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Civil penalty charge notices (Councils, TFL and so on) / Re: Redbridge, code 47j stopped on a restricted bus stop, Clayhall Avenue
« on: August 03, 2026, 10:51:58 am »As usual chapter and verse. Too long. This is a Notice of Appeal not a full argument. Just: I rely upon whole correspondence and will file further submissions accordingly upon receipt of the council's evidence pack.ok
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Civil penalty charge notices (Councils, TFL and so on) / Re: Redbridge, code 47j stopped on a restricted bus stop, Clayhall Avenue
« on: August 02, 2026, 01:22:13 pm »
Please see a draft of the London tribunals appeal. Kindly provide feedback
London Tribunals Appeal
Appellant: [Name]
PCN:
Vehicle Registration:
Enforcement Authority: London Borough of Redbridge
Grounds of Appeal:
* The alleged contravention did not occur.
* There has been a procedural impropriety on the part of the Enforcement Authority.
⸻
1. The alleged contravention did not occur
The vehicle was not stopped for the purpose of waiting at a bus stop.
The driver observed a vehicle already occupying a nearby lawful parking bay. Its occupant had entered the vehicle and closed the door, making it clear that the vehicle was about to leave. The driver therefore waited behind that vehicle for approximately 20 seconds while it started and vacated the bay, before immediately parking in the now vacant space.
The driver remained in the vehicle throughout and never left it. During this brief period, the passenger exited the vehicle safely.
The Council’s CCTV supports this explanation by showing the other vehicle driving away immediately before the appellant parked. However, the CCTV does not show the full sequence before recording commenced and therefore fails to provide the complete context of why the vehicle was stationary.
The Enforcement Authority has relied upon incomplete CCTV evidence and has failed to prove the contravention.
⸻
2. Failure to consider the representations
My formal representation stated:
“I put you to strict proof that this bus stop is legally signed. If you are unable to do so, please cancel the PCN.”
The Notice of Rejection simply asserts that compliant signage exists but provides no contemporaneous evidence whatsoever.
Instead, the Council relies upon Google Street View images dated August 2025. The alleged contravention occurred on 16 June 2026, approximately ten months later.
Historic Street View imagery does not prove that the required upright sign existed, remained unobstructed and was compliant on the date of the alleged contravention. The Council has therefore failed to provide strict proof of lawful signage at the material time.
The recent decision in Fahim Muhammad Haque v London Borough of Tower Hamlets (Case 2260000010, 29 July 2026) confirms that an enforcement authority must prove that the required upright sign was sufficiently visible. In that case, although the road markings were present, the appeal was allowed because the authority failed to establish that the required sign was adequately visible. Attached: Fahim Muhammad Haque v London Borough of Tower Hamlets (2260000010, 29 July 2026).pdf
⸻
3. Failure to properly consider the representations
The Notice of Rejection fails to address the substance of my representations.
It does not address:
* the incomplete CCTV evidence;
* my explanation that the driver was briefly waiting for a lawful parking bay to become available; or
* my request for strict proof that the bus stop was lawfully signed.
Instead, it simply repeats that stopping is prohibited. That is not proper consideration of the representations as required by the 2022 Regulations.
⸻
4. The Notice of Rejection demonstrates a failure to consider this case
The Notice of Rejection states:
“Our enforcement officer observed your vehicle…”
This statement is plainly incorrect.
The PCN itself confirms that it was issued solely on the basis of evidence from an approved CCTV device. No Civil Enforcement Officer observed the vehicle.
This factual error strongly suggests that the Council has issued a generic template rejection without properly considering the facts of this particular case. Whilst this point may not be decisive on its own, it reinforces the wider procedural impropriety that my representations were not genuinely considered.
⸻
5. The Notice of Rejection misstates the statutory right of appeal
Regulation 9(4)(b) of The Civil Enforcement of Road Traffic Contraventions (Representations and Appeals) (England) Regulations 2022 requires that a Notice of Rejection informs the recipient of the right to appeal under Regulation 10.
Regulation 10 expressly provides that an appeal may be made:
(a) within 28 days beginning with the date of service of the Notice of Rejection; or
(b) such longer period as the adjudicator may allow.
The Notice of Rejection omits this statutory right entirely and therefore fails to comply with the mandatory requirements of the Regulations.
⸻
6. The Notice of Rejection compounds that error
The Council goes further by stating that after 28 days there will be no further opportunity to appeal.
