Free Traffic Legal Advice
Live cases legal advice => Civil penalty charge notices (Councils, TFL and so on) => Topic started by: LondonTraveller84 on November 11, 2025, 09:25:53 pm
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Yes, usually put as "I rely on my formal representations". However, you can enhance them before the hearing, but your reps must be in by a certain date in advance of the hearing, as they need to be passed to the council.
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Hi All,
Have received the NTO finally, will look to fill in the adjudicator appeal process, any pointers on if I should be adding anythign different or additional or just state 'refer to previous appeal points'
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Looks like they fully ignored everything we said about the permit bay, and other points, see attached examples
https://ibb.co/PvxR1mb2
https://ibb.co/wNySPRC1
I assume wait for NTO and take to adjudication or better to pay the discounted rate based on their recent response above? Am a bit worried how well i would be able to argue the permit point if the adjudicator further questions it above and beyond what we've said..
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Submitted - Await their rejection :) - A miracile if they accept, but their track record says other wise
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Okay, I think I've now got it, hopefully I'll be able to hold my ground and argue that if it goes adjudication. I assume based on this my revised response above should suffice, as I've sort of covered that point.
Should I keep the oversight point (moved from 1 down to 2) or take it out as its not related to the PCN grounds?
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A permit only bay is.....a permit only bay!
This isn't.
End of....but give them the longer version!
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I've checked the difference between a code 16 and 12, if the issue is around the use of the code
16 - Contravention code 16 refers to parking in a permit-only space without a valid permit displayed. This applies to resident, visitor, or other types of permit bays, and the vehicle must either be clearly displaying a valid physical permit or have a valid virtual permit in place, where applicable
12 - Contravention code 12 is for parking in a residents' or shared-use parking place without a valid permit, voucher, or pay and display ticket where one is required. It can also apply if the paid time on a pay and display ticket has expired
Both sort of say the same thing no on the outset, while going deep I could do a lot of comparisons - 16 seems to be more focussed on permits, which includes visitor (I assume I fell into this) -
Is it that ground against the payment, cannot be for a permit rather has to be for a pay and display on a shared use bay which is only possible under code 12, ie code 16 does not cover payment tarriff permits for shared use bays, it only covers permit only?
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@H C Andersen, Please see reworded draft using yours as a template, while it was difficult to reword as i struggled to word it any other way) draft, as you'd covered it as best possible.
Contravention did not occur -
The ground used in the PCN is 'Parked in a permit space or zone without a valid virtual permit or clearly displaying a valid permit' alongside a contravention code '16s'.
Redbridge LA is aware suffix 's' is prescribed for use only for shared use bays, in this instance the LA photo evidence show a signage stating that you have to be a permit holder OR can park upon payment of the tariff i.e. a shared use bay.
Given that parking is therefore permitted on either one these two conditions, with one clearly being 'payment upon tarrif. then it cannot be the case that the contravention of 'Parked in a permit space or zone without a valid virtual permit or clearly displaying a valid permit' could apply in any circumstances to any motorist - This would only be applicable in the case of a permit only bay.
Therefore this PCN cannot be valid and I request this is cancelled immediatly.
In addition to the above a valid ticket was purchased for the full duration of my stay.... etc (I've dropped this down as advised unless you further advise to leave it out in its entirity for this informal rep)
If this will suffice for now, I can send this to get it in tonight before the deadline, which then gives time to focus on formal appeal once they've rejected it.
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I would also relegate the fact that you paid to a footnote
Noted, will do so..
I think I have struggled to understand the reason you were proposing to the LA, hence my draft going off point on the wrong understanding. Having re-read your recent explanation, my current understnading is that issue isn't with the bay or the it being shared or the 's' code, rather the grounds and/or code used?
I am struggling to get my head around the below, it may that i am not able to see the wood from the trees as they say or the contradications in their grounds used against the point you're making.
Therefore the authority cannot rationally assert that while its own evidence acknowledges the shared use nature of the parking place a contravention could have been committed based upon ONLY the fact that a permit was not displayed which means that the ONLY defence open to me in this regard would be to prove that I displayed the necessary permit.
1. I understand the bit around 's' and the bay being shared
2. I understand the two conditions you can park, ie have a permit, or pay for a virtual ticket (permit).
3. The only defence would be to prove I had a valid permit (or a paid session in our case) surely? what other defence is there, as a permit is required to park in that bay.
