Free Traffic Legal Advice

As requested please see draft representation: https://ibb.co/BVsk5HbV

I have drafted representations in a word document, though I presume they will be rejected, there are sometimes elements to challenge in a Notice of Rejection, so it's just a case of waiting to see what they come back with. If you PM email then I can send representation to you.

What road did you approach the Dulwich Bus Gate from? There is another live case on the forum for Dulwich bus gate (perhaps read that in meantime for strategy). Fortunately, there is a wording defect in the PCN paperwork that can be challenged.

Thought I would clarify my previous post as to how cases are winnable if you have collateral points of appeal, even when the contravention is visible or not. In your case, you may wish to challenge the PCN on multiple counts, 1) there is no contemporaneous image of the vehicle passing any sign, neither the PCN or TfL's video evidence shows any sign being passed, it has not been made out in the PCN paperwork or the supplementary evidence; 2) the wording on the paperwork for the payment period and grounds on page three can be challenged (unless they have updated it). If TfL reject the representation, then sometimes there may be a wording defect in the NOR to strengthen a case. I understand the balance of probabilities test, whether the sign was there on the date, but an ANPR camera is there for a specific purpose to make out the contravention, but in this case it did not. It shows your vehicle making a manoeuvre. If you need the wording to challenge the PCN paperwork let me know, but it's only my layman interpretation and there is no guarantee if it would be accepted.

In terms of the contemporaneous footage, the vehicle passing the sign seems to be clearly made out. With that said, there may well be points that can be challenged in the PCN paperwork, though I am unsure whether or not others here agree with my interpretation of the wording defects. If you want I can draft a short representation including a technical strategy that I recently learned on this forum. From my perspective, the best course of action would be a collateral challenge intermixed with other points of appeal to see if the council make an error in response, that may help build a case in the event you wished to contest it all the way. Do you have any mitigating circumstances or disability that put you at a disadvantage. Are you able to revisit location to film reconstruction footage with iphone by safely walking along the pavement showing the sign at the entrance of the road then walking a few moments to the pedestrian zone sign.

Hopefully someone will respond to your question.

If they have failed to consider your representation then that's a legal point that can be challenged in accordance with paragraph 1(7) under Schedule 1 of the relevant legislation. Now if you cited all the PCNs in that single representation, then that argument may apply to all the PCNs you cited.

If you submit a representation, make sure the PCN portal cites the correct date for submission, once I submitted a representation on Lambeth’s PCN portal, it cited the correct date, then a few days later it changed the date, it seemed to change the date when I sent a question to Lambeth Parking services. I used this error as another legal point to challenge. Also, calculate the last day for the PCN discount and take a screenshot of portal on that date, then take a screenshot the day after incase there are errors.

With regards to the LA exercising discretion, under Section 87 of the Traffic Management Act, they should give regard to the guidance from the secretary of state, this official guidance explicitly mandates that authorities must not fetter their discretion. Gov.uk states on 28 May 2026: “They should approach the exercise of discretion objectively and without regard to any financial interest in the penalty or decisions that may have been taken at an earlier stage in proceedings.”

However, I think the failure to consider argument and screenshot errors on the PCN portal (if any occur) may be a valuable strategy of appeal. I had a recent win against Lambeth, they did not contest at tribunal, just on the basis of a PCN portal screenshot error and telephone recordings where they misinformed the appellant of the enforcement process. Though I am unsure if they operate customer service by telephone or email in recent times.

@Incandescent, please correct me if I am mistaken but for moving traffic pcns would a “repeated contravention” be considered if service of the first PCN comes after the other contraventions occurred or is it strictly limited to parking pcns? In terms of a “continuous contravention” could that apply if a driver passed through multiple traffic restrictions in an area in a window of time on the same date. As I recall seeing cases like that on the previous forum (though it does not apply here).

There was an interesting case on the London Tribunals register of appeals for Rye Lane junction Blenheim Grove

Search case reference: 2220643718

Decision date: 28 Nov 2022

You can read the case here: https://www.londontribunals.gov.uk/about/registers-appeals

Perhaps read the recent southwark cases on FTLA in respect to collateral arguments ie by challenging flaws in the PCN wording, PCN portal or when the LA fail to consider a representation.

GSV shows that from entry to the road the driver is presented with a one-way directional sign, then at the midway point of the road there is a straight ahead directional arrow road marking, upon passing that the road narrows considerably, the traffic seems to be funnelled towards the restriction, and it seems quite difficult to negotiate a u-turn: https://ibb.co/JRHr6Mnn, while the 619 sign seems to be poorly illuminated as per the image on PCN. I responded to your other post so check that for insights.

No worries, just provide an update when Southwark serve the NOR or NOA after your 24 May 2026 PCN challenge. Also monitor PCN portal for any errors in the meantime.