That is incorrect.
Regulation 10 expressly permits an adjudicator to accept a late appeal where appropriate.
By informing the motorist that there is no further opportunity to appeal, the Council has misrepresented the statutory position and is capable of discouraging a motorist from exercising rights expressly conferred by Parliament.
This amounts to a procedural impropriety.
-----
For the reasons set out above, I respectfully request that the Adjudicator allows this appeal and directs the London Borough of Redbridge to cancel PCN
London Tribunals Appeal
Appellant: [Name]
PCN:
Vehicle Registration:
Enforcement Authority: London Borough of Redbridge
Grounds of Appeal:
* The alleged contravention did not occur.
* There has been a procedural impropriety on the part of the Enforcement Authority.
⸻
1. The alleged contravention did not occur
The vehicle was not stopped for the purpose of waiting at a bus stop.
The driver observed a vehicle already occupying a nearby lawful parking bay. Its occupant had entered the vehicle and closed the door, making it clear that the vehicle was about to leave. The driver therefore waited behind that vehicle for approximately 20 seconds while it started and vacated the bay, before immediately parking in the now vacant space.
The driver remained in the vehicle throughout and never left it. During this brief period, the passenger exited the vehicle safely.
The Council’s CCTV supports this explanation by showing the other vehicle driving away immediately before the appellant parked. However, the CCTV does not show the full sequence before recording commenced and therefore fails to provide the complete context of why the vehicle was stationary.
The Enforcement Authority has relied upon incomplete CCTV evidence and has failed to prove the contravention.
⸻
2. Failure to consider the representations
My formal representation stated:
“I put you to strict proof that this bus stop is legally signed. If you are unable to do so, please cancel the PCN.”
The Notice of Rejection simply asserts that compliant signage exists but provides no contemporaneous evidence whatsoever.
Instead, the Council relies upon Google Street View images dated August 2025. The alleged contravention occurred on 16 June 2026, approximately ten months later.
Historic Street View imagery does not prove that the required upright sign existed, remained unobstructed and was compliant on the date of the alleged contravention. The Council has therefore failed to provide strict proof of lawful signage at the material time.
The recent decision in Fahim Muhammad Haque v London Borough of Tower Hamlets (Case 2260000010, 29 July 2026) confirms that an enforcement authority must prove that the required upright sign was sufficiently visible. In that case, although the road markings were present, the appeal was allowed because the authority failed to establish that the required sign was adequately visible. Attached: Fahim Muhammad Haque v London Borough of Tower Hamlets (2260000010, 29 July 2026).pdf
⸻
3. Failure to properly consider the representations
The Notice of Rejection fails to address the substance of my representations.
It does not address:
* the incomplete CCTV evidence;
* my explanation that the driver was briefly waiting for a lawful parking bay to become available; or
* my request for strict proof that the bus stop was lawfully signed.
Instead, it simply repeats that stopping is prohibited. That is not proper consideration of the representations as required by the 2022 Regulations.
⸻
4. The Notice of Rejection demonstrates a failure to consider this case
The Notice of Rejection states:
“Our enforcement officer observed your vehicle…”
This statement is plainly incorrect.
The PCN itself confirms that it was issued solely on the basis of evidence from an approved CCTV device. No Civil Enforcement Officer observed the vehicle.
This factual error strongly suggests that the Council has issued a generic template rejection without properly considering the facts of this particular case. Whilst this point may not be decisive on its own, it reinforces the wider procedural impropriety that my representations were not genuinely considered.
⸻
5. The Notice of Rejection misstates the statutory right of appeal
Regulation 9(4)(b) of The Civil Enforcement of Road Traffic Contraventions (Representations and Appeals) (England) Regulations 2022 requires that a Notice of Rejection informs the recipient of the right to appeal under Regulation 10.
Regulation 10 expressly provides that an appeal may be made:
(a) within 28 days beginning with the date of service of the Notice of Rejection; or
(b) such longer period as the adjudicator may allow.
The Notice of Rejection omits this statutory right entirely and therefore fails to comply with the mandatory requirements of the Regulations.
⸻
6. The Notice of Rejection compounds that error
The Council goes further by stating that after 28 days there will be no further opportunity to appeal.
That is incorrect.
Regulation 10 expressly permits an adjudicator to accept a late appeal where appropriate.
