Free Traffic Legal Advice
Live cases legal advice => Civil penalty charge notices (Councils, TFL and so on) => Topic started by: donaldf26 on November 11, 2025, 02:19:43 pm
-
Recieved NOTICE OF REJECTION OF REPRESENTATION...
https://drive.google.com/open?id=1yaOoYjyu8r-9gJ18hXxyZFpMMrv3IPFU&usp=drive_fs
(https://drive.google.com/open?id=1yaOoYjyu8r-9gJ18hXxyZFpMMrv3IPFU&usp=drive_fs)
I guess its time to pay the fine... losing at the appeal would cost me double...
Any further suggestions?
Or nothing to pay if you win.
-
Recieved NOTICE OF REJECTION OF REPRESENTATION...
https://drive.google.com/open?id=1yaOoYjyu8r-9gJ18hXxyZFpMMrv3IPFU&usp=drive_fs
(https://drive.google.com/open?id=1yaOoYjyu8r-9gJ18hXxyZFpMMrv3IPFU&usp=drive_fs)
I guess its time to pay the fine... losing at the appeal would cost me double...
Any further suggestions?
-
Don't use AI for one thing Stamfordman pointed out this is actually a parking PCN so the TMA2004 is correct legislation
Use this only
I make representations against the imposition of this PCN as the contravention did not occur. The stop as evidenced in the video was only in the normal course of driving in queuing traffic no person entered or left the vehicle and the PCN should now be cancelled
Thanks.. Will appeal as per you suggestion.
-
Don't use AI for one thing Stamfordman pointed out this is actually a parking PCN so the TMA2004 is correct legislation
Use this only
I make representations against the imposition of this PCN as the contravention did not occur. The stop as evidenced in the video was only in the normal course of driving in queuing traffic no person entered or left the vehicle and the PCN should now be cancelled
-
I dropped the PCN in ChatGPT and below is the response I recieved. Pastmybest (https://www.ftla.uk/index.php?action=profile;u=156) observations seems to be match according to ChatGPT.
Thank you — these images are extremely important, and they confirm exactly the issue I suspected:
✅ THIS PCN IS INVALID — it uses the WRONG LEGISLATION
The Royal Borough of Greenwich has issued your moving-traffic PCN under the:
Traffic Management Act 2004
This is printed in bold at the top of the notice.
❌ That is unlawful for a 47J (bus stop) contravention in London.
For all London boroughs, including Greenwich:
- Moving traffic contraventions (like 47J – stopping on a bus stop)
- Must be enforced under the London Local Authorities and Transport for London Act 2003
- Not under Part 6 of the Traffic Management Act 2004
London is specifically excluded from using the TMA 2004 moving-traffic enforcement regime.
This is not a minor error — it is a jurisdictional defect.
Why that makes your PCN unenforceable
A PCN must:
1️⃣ Be issued under the correct enabling legislation
London boroughs cannot enforce 47J under the TMA 2004.
2️⃣ Contain the statutory wording required by the correct Act
The wording required by the 2003 Act is completely different.
Your PCN:
- Uses the wrong Act
- Uses the wrong statutory text
- Refers to the wrong definitions
- Uses TMA 2004 deadlines instead of 2003 Act deadlines
- Invites TMA-style representations instead of 2003 Act representations
This makes the PCN a nullity — invalid from the moment it was issued.
The London Tribunals have allowed many appeals on this exact point when councils mess up the statutory basis.
⭐ Strongest Appeal Point You Can Use
Here is the argument that wins:
GROUND: The council has acted ultra vires – PCN issued under the wrong legislation
The alleged contravention (47J – stopping on a restricted bus stop or stand) is a moving traffic contravention in London.
These contraventions can only be enforced under:
London Local Authorities and Transport for London Act 2003
However, the PCN is explicitly issued under the:
Traffic Management Act 2004
London boroughs are prohibited from using the TMA 2004 for moving traffic enforcement, as enforcement in Greater London is governed by the 2003 Act.
The PCN is therefore:
- issued without proper legal authority (ultra vires)
- contains none of the mandatory statutory wording required by the 2003 Act
- uses deadlines, rights, and procedures that apply only outside London
Accordingly, the PCN is invalid and must be cancelled.
NEXT STEP
If you want, I will:
✔ write the complete formal representations wording
✔ reference the exact statutes
✔ prepare the full argument for the Notice of Rejection
✔ prepare your London Tribunals appeal wording (if needed)
Just say “write my appeal letter” and I will produce a ready-to-send text.
