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Messages - Europlus

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I will complete the online representations form but found this template where I have drafted the content I would submit, and potentially send this or something very similar to the Leader of Camden council... I would also be intrigued to know how many tickets have been issued on Maple St for this same, erroneously alleged contravention and how much that has raised, both in total and since the council have clearly been told they should be doing this.

08/06/2026
Camden Council

Dear Sir or Madam,

PCN number: [insert reference number beginning with the letter prefix of the authority]
Vehicle registration number: HX23XWB

I am writing to make formal representations regarding the PCN above. This letter is in addition to my completed representations form, which has been submitted online. I am making representations due to the following reasons:

•   The traffic rules are wrong. The council didn't follow proper procedures for the 'Traffic Regulation Order' as the Penalty Charge Notice in this case was issued for the contravention of failing to comply with a one-way restriction. The video and photographic evidence, submitted by the council, clearly shows that my vehicle had not breached the one-way restriction listed in the 1964 regulations, because the vehicle is not shown to travel in the opposite direction to the arrow, that is to say the wrong way in a one-way street.

•   The rectangular sign clearly visible in the council’s evidence submission is that prescribed by Diagram 652 at Item 5 in Part 4 of Schedule 9 to the Traffic Signs Regulations and General Directions 2016 as indicating one way traffic. It is not that prescribed by Diagram 606 at Item 1 in Part 2 of Schedule 3, as indicating ‘vehicular traffic must proceed in the direction indicated by the arrow’. This circular sign is not shown in the council’s evidence. The signs are different and both, and their meanings, are illustrated in the current edition of the Official Highway Code.

•   The council are aware of this misrepresentation, as there have been two similar cases, dating from August and October 2025, where the PCN has been appealed to the London Tribunal and both appeals have been allowed and the PCN cancelled (References 2250671632 and 2250470539). The basis of these successful appeals was that the restriction contained in the 1964 regulations would not prevent a driver turning left or right off Maple Street. The only prohibition is on driving down Maple Street the wrong way, north-east to south-west and making findings of fact on the basis of the evidence actually produced by the parties and applying relevant law.

Yours faithfully,

(I would attach the photos from the council’s CCTV but don’t think there is any more I need to include?)

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Thank you so much for recognising the similarity between these cases!

I will submit representations (after sharing the draft here for approval) and would be willing to stand my ground at tribunal.

In addition to the representations, which may be processed by a team that are instructed, or encouraged, to reject in the hope of a submission, is there any value in also writing to the leader of the council to make them aware of the previous decisions and likelihood that they would lose at a hearing? Are there any consequences for the council if they pursue a claim that has previously been overturned?

I note the income this generates, especially if a lot of the process is simply automated and of little cost to the councils, but it's so frustrating - because the car is leased, I also get an invoice from the leasing company, though they will refund if/ when the penalty is overturned.


3
Good evening all,

I've tried a search for similar cases but can't find a similar case.

I've just received a postal PCN, dated 03/06/2026, for an alleged contravention on 07/03/2026. There are tiny photos on the PCN, but when looking at the online pictures I can't see any signs that prevent the manoeuvre at the junction (the name of which isn't actually referenced in the PCN - it just says Maple Street).

The circumstances are that the approach to the junction, according to the evidence provided, has a one-way arrow at the entrance to the crossroads. The car is seen driving in the correct direction for the arrow but then turning left at the junction into a two-way road. The determination that the crossroads leads to a two-way road is based on the photos which show a pedestrian warning painted on the road saying "Look Both Ways" and what appears to be a cycle box with a solid line which goes halfway across the road in the opposite direction.

I genuinely don't understand what the contravention is for, as there are no additional signs saying no left turn and, having had a look in the (online) Highway Code, the only references I can find for a one-way sign suggests there are two distinct types - The circular "Ahead Only" sign and the rectangular "One-way Traffic" sign, and it is the rectangular one at this junction.

I think I have reasonable grounds to make representations on this, but wondered if I could please get some help with the wording, so it doesn't get rejected for a poor argument?

Here are links to the PCN and a better image of the one-way sign
PCN - https://imgpile.com/p/jkIhgjB#UOqTm1E
One-way sign - https://imgpile.com/p/jkIhgjB#5PpCAQd

4
Thanks H C Andersen,

I have submitted the TE7 and included a record of the telephone conversation and the postal issues at TEC. I’ve also received an acknowledgement for my emailed submission to TEC (now I was able to email the forms to them).

The enforcement order was indeed sent by post and arrived today, so I appreciate your comment that the “due by” date makes that particular demand invalid.

I’ll ring trafford tomorrow and let them know about the TEC issues and see if they would pause any further action.