By informing the motorist that there is no further opportunity to appeal, the Council has misrepresented the statutory position and is capable of discouraging a motorist from exercising rights expressly conferred by Parliament.
This amounts to a procedural impropriety.
-----
For the reasons set out above, I respectfully request that the Adjudicator allows this appeal and directs the London Borough of Redbridge to cancel PCN
4
Civil penalty charge notices (Councils, TFL and so on) / Re: Redbridge Council, Parked without payment, George Lane,
« on: August 02, 2026, 01:08:22 pm »
Here is the London tribunals appeal with all points included. Please provide feedback
London Tribunals Appeal
PCN:
Vehicle Registration:
I rely upon all representations previously made to the enforcement authority, together with all supporting evidence previously supplied. Those representations are repeated and incorporated into this appeal.
Without repeating those submissions in full, I make the following additional submissions arising from the enforcement authority’s rejection of my formal representations.
1. The alleged contravention did not occur
The allegation is that the vehicle was “Parked without payment of the parking charge.”
That allegation remains incorrect.
The parking charge was paid in full using the RingGo cashless parking system. The only error was that the incorrect vehicle registration was inadvertently selected within the RingGo application.
The authority has suffered no financial loss whatsoever.
The authority has never disputed that payment was made.
Accordingly, the allegation that the vehicle was parked without payment is not established.
If the authority contends that payment must be linked to the correct vehicle registration, that is a different issue from the contravention alleged on the PCN.
⸻
2. Failure to properly consider the representations
The enforcement authority was under a statutory duty to properly consider my representations.
Instead, the Notice of Rejection consists largely of standard wording and fails to engage with the principal issues raised, namely:
* that payment had in fact been made;
* that the council suffered no financial loss;
* that the alleged contravention specifically alleged non-payment;
* the procedural impropriety arguments concerning the wording of the PCN.
The rejection gives no proper reasons explaining why those submissions were rejected.
A failure to genuinely consider representations is itself a procedural impropriety.
⸻
3. The Notice of Rejection misstates the statutory right of appeal
Regulation 9(4)(b) of The Civil Enforcement of Road Traffic Contraventions (Representations and Appeals) (England) Regulations 2022 requires that where representations are rejected, the decision notice must inform the recipient of the right to appeal under Regulation 10.
Regulation 10 provides that an appeal must be made:
“(a) within the period of 28 days beginning with the date of service of the decision notice; or
(b) such longer period as the adjudicator may allow.”
The Notice of Rejection fails to inform me of this statutory right.
Instead, it omits entirely the statutory wording permitting the adjudicator to accept a late appeal.
That omission is material because Parliament has expressly conferred that discretion upon the adjudicator.
The authority has therefore failed to comply with the mandatory requirements of the Regulations.
⸻
4. The Notice of Rejection compounds the error
The defect is compounded by the authority exercising its discretion under Regulation 9(
(b) to include additional information stating, in effect, that:
after 28 days, and once a Charge Certificate is served, there would be no further opportunity to appeal.
That statement is inaccurate.
The legislation expressly provides that an adjudicator may allow an appeal outside the 28-day period.
Rather than accurately informing the motorist of their statutory rights, the authority has stated the opposite.
This is capable of discouraging or deterring a motorist from exercising statutory appeal rights and is therefore a procedural impropriety.
⸻
5. The PCN does not comply with the 2022 Regulations
As submitted previously, the Regulation 9 PCN states:
“The Penalty Charge must be paid no later than the last day of the period of 28 days beginning with the date on which the PCN was served.”
However, Schedule 2 to The Civil Enforcement of Road Traffic Contraventions (Approved Devices, Charging Guidelines and General Provisions) (England) Regulations 2022 requires the PCN to state that payment must be made within 28 days beginning with the date on which the alleged contravention occurred.
This point was raised in my representations but has not been properly addressed.
⸻
6. The PCN fails to include the mandatory information required by Regulation 3
As previously submitted, the Regulation 9 PCN also fails properly to convey the mandatory information required by Regulation 3 of The Civil Enforcement of Road Traffic Contraventions (Representations and Appeals) (England) Regulations 2022 concerning:
* pre-Notice to Owner representations;
* the authority’s duty to consider them; and
* the position should a Notice to Owner nevertheless be served.
Again, this point was not properly addressed.
⸻
7. Contravention not proven
The authority bears the burden of proving the contravention.