The latter part of their grounds states ".... without a valid virtual permit or clearly displaying a valid permit'., which I am unable to prove and had taken place as I did not have a virtual permit or a valid permit for that location?
** UPDATED ** @ 22:11 - Having re-read this a dozen times, is it that is is a shared use bay, so grounds should be not displaying a valid permit, as that only applies to a permit only bay? ie they are enforcing that this is the only ground I can appeal on, where as it should be code 12, which is for shared used bays and has pay and display ground?
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? It is NOT the wrong code just because it uses 's'. Your argument should accept that the 's' is correct, not claim it isn't.
I would also relegate the fact that you paid to a footnote because your actual argument is that even if you could prove you paid this is not a defence against the alleged contravention anyway!
OP, I would reword.
The contravention did not occur.
The evidence in this case is the PCN citing the grounds of '****' and giving code 16s. As the authority know, the suffix 's' is prescribed for use only for shared use bays. Indeed, the authority's own photos show a traffic sign which allows parking between the stated hours by either permit holders or on payment of the required tariff i.e. a shared use bay.
Given that parking is therefore permitted on display of a permit OR on payment of the tariff, then it cannot be the case that the contravention of '***' could apply in any circumstances to any motorist.
So:
The PCN acknowledges that the parking place was shared use by using the code suffix 's';
The authority's evidence shows a shared use traffic sign;
Therefore the authority cannot rationally assert that while its own evidence acknowledges the shared use nature of the parking place a contravention could have been committed based upon ONLY the fact that a permit was not displayed which means that the ONLY defence open to me in this regard would be to prove that I displayed the necessary permit.
Had the PCN used the correct grounds for this type of bay, that it to say 'failing to ******', then I would have made representations on the grounds that I actually paid and provided proof. But I do not need to deal with this as this is not the alleged contravention.
The contravention grounds and the CEO's actions cannot withstand scrutiny and therefore the PCN must be cancelled.
But you must draft as suits you.
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I would add to the first point
Updated the post above with the addition. A question does it make sense to go full in on the informal rep or just keep it very basic, as the formal rep after will basically have nothing more for us to add?
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It's an informal challenge at this stage.
I would add to the first point:
I remind you of the Department of Transport's Statutory guidance for local authorities in England on civil enforcement of parking contraventions, which state you "have a duty to act fairly and proportionately and are encouraged to exercise discretion sensibly and reasonably and with due regard to the public interest".
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So I've drafted up the appeal below, @stamfordman @H C Andersen await your advise and suggestions or amendments if any, before I submit tonight :)
Dear Redbridge LA,
I am writing to formally request the cancellation of the above PCN on the following grounds:
1. Genuine Oversight in Location Code Entry - A valid ticket was purchased for the full duration of my stay. The warden would have seen that a ticket had been purchased and that the location code entered was incorrect by only one digit. The code I used relates to York Road, which is only a few metres away and was shown in RingGo as the nearest location. The listed location was “Ilford Town, Redbridge,” which matches where I was parked, whereas the correct code refers to “Ilford Outer, Redbridge.” Given how similar these descriptions are, this was an easy and genuine mistake when using the RingGo app.
Furthermore, as the first hour of parking is free, this minor oversight resulted in no financial loss to the local authority. I had no intention of avoiding payment or failing to obtain a ticket—indeed, I went out of my way to ensure a ticket was obtained.
I remind you of the Department of Transport's Statutory guidance for local authorities in England on civil enforcement of parking contraventions, which state you "have a duty to act fairly and proportionately and are encouraged to exercise discretion sensibly and reasonably and with due regard to the public interest".
In light of this, I respectfully request that discretion be applied.
2.Incorrect Contravention Code - According to London Councils’ guidance for Contravention Code 16, the suffix “s” is only to be used where the bay is completely non-resident. For shared-use bays—where both residents’ permits and paid-for parking are valid—contravention codes 12 or 19 should be used instead.
The bay in which the vehicle was parked is a shared-use bay, allowing both resident permit holders and non-residents using a paid permit. Therefore, the contravention alleged on the PCN could not have occurred, as the code applied does not correspond to the type of bay involved.