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Thank you both, again:

The WS was sent by post (I'd printed it off for signing but couldn't scan it afterwards) to St Katherine's House on, or around, 18/07/2025 stating the grounds that I had not received a Notice to Owner and was, as far as I can see, completed and signed correctly.

I just rang (today) TEC to ask about my WS and they said they've been having issues with their post and they've sent me a TE7 which I will complete and send back with a copy of my original TE9. They will then pass that to Trafford in order to start the process again.

The Order for Recovery and NoE are here:

https://ibb.co/3m1MVNN1 OfR Front
https://ibb.co/ZpgD1558 OfR Rear
https://ibb.co/JFMqqK21 NoE Front
https://ibb.co/35h8QgB0 NoE Rear

In relation to making the payment, TEC suggested I could call Trafford and Jacobs to let them know what is happening and to see if they will await the outcome.

Should I pay in the meantime?

Thanks

6
I don't think the references to London boroughs was irrelevant or nonsense, though as it happens, I had misremembered and that is not what I sent originally but was something I found in the MSE forum (I think) and planned to reference in the next stage... but that is why I'm here seeking help, as I think the arguments put in the article I referenced are similar:
  • There is no detail in the contravention code or description which indicates the specific breach and helps a driver to avoid in the future (i.e. there are parking bays on Elsinore road and there are "matchday restrictions" too - albeit further along that road)
  • Within the Trafford Borough Parking Order 2001, there are measurements along Elsinore Road, specifying the length of the road where double yellow line restrictions apply - and my car was not within the measured area


Regardless, in response to the procedure outlined by Incandescent, I received an Order for Recovery on 07/08/2025 and submitted a witness statement, as per the link in your comment. I didn't get a notice of rejection and have just today received a Notice of Enforcement, from Jacobs, for the sum of £190.

Is there anything can I do now?

7
Thank you both for your responses and suggestions.

Taking the first response initially, o wasn’t certain if parking on the “other side” of a DYL (as if it were a grass verge for example) was the same as parking on the road where there was a DYL?

With respect to the second series of questions and comments; my appeal was submitted online after receiving the PCN. I can’t find a copy of the rejection notice and don’t recall having an NtO.

At this CC stage, even if the stretch of road is not covered by the council’s order, is my only option to pay the charge?

8
Good evening all,

I'm really struggling with the formatting of this post, so will leave all of the image/ link inserts until the end if that's ok?

Some months ago I received a PCN from the local council which alleged my car had been parked on a restricted street during prescribed hours. Initially, I assumed this related to matchday restrictions around Old Trafford cricket and football grounds and spent some time researching and confirming that the road in question, Elsinore Road, is not within any of the Restricted Zones which are listed and mapped out on the Trafford MBC website.

However, I found one of your templates, which suited my situation and used that to appeal on the grounds that the penalty code made no sense and did not accurately and unambiguously show me what contravention had occurred.

The appeal was rejected, on the basis that double-yellow lines denote an area to be restricted "at all times" (choosing words carefully, so I do not make the same mistake of suggesting the whole road, as the fantastic template pointed out).

I have subsequently found the BOROUGH OF TRAFFORD (PROHIBITION OF WAITING AND LOADING AND PROVISION OF PARKING) ORDER 2001, which lists, seemingly, all of the traffic restrictions within the borough of Trafford, and which does indeed include Elsinore Road. My argument now is that the very specific restricted areas include a reference to the NorthEast carriageway restriction which stretches from the junction of Seymour Grove for a distance of 63 metres. The location of the car, using an online map measuring site (Calcmaps.com) was approximately 108 metres from that junction, and therefore appears to be beyond the restricted area.

I have attached, for now, both sides of the PCN, a picture of my car showing the location (in which it faces down the road toward Seymour Grove) and an extract from the Borough Parking Order 2001.

Thank you

NB: The format online was much better than the preview led me to believe, so I will include now a copy of your appeal template that I used...

Dear Sir/Madam

The alleged contravention did not occur. The traffic regulation order fails to define what a “restricted street” is and it does not prescribe that it is a contravention to park in a restricted street during prescribed hours.