The photographs relied upon do not establish the alleged contravention.
In particular:
* no photograph shows the vehicle together with the relevant sign;
* no photograph demonstrates the relationship between the vehicle and the applicable parking sign;
* no photograph shows the extent of the parking bay or the applicable restriction.
The evidence therefore fails to establish that the vehicle was parked subject to the restriction alleged.
Where photographic evidence is relied upon, it should demonstrate both the vehicle and the applicable restriction. It does not do so in this case.
Accordingly, the contravention has not been proved.
⸻
8. The Notice to Owner misstates and conflates the statutory time periods
The Notice to Owner states:
“If you do not pay the penalty charge in full, or if you have not made representations to the authority, within the period of 28 days beginning with the date on which this Notice to Owner is served, the authority may increase the penalty charge by 50% to £165 and may take steps to enforce payment of the increased charge.”
This wording is capable of misleading the recipient.
The legislation requires the Notice to Owner to clearly explain the statutory time limits applicable to payment and to the making of representations. Instead, the authority has combined both matters into a single sentence connected by the word “or”.
A reasonable recipient could read this as meaning that a Charge Certificate may be issued where either:
* payment has not been made; or
* representations have not been made,
without appreciating how those statutory rights interact.
The wording therefore lacks the clarity expected of a statutory notice.
Furthermore, by compressing two distinct statutory requirements into a single composite sentence, the Notice to Owner fails to accurately and transparently explain the legal position.
Statutory notices are required to communicate legal rights and obligations with clarity. Where ambiguity exists, it should not be construed against the recipient.
For these reasons, the Notice to Owner is procedurally defective.
⸻
For all of the reasons previously advanced, together with the additional procedural improprieties identified above, I respectfully request that the Adjudicator allows the appeal and directs the London Borough of Redbridge to cancel the Penalty Charge Notice.
London Tribunals Appeal
PCN:
Vehicle Registration:
I rely upon all representations previously made to the enforcement authority, together with all supporting evidence previously supplied. Those representations are repeated and incorporated into this appeal.
Without repeating those submissions in full, I make the following additional submissions arising from the enforcement authority’s rejection of my formal representations.
1. The alleged contravention did not occur
The allegation is that the vehicle was “Parked without payment of the parking charge.”
That allegation remains incorrect.
The parking charge was paid in full using the RingGo cashless parking system. The only error was that the incorrect vehicle registration was inadvertently selected within the RingGo application.
The authority has suffered no financial loss whatsoever.
The authority has never disputed that payment was made.
Accordingly, the allegation that the vehicle was parked without payment is not established.
If the authority contends that payment must be linked to the correct vehicle registration, that is a different issue from the contravention alleged on the PCN.
⸻
2. Failure to properly consider the representations
The enforcement authority was under a statutory duty to properly consider my representations.
Instead, the Notice of Rejection consists largely of standard wording and fails to engage with the principal issues raised, namely:
* that payment had in fact been made;
* that the council suffered no financial loss;
* that the alleged contravention specifically alleged non-payment;
* the procedural impropriety arguments concerning the wording of the PCN.
The rejection gives no proper reasons explaining why those submissions were rejected.
A failure to genuinely consider representations is itself a procedural impropriety.
⸻
3. The Notice of Rejection misstates the statutory right of appeal
Regulation 9(4)(b) of The Civil Enforcement of Road Traffic Contraventions (Representations and Appeals) (England) Regulations 2022 requires that where representations are rejected, the decision notice must inform the recipient of the right to appeal under Regulation 10.
Regulation 10 provides that an appeal must be made:
“(a) within the period of 28 days beginning with the date of service of the decision notice; or
(b) such longer period as the adjudicator may allow.”
The Notice of Rejection fails to inform me of this statutory right.
Instead, it omits entirely the statutory wording permitting the adjudicator to accept a late appeal.
That omission is material because Parliament has expressly conferred that discretion upon the adjudicator.
The authority has therefore failed to comply with the mandatory requirements of the Regulations.
⸻
4. The Notice of Rejection compounds the error
The defect is compounded by the authority exercising its discretion under Regulation 9(
(b) to include additional information stating, in effect, that:after 28 days, and once a Charge Certificate is served, there would be no further opportunity to appeal.
That statement is inaccurate.
The legislation expressly provides that an adjudicator may allow an appeal outside the 28-day period.