Given that:
1. a valid ticket was purchased,
2. the mistake was an understandable, genuine oversight,
3. no financial loss occurred, and
4. the contravention code used was incorrect and therefore invalid,
I respectfully request that the PCN be cancelled.
Thank you for your time and consideration.
I deffinitly don't see the council applying any discretion or caring about point 1, as can be seen from the case @hippocrates referenced earlier, the adjudicator will also side with them, as they had said in that appeal "I find that it does remain the driver's responsibility to provide the correct location code before obtaining a parking session using the RingGo service"
Correct me if I'm wrong but we're counting on the incorrect location code to help us win this one?
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The PPA is not really relevant as it's a signed bay but I'm assuming both the PPA and signed bays permit resident parking. The sign just days Permit holders D.
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Ok so I think I've now finally got it! they've issued a 16s, which is a wrong code, ie the 's' should not have been there, rather a code 12/19 should have been used, hence we are saying no contravention took place - Would we not just say wrong code used to spell it out for the LA?
Leaving the below point,
It is a signed bay in a PPA though.
This a good thing or a bad thing in our case and come into play with the defence we're looking at no contravention due to incorrect code?
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I've changed my mind. London Councils say for code 16:
Suffix ‘s’ only for use where bay is completely non-resident. In shared use bays where residents’ permits are valid, codes 12 and 19 should be used as appropriate.
It is a signed bay in a PPA though.
(https://i.ibb.co/7J5YNPBy/Screenshot-2025-11-23-at-22-26-23.png)
(https://i.ibb.co/JwVdTgYS/Screenshot-2025-11-23-at-22-26-10.png)
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OP, getting back to the facts of this case as you've presented them.
IMO,
It is not a Permit Parking Area.
It's a parking place, and that's it. CPZs are not relevant as they only control waiting, not parking.
The hours shown on the sign mean that it is a SHARED USE bay for its entirety, that is to say Mon-Sat 8.30-6.30. The only distinction is that permit holders may park without time limit whereas those who pay are limited to a maximum of 2 hours.
With this background in mind Parking without displaying a permit is nonsense. It must be code the lengthy code 12 description.
Your defence: contravention did not occur.
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Just catching up on my tickets/appeals :( Based on all the discussions and thoughts, how should I respond as there has been a number of points made in this thread, some have confused me, I believe tomorrow is the last day to appeal
Some more info, not sure if it'll help, I was there the other day and noticed the roads (York Road & Beal Road) off Argyle road that I was on, actually had the code that I had used and that appeared on Ring Go 6081228, so its very easily confusing, with two parralell roads having the code but the road itself not.. and one would deem this area Ilford Town.
I assume I cannot say I saw the sign on the side road which matched the ringo, as I was walking being the same area, as Redbridge have a tendancy to give a block/area of roads the same code and/or I had parked in the area before a number of times (which I had) and been using the 6081228 so had no reason to think otherwise when it showed in the app or would they counter saying I should have verified with the sign on the actual road?
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Why can't a shared use bay be just a permit and pay? It may be that the only permit allowed there is resident but the sign and PCN match.
Must say I can't see a strong case here - the fairness of the ridiculous location code and app location is the main route IMO.
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Nonsense.
You can have 1 or 2, therefore it follows that not having one cannot be a contravention because you could have the other.
Only contravention grounds which relate to permits AND payment could apply. And this is 12 in your case.
Where are the Permit Parking Area signs?
"permit parking area”
an area—
(a)
into which each entrance for vehicular traffic has been indicated by the sign provided for at item 5 of the sign table in Part 3 of Schedule 5; and
https://www.legislation.gov.uk/uksi/2016/362/schedule/5
(b)
where any parking place within that area reserved for the use of the permit holders as indicated on that sign is not shown by markings on the road (whether or not an upright sign is placed next to, or near, such a parking place to indicate that only the permit holders in question may use the place)
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It's a PPA not a CPZ
So does the CPZ/PPA element not make any difference to the case, even the fact two entry points actually show a controlled zone sign?
Ironically I happened to listen in on the case cited. Does the council's evidence show the car in relation to the sign?
The CEO pictures does not have a picture with both the car and the sign in one, however one could figure out using other pictures that the sign is shown is actaully sitauated where the car was parked.
