Free Traffic Legal Advice

Please accept this letter as confirmation that <LEASE COMPANY> authorise you to communicate directly with the nominated person
detailed below in relation to the Penalty Charge Notice they have received:

<REDACTED PCN DETAILS WITH MY NAME AND ADDRESS>

The above vehicle is on long term lease with <LEASE COMPANY> and the nominated person above has full use of the vehicle.

I appeal PCN RG84619650 for Minster Street (westbound) on the grounds that (1) the alleged contravention did not occur because the restriction is not adequately signed and operates as a trap, and (2) there have been procedural improprieties in the PCN wording and in the council’s consideration of my representations.

I approached Minster Street via King’s Road and King Street. The only advance sign on King’s Road before the King Street junction is a long narrative sign with several lines of text, positioned on a priority route with a pedestrian island at the junction. In real traffic conditions it is not safe or realistic to slow or stop to read multiple lines of text, so a driver only has a momentary glance. At that glance, the sign and carriageway markings give the impression that only buses etc. may proceed in a particular direction and that “all other traffic” should take a different route, but they do not clearly and accurately explain that entering King Street is always lawful and that the real restriction is at the far end when leaving via Minster Street.

Once in King Street, the road feels like an ordinary city‑centre street and leads naturally towards the western end. There is no clear warning that by continuing, an ordinary motorist may be left with no safe and realistic exit. At the western end, “No Entry” signs block both the Broad Street and Butter Market options; in live traffic there is no practical or safe way to turn around or reverse back up King Street without creating a hazard and contrary to basic Highway Code advice about reversing in busy roads. In practice, the only apparent way out is left into Minster Street, which is the camera‑enforced bus‑lane exit. I say this layout functions as a trap: I entered King Street lawfully and then found that the only realistic way to leave during the restricted hours was by using the bus lane.

These are the same fundamental concerns identified by an adjudicator in an earlier case about this location (Carnevale v Reading BC, RG00104‑1610, 7/12/2016), where the same advance sign was found to be misleading, too long to be assimilated, and inconsistent with the diagrammatic advance signing recommended in the Traffic Signs Manual (TSM) Chapter 3. I rely on the reasoning already quoted in my representations and do not repeat those extracts here. I also provide a photo of the current narrative sign and copies of the relevant 2019 TSM Chapter 3 figures (9‑26 and 5‑4), which show the recommended diagrammatic style.

On the procedural side, the PCN states that if I do not pay or make representations “the Council WILL serve a Charge Certificate”, whereas under the current Civil Enforcement of Road Traffic Contraventions regulations this is a discretionary step (“may”), not automatic. This misstates the legal position and fetters the council’s discretion. The PCN also fails clearly to state that still images of the alleged contravention will be provided free of charge on request, and appears to reserve control over viewing arrangements entirely to the council, so it does not fully and clearly convey my statutory entitlement to evidence.

Finally, with my representations to the council I supplied a narrated video of the approach from King’s Road into King Street and the constrained exit at Minster Street, and expressly asked that it be considered. In the Notice of Rejection the council states that the representations were decided “after full consideration of the representations”, yet the letter does not mention my video at all; it refers only to the council’s own CCTV and responds largely with generic assertions about signage. I also have evidence that the council did not in fact access my video link. Taken together, the absence of any reference to the video and the failure to engage with the substance of my signage/trap arguments show that the council did not genuinely give “full consideration” to my representations or supporting evidence as required by the 2022 Civil Enforcement regulations. I say this is a further procedural impropriety.

For clarity, my original representations to the council used the terminology of the earlier Bus Lane Contraventions regulations. I now understand that enforcement in Reading is governed by the Civil Enforcement of Road Traffic Contraventions (Approved Devices, Charging Guidelines and General Provisions) (England) Regulations 2022 and the Civil Enforcement of Road Traffic Contraventions (Representations and Appeals) (England) Regulations 2022. My legal points are intended to be read as applying under the current 2022 regulations.

I attach my original written representations (including the Carnevale passages already cited, photographs of the signage and the 2019 TSM figures), the council’s Notice of Rejection, the narrated video link itself, and the other supporting evidence I have retained.