.
Would I just send them what I emailed over and do I paste the appeal decision for their convenience?
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I'm the registered keeper and the details on the logbook is correct.
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I would wait for the NTO. Who is the registered keeper and are the logbook name and address correct.
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I sent the email a week ago and got no response. Received an automated reply, saying they do not deal with PCN over email.
I think the discount period ends on Thursday.
If I wait for NtO and put in a formal reps, would they reoffer the discount again?
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I was hoping it would be the same person as the adjudication.
I would add to the note:
'I copy below the appeal decision for your convenience' and paste the text.
Unless anyone comes up with any better ideas.
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The rejection letter was signed by: R Smith
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Which Camden officer signed the rejection letter?
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I assume the 3 hours and 2 mins comes from when the CEO first noted the car and then when the PCN was produced.
On the PCN the vehicle was observed from 09:46 to 12:48, where the 3 hours 2 mins comes from.
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Where does 3hrs 2mins come from? You parked sometime between 8.16 and 8.30. The PCN was issued over 4 hours later.
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Should I email the following to the parking ops team:
Dear Parking Operations Team,
In the light of your rejection to my informal challenge, I refer you to London Tribunals case 2240520470 which you attended and invite you to reconsider the rejection.
Kind Regards,
TMOCONTRACTLAW
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All looks in order, but not from their standpoint.
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It was outside of the Green Badge Zone.
I agree, it might be worthwhile emailing to ask them to reconsider as it will save both parties time.
A few of the (redacted) images taken by the CEO (https://drive.google.com/file/d/1jt8gLLU6F9xCGBlO9f_yg0h9ZHCa2Is-/view?usp=sharing)
GSV - Location of Contravention (https://maps.app.goo.gl/VDakPd2Rr411u1Sy7)
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They have 6 months to serve an NTO.
I'd be tempted though to write back to them now and just say in the light of your rejection to my informal challenge I refer you to London Tribunals case 2240520470 which you attended and invite you to reconsider the rejection.
Also, you blanked all the details on the PCN so all this depends on what you say as we can't check the evidence - you could at least post a couple of the council's pics and the location.
I presume you were outside the green zone.
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I am the registered keeper and the logbook address is correct, I have double checked this today.
At the moment, should I do nothing and wait for the 'Notice to Owner' to come through the post?
Is there a certain time frame the NtO should come by, just so I'm aware.
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You need to wait for the NTO - who is the registered keeper and is the logbook address correct.
When the time comes your reps can be much shorter and to the point - you don't need most of what you've done. The contravention simply did not occur as it doesn't exist as Mr Stanton-Dunne adjudicated.
Just to show though that some adjudicators don't know bottom from elbow, the below case was also for a yellow line (but in Redbridge). But don't be put off by this.
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Case reference 2250021692
Appellant Muhammad Iqbal Khokhar Begum
Authority London Borough of Redbridge
VRM KK19DYN
PCN Details
PCN AF08177945
Contravention date 30 Oct 2024
Contravention time 16:49:00
Contravention location Grange Road
Penalty amount GBP 80.00
Contravention Parked for longer than permitted
Referral date -
Decision Date 05 Apr 2025
Adjudicator Natalie Goffe
Appeal decision Appeal refused
Direction Full penalty charge notice amount stated to be paid within 28 days.
Reasons This is an appeal by the Appellant against a Penalty Charge Notice (PCN) issued by the Enforcement Authority (EA). The case was listed as a postal appeal.
The EA's case is that the vehicle was parked for longer than permitted.
The Appellant refers to medical factors. There is further information set out in the representations.
An Adjudicator decides appeals by making findings of fact on the basis of the evidence, and by applying the law.
Having considered the evidence, I find that the contravention occurred. The arrival time on the blue badge was set at 1:30pm, and the PCN was issued at 4:46pm. The vehicle was parked for longer than the permitted time of 3 hours.
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Thanks for that case, helps immensely as it is Camden Council.
I was planning on submitting the following formal reps:
I do not agree that the alleged contravention observed by the CEO took place.
I have explained in my informal challenge as to why the Blue Badge (BB) Holder has parked there. Unfortunately, this couldn’t be taken in to consideration. Though you are welcome to look at the informal challenge and reconsider the situation of the day.
The alleged contravention of ‘Parking for longer than permitted blue (badge holder)’ could not have taken place. As, the vehicle was parked on a single yellow line with the (substitute) blue badge and timer clock correctly displayed.
The alleged contravention can not take place on single yellow lines (SYL) as the BB Holder can not be parked longer than permitted on a SYL. The BB Holder is exempted rather than permitted, to park on a SYL for 3 hours during restricted controlled hours as long as the badge and associated timer clock is displayed correctly.
After the 3 hours are up, the exemption for the BB Holder SYL restriction ceases to apply and should be dealt with as having no exemption. As, outlined in Camden’s Enforcement Protocol Document*: ‘Parking Operations Enforcement Protocol, page.15, rev. 18/10/24.
Upon reading the enforcement protocol, you can see that the contravention code 30(o) can only take place in a designated parking bay rather than a SYL.
Clearly, the alleged contravention can only take place in a designated parking place rather than a yellow line. Such as, on this occasion. Where another contravention may have allegedly taken place on the SYL, this should have been noted by the CEO however, it wasn’t.