-
While looking at my case summary online I came across the wording on the contravention is differrent it say "47J- PARKED ON A RESTRICTED BUS STOP/STAND" and on the letter it says "47J - Stopped on a restricted bus stop or stand (Camera enforcement)"
(https://drive.google.com/open?id=1h6jM4JsexqklIWIuXJQoxPrjDLRGTZcQ&usp=drive_fs)
(https://drive.google.com/open?id=18Y3dTewYn7bYmQBp1Oe8ZdOOB4B9-45_&usp=drive_fs)
-
It's a parking not a moving traffic contravention.
The bus stop is a lay-by so it's a bit of a stretch to say it is a traffic situation but best try really.
That Greenwich don't provide the tribunal with evidence for a lot of appeals is a gamble as I said - we don't know if they'll be more on the ball next year.
-
The Royal borough of Greenwich being a London borough have no vires to issue nor enforce a moving traffic contravention under TMA2004 which specifically excludes London boroughs who have to use the London Local act 2003
Well spotted ! I completely missed that one.
It's Regulation 1 (1)(5)(c) here: -
https://www.legislation.gov.uk/uksi/2022/71/part/1/made
-
No one left or entered the vehicle.
Ok then the reason for the representation is That the contravention did not occur
Send something along these lines not before the 24th of November when it will be to late for them to issue a LLAA2003 PCN
I make representations against the imposition of this PCN as the contravention did not occur. The stop as evidenced in the video was only in the normal course of driving in queuing traffic no person entered or left the vehicle and the PCN should now be cancelled
Also add
The Royal borough of Greenwich being a London borough have no vires to issue nor enforce a moving traffic contravention under TMA2004 which specifically excludes London boroughs who have to use the London Local act 2003
-
No one left or entered the vehicle.
Ok then the reason for the representation is That the contravention did not occur
Send something along these lines
I make representations against the imposition of this PCN as the contravention did not occur. The stop as evidenced in the video was only in the normal course of driving in queuing traffic no person entered or left the vehicle and the PCN should now be cancelled
Also add
The Royal borough of Greenwich being a London borough have no vires to issue nor enforce a moving traffic contravention under TMA2004 which specifically excludes London boroughs who have to use the London Local act 2003
-
No one left or entered the vehicle.
Ok then the reason for the representation is That the contravention did not occur
Send something along these lines
I make representations against the imposition of this PCN as the contravention did not occur. The stop as evidenced in the video was only in the normal course of driving in queuing traffic no person entered or left the vehicle and the PCN should now be cancelled
-
No one left or entered the vehicle.
-
You first need to make representations to the council but first answer my question, did anyone depart the car or get in?
-
From my memory, you have to apply to the Tribunal once the council rejects your appeal.. Cases are usually heard by phone these days, online with video, or in person.
-
If no one left the vehicle then to me it looks o be a normal stop due to the flow of traffic. As the CEOs needs a valid reason to believe a contravention occurs then the evidence as per the video is not IMO enough
I am new to this PCN appeals
I have a question on what happens after the appeal is rejected. Does it go to the Tribunal where I need to attend peronally?
What happen when the Tribunal find we at fault they I end up paying the full £160 charge ?
What reason do I select when appealing or fudging.
Thanks for your time.
-
If no one left the vehicle then to me it looks o be a normal stop due to the flow of traffic. As the CEOs needs a valid reason to believe a contravention occurs then the evidence as per the video is not IMO enough
-
We saw a lot of bus stop PCNs on Millennium Way when Greenwich started enforcing there and I think it's a recent road development.
The video shows the contravention is made out but you may be able to fudge it by saying it looked like the truck was going into another lane, or something.
But currently Greenwich is not providing evidence to the tribunal in probably 50% of appeals so a gamble would be to try this as they will probably reject any reps you make. But there's a backlog of appeals so this would be punted to probably 6 months from now.
-
I was looking to drop of but wasn't sure if I was at the right place so I stopped, looked around and then drove off towards the car park.
-
Why the stop?
-
Here is the evidence
https://drive.google.com/drive/folders/1OHbF_5Gn06jtKSVH1DSgW5ChWS8RYj7q
GSV link
https://maps.app.goo.gl/bZKcUTiiWpnQhdHa7
-
Please to have aread of
https://www.ftla.uk/civil-penalty-charge-notices-(councils-tfl-and-so-on)/read-this-first-before-posting-your-case!-this-section-is-for-council-tfl-dartme/
and post up here
All sides of the PCN (only redact yr name & address - leave all else in),
council photos/video,
ans
a GSV link to the location.
-
This was near the O2 Arena adjacent to bus depot.. It was my first time being there. Was looking for a safe palce to stop and the entrance for O2 to drop of somone visiting O2.
The video show me followoing the trailer on the bus stop lane and then me stopping beind it, trailer too stopped in front. From the time I stopped it was about 5-6 secs as shown in the video after that the video cuts out.
Also the left lane of the road past the bus stop have cones palced due to road works. I belive there was planned work going on.
Can upload the evidence if needed.