Rather than accurately informing the motorist of their statutory rights, the authority has stated the opposite.
This is capable of discouraging or deterring a motorist from exercising statutory appeal rights and is therefore a procedural impropriety.
⸻
5. The PCN does not comply with the 2022 Regulations
As submitted previously, the Regulation 9 PCN states:
“The Penalty Charge must be paid no later than the last day of the period of 28 days beginning with the date on which the PCN was served.”
However, Schedule 2 to The Civil Enforcement of Road Traffic Contraventions (Approved Devices, Charging Guidelines and General Provisions) (England) Regulations 2022 requires the PCN to state that payment must be made within 28 days beginning with the date on which the alleged contravention occurred.
This point was raised in my representations but has not been properly addressed.
⸻
6. The PCN fails to include the mandatory information required by Regulation 3
As previously submitted, the Regulation 9 PCN also fails properly to convey the mandatory information required by Regulation 3 of The Civil Enforcement of Road Traffic Contraventions (Representations and Appeals) (England) Regulations 2022 concerning:
* pre-Notice to Owner representations;
* the authority’s duty to consider them; and
* the position should a Notice to Owner nevertheless be served.
Again, this point was not properly addressed.
⸻
7. Contravention not proven
The authority bears the burden of proving the contravention.
The photographs relied upon do not establish the alleged contravention.
In particular:
* no photograph shows the vehicle together with the relevant sign;
* no photograph demonstrates the relationship between the vehicle and the applicable parking sign;
* no photograph shows the extent of the parking bay or the applicable restriction.
The evidence therefore fails to establish that the vehicle was parked subject to the restriction alleged.
Where photographic evidence is relied upon, it should demonstrate both the vehicle and the applicable restriction. It does not do so in this case.
Accordingly, the contravention has not been proved.
⸻
8. The Notice to Owner misstates and conflates the statutory time periods
The Notice to Owner states:
“If you do not pay the penalty charge in full, or if you have not made representations to the authority, within the period of 28 days beginning with the date on which this Notice to Owner is served, the authority may increase the penalty charge by 50% to £165 and may take steps to enforce payment of the increased charge.”
This wording is capable of misleading the recipient.
The legislation requires the Notice to Owner to clearly explain the statutory time limits applicable to payment and to the making of representations. Instead, the authority has combined both matters into a single sentence connected by the word “or”.
A reasonable recipient could read this as meaning that a Charge Certificate may be issued where either:
* payment has not been made; or
* representations have not been made,
without appreciating how those statutory rights interact.
The wording therefore lacks the clarity expected of a statutory notice.
Furthermore, by compressing two distinct statutory requirements into a single composite sentence, the Notice to Owner fails to accurately and transparently explain the legal position.
Statutory notices are required to communicate legal rights and obligations with clarity. Where ambiguity exists, it should not be construed against the recipient.
For these reasons, the Notice to Owner is procedurally defective.
⸻
For all of the reasons previously advanced, together with the additional procedural improprieties identified above, I respectfully request that the Adjudicator allows the appeal and directs the London Borough of Redbridge to cancel the Penalty Charge Notice.
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Civil penalty charge notices (Councils, TFL and so on) / Re: Redbridge, code 47j stopped on a restricted bus stop, Clayhall Avenue
« on: August 01, 2026, 04:34:22 pm »1. How old are those Google images?Timestamp of google images shows August 2025. I can read it on the letter they sent but the scan I uploaded here is a bit blurry.
2. https://drive.google.com/file/d/1D9H5QrIcb2exzFShYUfyrPIu4UVff8Ta/view
3. Same criticisms of NOR as per other PCN?
They are scraping the barrel in a few appeals at present.
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Civil penalty charge notices (Councils, TFL and so on) / Re: Redbridge Council, Parked without payment, George Lane,
« on: July 31, 2026, 07:42:55 pm »
I received the rejection letter from the council today. They have offered reduced fee so is it worth paying or further appeal is recommended ?
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Civil penalty charge notices (Councils, TFL and so on) / Re: Redbridge, code 47j stopped on a restricted bus stop, Clayhall Avenue
« on: July 31, 2026, 07:35:08 pm »
I have received the rejection notice from the council today. Funnily enough they have included a google street image of the sign as they have realised that the original notice doesn't have it. Please see below and advise on next steps.
