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@stamfordman @tincombe

Thanks for clarity around the NTO Service

Great I'll send this across and see, on my previous cases that have gone ajudication, theyve never re-offered a discount, but even if they did I'd be tempted to take this all the way if my case is strong.

Hi @stamfordman,

See my draft appeal, although in theory is very similar to the informal appeal I sent and re-iterating similar points. Added the bit you advised as point 2.


Ground: The alleged contravention did not occur

I make these formal representations following the council’s rejection of my informal challenge.

1. Incorrect and misleading contravention description

The PCN was issued for contravention code 16s – “Parked in a permit space or zone without a valid virtual permit or clearly displaying a valid permit.”

However, the council’s own photographic evidence shows that the vehicle was parked in a shared-use bay, where parking is permitted either:
* by permit or
* by payment of the applicable tariff.

Where payment is an alternative method of lawful parking, a contravention that alleges only the absence of a permit does not accurately reflect the restriction in force. This renders the contravention description misleading and ambiguous when applied to a shared-use bay.
This point was raised in my informal challenge, but the council’s response does not address it.
It is a fundamental principle of civil enforcement that a PCN must correctly and unambiguously describe the alleged contravention. Where it does not, the contravention cannot be said to have occurred.

2. Clarification requested regarding the alleged regulation breached

In its rejection letter, the council states:
“For shared use bays, the general regulation requires either a valid permit or a correctly registered pay-by-phone session for the specific location.”

I respectfully request clarification as to which specific regulation or Traffic Regulation Order (TRO) provision the council is relying upon when making this assertion.

This clarification is necessary in order to properly understand:
* the precise legal basis of the alleged contravention, and
* how that basis aligns with the contravention alleged under code 16s, which expressly refers to the absence of a permit rather than a payment-related failure.

The council’s response to date has not identified any specific regulation or TRO provision that is said to have been breached.

3. Genuine attempt to comply and payment made

It is not disputed that:
* a RingGo parking session was purchased,
* the correct vehicle registration number was entered, and
* the session covered the full duration of my stay.

The only error was the selection of an incorrect location code by one digit (6081226 instead of 6081228).

The code entered relates to York Road, only a short distance from where the vehicle was parked, and was presented in RingGo with the description “Ilford Town, Redbridge.” The correct code refers to “Ilford Outer, Redbridge.” Given the similarity of these descriptions and the proximity of the locations, this was a genuine and understandable mistake when using the app.

There was no intention to avoid payment or circumvent parking controls. On the contrary, I actively attempted to comply and ensured payment was made.

4. No loss to the authority and disproportionate enforcement

The first hour of parking at this location is free. As such, even if no parking session had been purchased, no financial loss would have arisen during the relevant period.
Issuing a penalty in circumstances where:
* payment was made,
* the vehicle was authorised in principle to park in the bay,
* the error was minor and limited to a location code, and
* no financial loss occurred,
is disproportionate.

The Secretary of State’s Statutory Guidance advises that enforcement authorities must act fairly and proportionately and are encouraged to exercise discretion sensibly and reasonably. The council’s response does not demonstrate that discretion has been meaningfully considered in this case.

5. Failure to properly consider representations

The council’s informal rejection does not engage with:
* the argument regarding the applicability of contravention code 16s to a shared-use bay, nor
* the requirement to consider discretion in cases of genuine error and paid parking.

Instead, it merely restates that no valid session existed for the precise location code, which was never in dispute.

This suggests that my representations were not properly considered. I therefore request that the Penalty Charge Notice be cancelled.

Slight nudge, as I need to respond today

It will be interesting if the adjudicator finds they did not address your point about the statutory guidance.

Yep, got a date for adjudication 9th July,.

Hoping that the statuary guidance ground to go in my favour, as the sky news article also said that BPA (British Parking Association) say the same that on minor errors the tickets should be cancelled, although I assume thats more for private parking.

I just need to decide if I add the bit around my ticks or if it'll be seen as 'why am I adding it now'

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'

Hey all,

Received the NOR, which I was supposed to post a few weeks ago but procrastianted heavily, as expected ignored reasons i mentioned in my appeal from the previous post - See attached.

https://ibb.co/pvwWhsKb
https://ibb.co/ymHBx38Q

As I was checking I noticed I may have gone over the 28th days to respond to appeal in the tribunal, which I did today (14/01/26), letter was dated 17/12/25 - Can someone confirm if I'm ok or they'll now increase the charge by 50% or if that +2 day rule applies that I've only heard being mentioned on this forums, as it was a letter received.?

For now I've appealed with no extra reasoning other then stating that same reasons as before - Is there anything else I can add or counter based on the NOR response above?

I've got a tribunal date of 28th May, after submitting a formal appeal - Should there not have been response from the LA to the formal appeal first, before it got a date at adjudication?

Responded with a lengty response, hopefully it'll do the job if not here then at ajudication


1. The Contravention Did Not Occur
1(a) A payment was made – therefore the alleged contravention is factually incorrect
Contravention 11 requires the motorist to have failed to make a payment. The enforcement authority’s rejection letter confirms that a parking session was created and that a payment was made, but under the wrong location code. This means the contravention as stated on the PCN is factually incorrect.

If the authority believes the issue was that the payment was allocated to the wrong location, that is a different contravention entirely, and not the one stated on the PCN. A PCN must match the facts alleged; if it does not, it is unenforceable - Therefore, the contravention as stated did not occur.

1(b) Additional point: the parking charge was £0.00 – no monetary payment was due
This is a crucial point, the location in which the vehicle was parked carried a £0.00 parking charge during the relevant period.
Where the required payment is £0.00, it is impossible to “fail to pay the parking charge” because:
* No monetary payment is required,
* No monetary payment is possible, and
* A charge of £0.00 cannot logically be “unpaid.”

If the authority’s position is that a free session was not correctly registered due to a location-code error, then that is not the contravention on the PCN. Code 11 explicitly requires non-payment of a charge, but when the charge is £0.00, the contravention cannot occur in law or in logic - It is therefore impossible for the alleged contravention to have taken place.


2. Failure to Consider Circumstances and Exercise Discretion
The Traffic Management Act 2004 statutory guidance requires councils to properly consider representations and exercise discretion fairly and proportionately. My error was a genuine and minor human mistake — a single incorrect digit/location code input while using the RingGo app. I made a good-faith effort to comply and made the required payment (even though the charge was £0.00).

[**** Intersted your extract from the General Guidance Here *****]

The rejection letter does not indicate that due consideration was given to mitigation or discretion. It uses a standardised explanation of policy rather than addressing my specific circumstances. The purpose of parking enforcement is compliance, not punishment. Penalising a minor clerical mistake — especially when the charge was £0.00 — is disproportionate, with my intention to comply being clear, this is precisely the type of situation where statutory discretion should be applied


Conclusion -
* The contravention as stated did not occur,
* It is logically impossible to “not pay” a charge of £0.00,
* The authority’s own evidence confirms a payment was made,
* The authority failed to consider the cirsumstances and fairly and proportionately
* And the enforcement action is disproportionate and unreasonable.