Contravention code 01 was originally devised by the London Councils and reflected the fact that London council’s traffic orders made specific reference as to what is to be considered “restricted street”. This can be seen in the example below (for reference, Schedule 1 concerned No Waiting restrictions);

“restricted street” means any street within the London Borough of Lewisham specified in Schedule 1 (hereinafter referred to as a “scheduled street”) and includes, except where the context otherwise requires, so much of every other street within that London borough which is not a scheduled street or a street specified in Schedule 4 and which joins any scheduled street as lies between the kerb line of the scheduled street and a point 18.29 metres distant therefrom and any reference in this order to any restricted street shall be construed accordingly, provided that the expression “restricted street” shall not for the purposes of this order include–

(a) any area on a highway or any place within the London Borough of Lewisham for the time being designated or described as a parking place by any order made or having effect as if made under section 6 or section 45 of the Road Traffic Regulation Act 1984;

(b) in its application to a street specified in column (2) of Schedule 5, that length of street which extends 18.29 metres measured in the direction specified in column (3) of that schedule from the kerb line of the scheduled street specified in column (4) of that schedule, and in this definition the expression “kerb line” in relation to a scheduled street shall mean that imaginary line which is the projection of the line formed by the edge of the main carriageway of the scheduled street adjacent to its junction with the side in question of any other street;

(c) any length of street designated as red route;

The London boroughs would not go to the trouble of taking great care to specifically define what is a “restricted street” if it served no purpose and was unnecessary. Without a traffic order defining “restricted street” then it is reasonable to apply common language. The commonplace definition of “restricted” is thus; “place limits on, confine, restrain”. Therefore, in essence, the PCN informed me that I parked in a street during hours that the street is subject to parking restraints. It does not however inform me of how the vehicle contravened a particular parking restraint or even what parking restraint was contravened. It is highly important to note that not all parking restrictions prohibit parking (eg: parking place restrictions) and so parking in a restricted street during prescribed hours is not a contravention by default since it can be lawful. It is only a contravention if the traffic order is drafted correctly in the manner exampled above.

A street is often subject to a number of differing parking restrictions. For example, one particular parking bay in a street may be restricted to permit holders only between the prescribed hours of 9am to 6pm while another parking bay may be restricted to Pay & Display between the prescribed hours of 8am to 6pm. However, a person who lawfully parks their vehicle in ether bay during the prescribed hours is doing just as my vehicle was also doing, that being, “parked in a restricted street during prescribed hours”. Quite simply, the ground stated on the PCN is not fit for purpose since it does not distinguish between a vehicle that is lawfully parked in a restricted street during prescribed hours and one that is not.

The use of this equivocal ground is potentially prejudicial as a person may prepare an appeal focusing on a parking restriction that is not actually relevant to the reason why the PCN was served. For instance, many PCN’s are served upon vehicles that are parked partly in a parking space with either their front or rear end slightly overhanging an adjacent single or double yellow line. Often where this happens a PCN is served upon the vehicle for being “parked in a restricted street during prescribed hours”. However, due to the diverse meaning in plain English of this ground, the recipient of the PCN may wrongly but reasonably assume that they contravened the parking place restriction rather than be aware that they fractionally infringed upon the “No Waiting” yellow line restriction. In the interest of justice a person needs to easily comprehend why their vehicle was not considered lawfully parked so that they can either avoid doing so again or gather the relevant evidence for any subsequent appeal.

It must also be remembered that the ground on the PCN will be repeated on the NtO and the owner may not have been the driver. Therefore, unless an NtO is accompanied each and every time by adequate photos of the signage, the owner when applying common language will not be able to deduce with certainty what parking restriction the expression “restricted street “concerns and was allegedly contravened. The general principles of law dictate that a person should not have to decipher the ground stated on a PCN or guess what restriction was allegedly contravened; it should be unequivocal. In a day and age when the UK is host to a wealth of visitors and residents whose first language is not English and when central and local Government both readily advocate the use of plain English on all public forms and documents it is nonsensical to use language on a PCN that is ambiguous or may require a person to refer to the glossary of a far away traffic order to gain a degree of understanding of what they allegedly did wrong.

The council may be using the standard contravention codes but it should be remembered that these contravention codes have no statutory authority and cannot be relied upon as a defence as made clear in the key adjudication case between Metrick v Camden (Case no 207034396A).

I find the ground of “parked in a restricted street during prescribed hours” to be unsupported as a parking contravention prescribed by the traffic order. The order may prohibit waiting in certain lengths of road at certain times but the order does not define and correlate waiting restrictions with being "restricted street" nor does it define and correlate what is considered "prescribed hours". It is critical to remember that the purpose of a PCN is to encourage people to park lawfully, so it stands to reason that a person needs to know precisely what they did wrong in order to avoid doing so again. The ground given on the PCN is ineffective in conveying what I allegedly did wrong and as such it does not satisfy paragraph 1(e) contained within the Schedule to “The Civil Enforcement of Parking Contraventions (England) General Regulations 2007 and the penalty charge should be cancelled forthwith rather than drag this matter to adjudication.


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