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Civil penalty charge notices (Councils, TFL and so on) / Re: Redbridge Council, Parked without payment, George Lane,
« on: July 15, 2026, 10:36:12 am »
Representations submitted.
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Civil penalty charge notices (Councils, TFL and so on) / Re: Redbridge Council, Parked without payment, George Lane,
« on: July 09, 2026, 02:38:03 pm »
Draft for representation
Grounds of Representation
☑ The alleged contravention did not occur.
☑ There has been a procedural impropriety on the part of the enforcement authority.
⸻
REPRESENTATIONS
I make these representations on the grounds that the alleged contravention did not occur and that there has been a procedural impropriety by the enforcement authority.
1. The alleged contravention did not occur
The allegation is that my vehicle was:
“Parked without payment of the parking charge.”
That allegation is factually incorrect.
The parking charge for the relevant location and period was paid in full using the RingGo cashless parking system. Unfortunately, when completing the payment, the driver inadvertently selected the wrong vehicle registration number within the RingGo application.
This was a genuine keying error and not an attempt to avoid payment.
The council received the parking fee it was entitled to receive. There was therefore no loss of revenue whatsoever.
The contravention alleged is specifically one of parking without payment. Payment was made. Accordingly, the allegation that the vehicle was parked without payment is simply not correct.
Whilst I appreciate the council may argue that payment should have been linked to the correct vehicle registration, that is not what this PCN alleges. The allegation is non-payment.
Numerous adjudicators have recognised that there is an important distinction between:
* parking without payment; and
* payment having been made but recorded against an incorrect registration because of a genuine keying error.
The latter is not accurately described by the contravention alleged on this PCN.
For that reason alone, I submit that the alleged contravention did not occur.
⸻
2. The council has failed to properly exercise its discretion
Even if the council considers that a contravention technically occurred, I request that it exercises its discretion under section 87 of the Traffic Management Act 2004.
This was a genuine mistake.
* the parking session was purchased;
* the correct location was selected;
* the council received full payment;
* there was no intention whatsoever to evade payment;
* there was no financial prejudice to the council.
The purpose of civil parking enforcement is compliance, not punishment.
Cancelling this PCN would be entirely consistent with the Secretary of State’s Statutory Guidance, which expects authorities to exercise discretion fairly and reasonably where appropriate.
Should the council refuse to cancel the PCN, I request that it explains precisely why it considers it proportionate to demand a penalty of £110 where the parking charge itself was fully paid.
⸻
3. Procedural Impropriety
The original Regulation 9 PCN does not appear to comply with the statutory requirements introduced by the 2022 Civil Enforcement Regulations.
The PCN states:
“The Penalty Charge of £110 must be paid no later than the last day of the period of 28 days beginning with the date on which the PCN was served.”
However, paragraph 2(d) of Schedule 2 to The Civil Enforcement of Road Traffic Contraventions (Approved Devices, Charging Guidelines and General Provisions) (England) Regulations 2022 requires a Regulation 9 PCN to state that payment must be made:
“within the period of 28 days beginning with the date on which the alleged contravention occurred.”
The wording used on Redbridge’s PCN appears to replicate the wording of the superseded 2007 Regulations rather than the wording now prescribed by the 2022 Regulations.
The statutory wording is mandatory.
Failure to include the information required by the Regulations amounts to a procedural impropriety.
⸻
4. Failure to include the information required by Regulation 3
In addition, I do not believe the original PCN adequately conveys the information required by Regulation 3 of The Civil Enforcement of Road Traffic Contraventions (Representations and Appeals) (England) Regulations 2022.
In particular, the PCN does not properly explain:
* that representations received before a Notice to Owner is served must be considered by the authority; and
* that, if a Notice to Owner is nevertheless served, formal representations must then be made in accordance with that Notice.
These are mandatory statutory requirements.
Again, failure to comply with those requirements constitutes procedural impropriety.
⸻
5. Request for disclosure
Should the council not accept these representations, please provide:
* the complete Traffic Management Order applicable to George Lane (C);
* all Civil Enforcement Officer notes;
* all photographs;
* the RingGo payment audit relied upon by the council;
* confirmation that the council has actively considered the exercise of discretion rather than applying a blanket policy.
Accordingly, I respectfully request that the Notice to Owner and the Penalty Charge Notice be cancelled.
Yours faithfully,
Grounds of Representation
☑ The alleged contravention did not occur.