A motorist has 2 options to procure parking rights:
1. To display a valid permit or hold a virtual permit; or
2. To pay the parking charge.
IMO, the only possible contravention description is 12. It cannot be 16 because having a valid paid parking session is not a defence against failing to display/hold a permit.
Excuse my ignorance here, but the contravention meets point 1? which is basically what the contravention 16s states surely, which according to them I did not do/have (16s - Parked in a permit space without a valid virtual permit)?
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IMO, it's the wrong contravention.
A motorist has 2 options to procure parking rights:
1. To display a valid permit or hold a virtual permit; or
2. To pay the parking charge.
IMO, the only possible contravention description is 12. It cannot be 16 because having a valid paid parking session is not a defence against failing to display/hold a permit.
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Ironically I happened to listen in on the case cited. Does the council's evidence show the car in relation to the sign?
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It's a PPA not a CPZ - I just thought it odd that permit holders can also use the signed bays when they also have the unmarked kerbside.
The parking sign doesn't say resident though.
(https://i.ibb.co/MD8dJWqF/r1.jpg)
(https://i.ibb.co/6Rnx4ntQ/r2.jpg)
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Thanks! A very long order, not sure what bit I should be looking at :/
The location is https://maps.app.goo.gl/SAHtMPFf4vmfUyNt6, the lampost sign states it is a Shared Bay (Resident and P&D), not sure of any other signage that I saw ie entering the roads/area, however I believe it is part of a CPZ.
There are some parts of the road with no bay marking at all, nor any yellow line markings, so my understanding was I could park there, however I asked a CEO (to be safe) said, only residents with parking permit can park there, anyone else would get a ticket, it doesnt need to have a marked bay, nor a lampost with signage, nor a yellow line, as its in a CPZ - True?
UPDATE - Having checked around the boundary of the CPZ, There are 5 entry points, from GSV, I see the following
Point 1. https://maps.app.goo.gl/mjN7MB8MYQycGbxy8 - Permit Holders Only, Except Signed Bays
Point 2. https://maps.app.goo.gl/94zNGkL39M3BBz7n6 - Permit Holders Only, Except Signed Bays
Point 3. https://maps.app.goo.gl/PrHDWMPUEYbHbtL27 - CPZ Sign
Point 4. https://maps.app.goo.gl/VcwPCy8e89QEmabU7 - CPZ Sign
Point 5. https://maps.app.goo.gl/5ZHKxZm53oR7NPWj8 - Nothing
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This is the order.
I think the bay you were in is in a permit parking area - do you know what the entry signs say? Usually the signed bays are not for permit holders.
What is the latest Maps link.
https://store.traffweb.app/redbridge/documents/parkmap/sched/1.%20The%20Redbridge%20(Waiting,%20Loading,%20Stopping%20and%20Street%20Parking%20Places)%20Consolidation%20Order%202021.pdf
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This is different from the usual Redbridge ones - we'd have to look at the order to see what permits are allowed there.
Interesting, I've noticed (from experience of being hit) they usually issues a '11 - Parked without payment of the parking charge' or similar, but those were P&D bays - I assume I'll have to ask the parking team at Redbridge for the TMO for that bay?
And if the CEO could tell there was a live pay session for a nearby location I'd say a Lower level code 19 should have been issued.
110% the CEO would have seen a live session nearby, I actually think the code I had is used on side road of the one I was on, although not sure what the other codes such as 19 would have meant for me in this case? assume it doesn't mean they've used a wrong contravention code and a way out for us?
But a challenge can still be made on having a pay/free session - Redbridge has recently changed to 7 digit location codes which I think is bound to result in more errors where there us just one end digit different among similar location names.
Redbridge will ignore that challange for sure, question is if we took it to adjudication would that hold against this?
Yes agree, which is whats annoying, as this is my second error (have another post which you've posted on, currently awaiting NTO to further appeal), but same thing although on that occasion I typed it in with the last digit incorrect!
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This is different from the usual Redbridge ones because it's a shared use permit/pay bay and the contravention is not having a permit in a shared use bay (the suffix s is shared use). The usual code in shared use bays is 12 as most are resident permit bays - we'd have to look at the order to see what permits are allowed there.
