Hello.
I have received this PCN for stoping for 27 seconds in a bus stop. The contravention happened on 26/02/2026, the date of notice is 02/03/2026, the date I received the letter is 05/02/2026.
Council name : Havering London Borough
PCN Nr: HG82085679
Contravention : Stopped on a restricted bus stop or stand , location Station RD/Balgores Lane RM2 , date 26/02/2026 at time 06:12 AM.
I have dropped my wife for Gidea Park station early in the morning at 06:12 , it was dark, i did not see any signs , nothing was iluminated or highlighted, stoped briefly for only 27 seconds, with half the car in the bus stop, did not obstruct any buss or traffic.
Now, I went there during day time, and took some pictures of the bus stop, and noticed, the yellow curb clearway marking is faded,broken, and at places non existing, the bus stop yellow sign on the ground is in the same condition. There is no clear sign displayed for the oncoming traffic way, where you can see it before stopping. There is only a small upright yellow sign that says No stopping except busses, but this sign is only visible if you are paralel to it, as it is facing the oposite side of the road.
I want to know, that using all this could help me for an appeal, I have seeked help using AI tools such as gemini and copilot, which gave me some compelling arguments and drafts for the appeal, but I believe some real proffesional help might be better.
Thank you in advance for your help. I will attach bellow the photos of the contravention and of the real time bus stop state and condition.
Bus stop google maps link -
https://maps.app.goo.gl/g6gBqsefQVB4iHcR6Photos and viddeo of the contravention :
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https://imgpile.com/p/1Xs8Ejb#DhBYPyF - photo
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https://imgpile.com/p/1Xs8Ejb#bo92fFC - video
Photos of the curent state and condition of the bus stop / road markings/post sign :
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https://imgpile.com/p/1Xs8Ejb#blRlpPb - photo of bus stop
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https://imgpile.com/p/1Xs8Ejb#Xpc0k3o - photo of bus stop
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https://imgpile.com/p/1Xs8Ejb#mAemAfY - photo of no stopping sign and where it's facing
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https://imgpile.com/p/1Xs8Ejb#daDceeE - photo of no stopping sign and no illumination
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https://imgpile.com/p/1Xs8Ejb#VsT1Scz - photo of the condition of the bus stop
I would like to post the draft and grounds for the appeal that was made with the help of Gemini/CoPilot,and would like to kindly ask for advice as it could be a viable appeal or grounds. Thank you in advance to everybody.
Formal Representation Against PCN HG82085679
Vehicle VRM: [Insert Car Reg]
Grounds for Appeal: The contravention did not occur / Procedural Impropriety
To the London Borough of Havering Parking Department,
I am writing to formally contest this PCN. As the Registered Keeper, I contend that the penalty is unenforceable based on the following three critical points:
1. The Principle of "De Minimis" (Negligible Duration)
The council’s CCTV evidence confirms that the vehicle was stationary for only 27 seconds at 06:12 AM. The vehicle was only partially encroaching (two wheels) into the marked bay. No bus was present, no passenger boarding was obstructed, and no traffic flow was impeded. Under the legal principle of de minimis non curat lex, a stop of such a fleeting, trifling nature—especially during off-peak hours—does not constitute a contravention that warrants a penalty charge.
2. Failure of Statutory Signage (Visibility and Orientation)
The signage at this location fails to meet the requirements set out in the Traffic Signs Manual (Chapter 3).
Orientation: The upright "No Stopping" sign is oriented parallel to the kerb, facing the opposite side of the road. It does not face oncoming traffic.
Visibility: At 06:12 AM, in dark conditions, a sign facing away from the driver is effectively invisible as the headlights do not hit the reflective surface. A motorist cannot be expected to comply with a restriction that is not clearly visible from a moving vehicle.
3. Inadequate Road Markings (TSRGD Non-Compliance)
For a Bus Stop Clearway to be legally active, the road markings must be maintained to a compliant standard under the Traffic Signs Regulations and General Directions (TSRGD).
Faded Cage: The "Bus Stop" cage markings on the road surface are significantly faded, broken, and in a state of disrepair.
The Thick Yellow Line: There is no continuous, thick solid yellow line at the kerb edge. As seen in the attached images, the line is heavily worn and missing in several sections. Without this specific marking, the "No Stopping" restriction is legally void.
4. Disproportionate Use of CCTV Enforcement
The Secretary of State’s Statutory Guidance advises that CCTV enforcement should only be used where manual enforcement by a Civil Enforcement Officer is "not practical." At 06:12 AM on a quiet road, there is no evidence that on-street enforcement was impractical. Using high-tech surveillance to penalize a 27-second safety stop in a location with poorly maintained markings is a disproportionate application of the law.
Conclusion
Given the combination of the negligible stop duration, the incorrect orientation of the signage, and the council's failure to maintain the road markings, I request that this PCN be cancelled immediately. Should this representation be rejected, I will require a detailed explanation as to why the council believes a parallel-facing sign and faded curb lines meet the statutory requirements for "clear and consistent" signage.
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