☑ There has been a procedural impropriety on the part of the enforcement authority.
⸻
REPRESENTATIONS
I make these representations on the grounds that the alleged contravention did not occur and that there has been a procedural impropriety by the enforcement authority.
1. The alleged contravention did not occur
The allegation is that my vehicle was:
“Parked without payment of the parking charge.”
That allegation is factually incorrect.
The parking charge for the relevant location and period was paid in full using the RingGo cashless parking system. Unfortunately, when completing the payment, the driver inadvertently selected the wrong vehicle registration number within the RingGo application.
This was a genuine keying error and not an attempt to avoid payment.
The council received the parking fee it was entitled to receive. There was therefore no loss of revenue whatsoever.
The contravention alleged is specifically one of parking without payment. Payment was made. Accordingly, the allegation that the vehicle was parked without payment is simply not correct.
Whilst I appreciate the council may argue that payment should have been linked to the correct vehicle registration, that is not what this PCN alleges. The allegation is non-payment.
Numerous adjudicators have recognised that there is an important distinction between:
* parking without payment; and
* payment having been made but recorded against an incorrect registration because of a genuine keying error.
The latter is not accurately described by the contravention alleged on this PCN.
For that reason alone, I submit that the alleged contravention did not occur.
⸻
2. The council has failed to properly exercise its discretion
Even if the council considers that a contravention technically occurred, I request that it exercises its discretion under section 87 of the Traffic Management Act 2004.
This was a genuine mistake.
* the parking session was purchased;
* the correct location was selected;
* the council received full payment;
* there was no intention whatsoever to evade payment;
* there was no financial prejudice to the council.
The purpose of civil parking enforcement is compliance, not punishment.
Cancelling this PCN would be entirely consistent with the Secretary of State’s Statutory Guidance, which expects authorities to exercise discretion fairly and reasonably where appropriate.
Should the council refuse to cancel the PCN, I request that it explains precisely why it considers it proportionate to demand a penalty of £110 where the parking charge itself was fully paid.
⸻
3. Procedural Impropriety
The original Regulation 9 PCN does not appear to comply with the statutory requirements introduced by the 2022 Civil Enforcement Regulations.
The PCN states:
“The Penalty Charge of £110 must be paid no later than the last day of the period of 28 days beginning with the date on which the PCN was served.”
However, paragraph 2(d) of Schedule 2 to The Civil Enforcement of Road Traffic Contraventions (Approved Devices, Charging Guidelines and General Provisions) (England) Regulations 2022 requires a Regulation 9 PCN to state that payment must be made:
“within the period of 28 days beginning with the date on which the alleged contravention occurred.”
The wording used on Redbridge’s PCN appears to replicate the wording of the superseded 2007 Regulations rather than the wording now prescribed by the 2022 Regulations.
The statutory wording is mandatory.
Failure to include the information required by the Regulations amounts to a procedural impropriety.
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4. Failure to include the information required by Regulation 3
In addition, I do not believe the original PCN adequately conveys the information required by Regulation 3 of The Civil Enforcement of Road Traffic Contraventions (Representations and Appeals) (England) Regulations 2022.
In particular, the PCN does not properly explain:
* that representations received before a Notice to Owner is served must be considered by the authority; and
* that, if a Notice to Owner is nevertheless served, formal representations must then be made in accordance with that Notice.
These are mandatory statutory requirements.
Again, failure to comply with those requirements constitutes procedural impropriety.
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5. Request for disclosure
Should the council not accept these representations, please provide:
* the complete Traffic Management Order applicable to George Lane (C);
* all Civil Enforcement Officer notes;
* all photographs;
* the RingGo payment audit relied upon by the council;
* confirmation that the council has actively considered the exercise of discretion rather than applying a blanket policy.
Accordingly, I respectfully request that the Notice to Owner and the Penalty Charge Notice be cancelled.
Yours faithfully,
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Civil penalty charge notices (Councils, TFL and so on) / Re: Redbridge Council, Parked without payment, George Lane,
« on: July 09, 2026, 01:29:13 pm »
Got the NTO today. Appreciate next steps on this please.
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Civil penalty charge notices (Councils, TFL and so on) / Re: Redbridge, code 47j stopped on a restricted bus stop, Clayhall Avenue
« on: July 07, 2026, 02:05:40 pm »
I have submitted the representation now.