I await for you to can cancel the PCN.
*The referenced document is available at: https://www.camden.gov.uk/documents/d/guest/enforcementprotocol0925view
Pl, do let me know what you think and if any changes should be made
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This case was in Camden. There's often a pattern to certain councils misapplying certain parking regulations.
But I think I saw a case where the adjudicator wasn't as knowledgeable as this one.
Note that Camden attended this one so they should have accepted your challenge and now open themselves up to a cost claim if they persist.
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Case reference 2240520470
Appellant Ian Searle
Authority London Borough of Camden
VRM GF15TXT
PCN Details
PCN CU6794960A
Contravention date 02 Aug 2024
Contravention time 16:56:00
Contravention location Fordwych Road
Penalty amount GBP 80.00
Contravention Parked for longer than permitted
Referral date -
Decision Date 18 Feb 2025
Adjudicator Sean Stanton-Dunne
Appeal decision Appeal allowed
Direction cancel the Penalty Charge Notice and the Notice to Owner.
Reasons Mr Searle was scheduled for a hearing by video link today but he has not attended and so his appeal is being decided on the evidence presented. Ms Sabina Yasmin has attended by video link for the Council.
This PCN was issued for the alleged contravention of “being parked for longer than permitted blue (badge holder).”
The CEO’s images show that Mr Searle’s car was parked on a single yellow line displaying a blue badge with the clock set at 8.30am so that the three-hour blue badge parking exemption had ended. The Council’s evidence is that Fordwych Road is part of a CPZ with controlled hours of 8.30am to 6.30pm Mondays to Fridays.
There is no contravention of a blue badge holder being parked for longer than permitted. The contravention of being parked for longer than permitted occurs when a vehicle is parked in a parking place where there is a permitted period of parking which is exceeded. Mr Searle’s car was not parked in a parking place where there was a permitted period of parking. It was parked in a restricted street during prescribed hours where there is an exemption for blue badge holders to park with the display of a clock. When the vehicle became parked beyond the period of the exemption, a PCN could have been issued for being parked in a restricted street but it was not. The PCN was issued for the wrong contravention, indeed a contravention which does not exist.
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It's in Camden's enforcement protocol that the alleged contravention is a bay contravention and doesn't apply to SYL.
As, outlined in Camden’s Enforcement Protocol Document*: ‘Parking Operations Enforcement Protocol, page.15, rev. 18/10/24. (https://www.camden.gov.uk/documents/d/guest/enforcementprotocol0925view)
Unfortunately, it was a little over 2 mins. BB Timer Clock (https://drive.google.com/file/d/10N3ANyk0yijgD1c8dapy7_rlf-gYAIuW/view?usp=sharing)
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Just 2 mins over...
I think the wrong contravention can be won but some adjudicators don't know the law.
I think Camden should also be reminded of its duty to act fairly.
(https://i.ibb.co/TqgckCxt/Informal-Reps-Decison-Letter.jpg)
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Recently got a PCN for allegedly parking for more than 3 hours on a SYL with a Blue Badge (there wasn’t any ‘no loading’ blips). The BB holder was unwell and took a while to leave but when they did the PCN was spotted on the car.
The CEO noted the contravention code 30o – parking for longer than permitted (blue) badge holder.
Made informal reps outlining why the BB holder took a while to leave. Also, explained how the alleged contravention could not have taken place on SYL.
Explained the above to the council in the informal reps and hoped they would either apply their discretion understating the circumstance of the day or just admit the alleged contravention didn’t take place. Unfortunately, they did neither and rejected the informal reps.
I am the vehicle owner/keeper and the V5 is in the correct name and address.
PCN Timeline:
19/09/25 – PCN on Windscreen
29/09/25 – Informal Reps/Challenge Submitted Online
10/10/25 – Informal Reps Decision Letter Received via Email
PCN Redacted (https://drive.google.com/file/d/1X_dg2AfRuXbWbznc_xyMwFLUfrAjalqW/view?usp=sharing)
Informal Reps Decision Letter Redacted (https://drive.google.com/file/d/1vS3qPplugVH6i5_ue8lKAJU1LRJLnCO-/view?usp=drive_link)
Mods, please PM me for unredacted images or the Reg No.
Is it worth making a formal representation? Will post my draft for formal response shortly.
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Thanks for confirming.
I've recently received a PCN but they noted the contravention as 30o instead of 01. There wasn't any 'no loading' blips.
Put in an informal challenge explaining why the BB Holder was parked there and that the wrong contravention code was noted.
Unfortunately, they rejected the informal challenge. It might be worth taking it all the way to ETA.
Will post up all the details soon.
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It's code 01, assuming that there aren't any parallel loading restrictions.
Holding and displaying etc. a valid BB provides an exemption to the prevailing waiting restriction. When this exemption ceases to apply e.g. parked for longer than 3 hours, then the prevailing restriction applies.
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Dear FTLA,
I wanted to know what is the correct contravention code that should be issued to those who park on a single yellow line with a Blue Badge and park for over 3 hours?
Is it code 01 - Parked in a restricted street during prescribed hours
or
code 30o - Parking for longer than permitted, blue badge holder