But a challenge can still be made on having a pay/free session - Redbridge has recently changed to 7 digit location codes which I think is bound to result in more errors where there us just one end digit different among similar location names.
And if the CEO could tell there was a live pay session for a nearby location I'd say a Lower level code 19 should have been issued.
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Hey Hippocrates!
My knight in shining armour, although this time it seems that you're asking me to lower the shield and accept defeat as the outcome will be as you've posted :'( that too of a very very recent case.
I get it from a persepctive of did it happen or did it not, its clear cut, but one would have thought some discretion could have been applied, we know the councils do not this anymore.
I saw in another post for a different issue, the below was mentioned, could it fall within this or not really?
"Under general principle of public law, authorities have a duty to act fairly and porportionately and are encouraged to excercise discretion sensibly and reasonably andwith due regard to public interest"
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Case Details
Case reference 2250334450
Appellant **********
Authority London Borough of Redbridge
VRM PF19FWH
PCN Details
PCN AF09033725
Contravention date 26 Apr 2025
Contravention time 13:27:00
Contravention location Beal Road
Penalty amount GBP 110.00
Contravention Parked without payment of the parking charge
Referral date -
Decision Date 08 Nov 2025
Adjudicator Carl Teper
Appeal decision Appeal refused
Direction Full penalty charge notice amount stated to be paid within 28 days.
Reasons
The Appellant attended the video linked hearing. The Authority was not represented.
The Enforcement Authority's case is that the Appellant's vehicle was parked without payment of the parking charge when in Beal Road on 26 April 2025 at 13:27.
The Appellant's case is as follows: 'I paid the £2 receipt attached but in error I put in location 7107 instead of 7157. I typed in wrong code which said parked in Grove Road, Wanstead. My £2 was paid on 13.06pm on 26 April. Note I cannot be parked in 2 places at the same time. It was a typo error by typing in 7107 instead of 7157. Proof attached of my payment to LBR of £2 on 13.06pm . Please cancel the penalty based on the above grounds as you can clearly see its a honest mistake and I cannot be parked with the same car at 2 locations at once.'
I have considered the evidence and I find that Appellant's vehicle was parked without payment of the parking charge when in Beal Road on 26 April 2025.
I find that the Appellant paid to park his vehicle in location 7107, which is Grove Park and not 7157, which is Beal Road.
I find that it does remain the driver's responsibility to provide the correct location code before
obtaining a parking session using the RingGo service or any parking payment service. The parking application cannot decide where a motorist's vehicle is actually parked - that is why location codes are provided.
I find this error by the Appellant only goes to mitigating circumstances, which have already been considered by the Authority; they do not provide a defence or raise an exemption.
The Adjudicator decides appeals by making findings of fact and applying the law as it stands. The Adjudicator has no power to quash a penalty charge on the basis of mitigation submitted.
The appeal is refused
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Guys,
Actually gutted on this one, as there was no intention to decieve or avoid booking the ticket, I actually
booked it with every intention to avoid a ticket but get to my car and there's a big yellow PCN!
16s - Parked in a permit space without a valid virtual permit
https://ibb.co/wZt3p6Pg
https://ibb.co/jv8F1gDP
Redbridge, offer the first hour of parking free but it has to be booked via Ringo, it seems that they take advantage of this, when user accidently input a incorrect location - So the booking code (6081228) I used was 1 digit different to the correct one (6081226).
I know the council will respond stating that the owness is on the customer to ensure location etc
I booked as follows:
1. I selected the location from the list pre populated within RingGo based on location/nearest.
2. Location said Ilford Town, which is where I was, so selected it - https://ibb.co/9kkbHtnr
3. Based on the above I automatically assumed location code was correct, coupled with it looking or having the similar digits, that I remembered from when I glanced at the P&D board (ie 60812...)
I noticed that the P&D board had a sticker on the location code, suggesting the code has been changed at some point. Therefore not sure if the 6081226 is a new code, hence why it had not appeared automatically in the Ringo list, rather would have had to be manually input and previously the location was in fact 6081228 hence why it appeared - Although the council will not care. (See below)
https://ibb.co/VpCNRfBJ
https://ibb.co/ZRHz6Yqk
I'm sure when the wardens put in a plate, it brings up all permits in that borough currently active, they would have seen it say 6081228 - Ilford Town, yet applied no discretion.