Free Traffic Legal Advice

I make formal representations against this PCN on the grounds that the alleged contravention did not occur and that there has been procedural impropriety.
The vehicle was lawfully parked in a free parking bay on Burdett Road. After the vehicle had been parked, the bay was suspended for tree works. Without my knowledge or consent, the vehicle was relocated by Transport for London and placed in Agnes Street in a permit-only bay.
I did not park the vehicle in Agnes Street, nor did I cause or contribute to the alleged contravention. The vehicle’s presence in Agnes Street was solely the result of actions taken by a public authority. A parking contravention cannot occur where the location of the vehicle is created by the authority rather than the motorist.
Following its relocation, the vehicle remained stationary in the same position at all times. The issuing of multiple PCNs for the same stationary vehicle, in the same location, for the same restriction constitutes a single continuous contravention. Established adjudicator decisions make clear that only one PCN may be issued until the vehicle is moved. The issuing of repeated PCNs is therefore unlawful and amounts to an abuse of process.
Further, the authority failed to act fairly or proportionately. Having caused the vehicle to be placed in contravention, no steps were taken to mitigate the situation by relocating the vehicle again, removing it, or notifying the registered keeper. Instead, penalties were allowed to accrue over a period of several weeks. This failure constitutes procedural impropriety.
I enclose evidence of the TfL relocation notice and photographs showing that the vehicle remained in the same position throughout the period in question.
For the reasons set out above, I require that this PCN be cancelled. Should the authority reject these representations, I require a full response addressing each ground raised and copies of all evidence and records relied upon, including relocation and enforcement logs.
Yours faithfully,

Registered Keeper

The reason your appeals were strong is that they weren’t “please be nice” mitigation — they were hard legal/procedural points that councils and adjudicators take seriously. These were the key pillars:

1) Authority-created contravention (the biggest one)

You didn’t “choose” to park in Agnes Street. Your case hinged on the fact that the vehicle was relocated by a public authority (TfL / contractor) into a permit bay without your knowledge or consent.

That makes the alleged contravention fundamentally unfair and often not legally attributable to the motorist. Once the council accepted “TfL relocated it,” they essentially accepted the core defence.

2) Continuous contravention (why multiple PCNs were abusive)

Even if a contravention could be said to exist, the vehicle:

- stayed in one place

- under the same restriction

- without moving

So issuing repeated PCNs is treated as one continuous event, not dozens of separate offences. This turns “20+ PCNs” into, at most, a single enforceable situation — and councils know tribunals don’t like repeated ticketing of a stationary car.

3) Failure to mitigate / proportionality (public law fairness)

Once the council (or TfL) caused the vehicle to be in contravention, they should act reasonably:

- relocate again to a lawful bay, or

- remove it, or

- at minimum not allow penalties to rack up endlessly

Your argument framed the enforcement as disproportionate and an abuse of process — especially when they could see the car was unmoved and PCNs were accumulating.

4) Clean, consistent story across every PCN

You kept:

- the same facts

- the same legal grounds

- the same evidence bundle

- the same tone (factual, not emotional)

That consistency is incredibly persuasive because it makes it easy for the council reviewer (and tribunal) to see it’s one event, not 30 unrelated contraventions.

5) Strong contemporaneous evidence

The TfL notice with dates/location/reference number + photos of the vehicle in situ were key because they are:

- time-linked,

- location-specific,

- and not “after-the-fact” explanations.

That kind of evidence shifts the burden back onto the council to justify what happened.

6) Procedural leverage (deadlines + audit trail)

You:

- appealed at NTO stage (where rights are strongest),

- saved submission confirmations,

- and knew the council had 56 days to respond per PCN.

That meant even if they messed up administratively, you had a procedural win ready.