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Civil penalty charge notices (Councils, TFL and so on) / Re: Redbridge, code 47j stopped on a restricted bus stop, Clayhall Avenue
« on: July 07, 2026, 12:56:44 pm »
After further discussions with @Hippocrates, here is the final simplified version of the appeal
"I put you to strict proof that this bus stop is legally signed. If you are unable to do so, please cancel the PCN."
"I put you to strict proof that this bus stop is legally signed. If you are unable to do so, please cancel the PCN."
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Civil penalty charge notices (Councils, TFL and so on) / Re: Redbridge, code 47j stopped on a restricted bus stop, Clayhall Avenue
« on: July 07, 2026, 11:14:45 am »The first thing to say is that Redbridge will reject your reps, as the video shows a contravention, and they like to have the money as well, even if just the discount amount. So you'd have to take them to London Tribunals, and I have to say I don't think the odds are good, but wait and see what the others say.Are there any serious errors remaining in the PCN ? I can see one of the previous ones has been fixed from the PCN
Of course the PCN, and also the relevant Redbridge web pages may show serious errors which could be used for a technical appeal on the basis of a procedural impropriety, as the PCN is under the Traffic Managment Act 2004, where this is a statutory appeal ground. Such appeals have no connection to the actual contravention.
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Civil penalty charge notices (Councils, TFL and so on) / Re: Redbridge, code 47j stopped on a restricted bus stop, Clayhall Avenue
« on: July 07, 2026, 11:12:18 am »You cannot require them to consider each point: HALTON CASE.
https://www.bailii.org/ew/cases/EWHC/Admin/2023/303.pdf
I have reworded the appeal slightly
DRAFT BELOW
I make representations on the ground that the alleged contravention did not occur. The vehicle waited for approximately twenty seconds while the vehicle ahead manoeuvred out of the adjacent parking bay across its path, and parked in that bay the moment it was clear; it was prevented from proceeding by circumstances beyond the driver’s control (Schedule 7, Part 6, paragraph 4(2)(b), TSRGD 2016). No bus was present or impeded.
The burden is on the Council to establish the contravention. There must be a yellow stopping plate, but there isn’t. The stills served do not show the signage relied upon or the full extent of the clearway marking; please provide that evidence, together with the full, unedited footage from camera 3341 covering two minutes either side of the alleged contravention.
Alternatively, given the momentary and harmless nature of the halt, I ask the Council to exercise the discretion referred to on the face of the Notice and cancel the PCN.
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Civil penalty charge notices (Councils, TFL and so on) / Re: Redbridge, code 47j stopped on a restricted bus stop, Clayhall Avenue
« on: July 05, 2026, 08:30:04 am »
Here is the revised letter. Given the signage is there (albeit a bit small), should point 1 still be included ?
Dear Sir or Madam,
I make representations against this PCN on the statutory ground that the alleged contravention did not occur.
The bus stop at this location is not signed with any upright “no stopping” plate. I put the Council to strict proof that the restriction was lawfully in place and properly indicated at the material time. Please provide:
1. evidence of the upright signage at this bus stop as at 16 June 2026;
2. contemporaneous photographs showing that the road marking conformed to diagram 1025.1 of the TSRGD 2016 and was complete, unobscured and in good repair;
3. the operative hours of the restriction and the legal basis on which contravention 47j is enforced at this location; and
4. the full, unedited CCTV footage from camera 3341.
If the Council is unable to evidence each of the above, please cancel the PCN. I require each point raised in these representations to be addressed in any Notice of Rejection.
Yours faithfully,
Dear Sir or Madam,
I make representations against this PCN on the statutory ground that the alleged contravention did not occur.
The bus stop at this location is not signed with any upright “no stopping” plate. I put the Council to strict proof that the restriction was lawfully in place and properly indicated at the material time. Please provide:
1. evidence of the upright signage at this bus stop as at 16 June 2026;
2. contemporaneous photographs showing that the road marking conformed to diagram 1025.1 of the TSRGD 2016 and was complete, unobscured and in good repair;
3. the operative hours of the restriction and the legal basis on which contravention 47j is enforced at this location; and
4. the full, unedited CCTV footage from camera 3341.
If the Council is unable to evidence each of the above, please cancel the PCN. I require each point raised in these representations to be addressed in any Notice of Rejection.
Yours faithfully,