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I have submitted the challenge today to Redbridge.
Many thanks @Hippocrates

@Hippocrates
@stamfordman

I have drafted an appeal below.  Please review and provide feedback

Formal Representation Against PCN – Redbridge Council

Dear Sir/Madam,

I wish to make formal representations against the above Penalty Charge Notice.

The alleged contravention did not occur. The parking charge for the vehicle was in fact paid via the RingGo app for the relevant parking session and location. Unfortunately, an honest and inadvertent error was made when entering the vehicle registration number within the application, resulting in payment being linked to an incorrect registration.

Importantly, the council suffered no financial loss whatsoever, as the appropriate parking fee was paid in full for the relevant period. This was clearly a genuine keying error and not an attempt to avoid payment. In these circumstances, enforcing a penalty charge of £110 is wholly disproportionate and contrary to the principles of fairness and reasonable public administration.

I would respectfully ask the council to exercise discretion and cancel the PCN on this occasion.

Further, I note that the PCN appears to contain procedural defects and may not comply with the requirements of the applicable legislation.

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, Schedule 2 paragraph 2(d) of 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 the penalty charge must be paid within the period of 28 days beginning with the date on which the alleged contravention occurred”.

The PCN therefore appears to rely on outdated wording derived from the superseded 2007 regulations by referring to the date the notice was “served” rather than the date the alleged contravention “occurred”.

In addition, the PCN does not appear to adequately convey the information required under Regulation 3 of The Civil Enforcement of Road Traffic Contraventions (Representations and Appeals) (England) Regulations 2022, specifically regarding the recipient’s right to make representations before a Notice to Owner is served and the council’s duty to consider those representations.

Accordingly, I submit that the PCN is non-compliant and unenforceable.

Should the council nevertheless decide not to cancel the PCN, please treat this letter as a request for:

1. A full copy of the relevant Traffic Management Order relied upon;
2. Copies of all CEO notes and photographs;
3. Confirmation that the council has properly considered exercising discretion in light of the payment having been made.

I look forward to your confirmation that this PCN has been cancelled.

Yours faithfully,

There may be an error in the PCN or on the Redbridge website relate to payments for PCNs, but we await your PCN post on a different hosting site. 'Hippocrates' is good on this aspect, so hopefully he will post soon.

Please check now, do the images appear properly ?

The driver of the vehicle paid for the parking ticket using the RingGo app, but unfortunately selected the incorrect vehicle registration when making the payment. The parking fee was still paid in full, which makes this penalty extremely unfair and disproportionate.

Given that payment was made for the parking session, I would like to know whether there is any way to contest this notice, as it appears to be an honest mistake rather than an attempt to avoid payment.
<br> PCN Front <br>


<br> PCN back <br>


<br> Evidence of payment<br>


<br> Evidence of multiple cars in the Ringo Account<br>


<br>
Council Photos <br>








<br>
Google Street <br>
https://maps.app.goo.gl/jbq954hxcg7yW24K8

The ltd. grounds is not that strong an argument.

Ok. here is the revised appeal.  Would be great to get some guidance on what should be the sequence of the points - from most important to least ?

FORMAL APPEAL

I am appealing the above Penalty Charge Notice (PCN) on the statutory ground that the contravention alleged by the Authority did not occur. The PCN is invalid for the reasons outlined below.

⸻

1. INADEQUATE SIGNAGE – CONTRAVENTION CANNOT OCCUR

The signage for the pedestrian zone restriction is positioned at an excessive height and is not visible to drivers in the normal course of driving.

Supporting Video Evidence

I have submitted video footage recorded from the driver’s perspective while driving along the same route. The footage clearly demonstrates:
• The signs are mounted well above the driver’s natural line of sight.
• While navigating urban streets, a driver must focus on the road ahead, pedestrians, other vehicles, and junctions — not crane their neck upwards to search for signage.
• To read these signs, a driver would need to perform an unusual and unsafe manoeuvre, looking skywards, which is contrary to the principles of safe driving.

The Department for Transport’s Traffic Signs Manual emphasises that traffic signs must be placed at drivers’ eye level where possible and in positions where they are easily visible without distraction. These signs fail that standard.

As the driver could not reasonably be expected to see or read these restrictions while driving safely, the alleged contravention cannot be said to have occurred.

⸻

2. LACK OF PROPER CONSULTATION AND NOTICE

The pedestrian zone restrictions appear to have been recently implemented without adequate consultation or sufficient public notice to residents and local businesses.

I have used this route daily for over 10 years to access essential services and was unaware of any material changes to restrictions. The absence of proper notice meant I was unable to adjust my route in advance, making compliance impossible.

⸻

3. UNREASONABLE AND UNCLEAR “TERM-TIME ONLY” RESTRICTIONS

The restriction operates on a “term-time only” basis. This is:
• Unclear to the general public, who cannot be expected to know school term dates.
• Ambiguous given that different schools may have different calendars.
• Unfair to residents and regular users of the route, who are left guessing when restrictions apply.

Such uncertainty makes enforcement inappropriate and undermines the legitimacy of the restriction.

⸻

4. ESSENTIAL LOCAL ACCESS

On the date in question, I was accessing essential local services, including:
• The Post Office on Sydney Road
• Local businesses, including the barber shop on Perrymans Farm Road

These restrictions effectively block access to essential destinations during normal daytime hours, which is unreasonable given the area’s mixed residential and commercial use.

⸻

5. DISPROPORTIONATE ENFORCEMENT

I received two identical PCNs within 40 minutes. This is indicative of overzealous enforcement rather than a genuine attempt to manage traffic or improve pedestrian safety.

This suggests the primary motivation may be revenue generation, which is not a lawful purpose for traffic restrictions under the relevant legislation.

⸻

6. COLLATERAL CHALLENGE: DEFECTIVE PCN

Under Para. 4 (8 ) (v) of the London Local Authorities and Transport for London Act 2003, a PCN must state:

“…that, if the penalty charge is not paid before the end of the 28-day period, an increased charge may be payable.”

The PCN issued to me fails to comply with this statutory requirement and instead states:

“If you fail to pay the Penalty Charge or make representations before the end of a period of 28 days beginning with the date of service of this notice, an increased charge of £240 may be payable.”

This is defective because:
• It conflates two distinct statutory periods using the word “or”, creating ambiguity.
• It wrongly refers to “date of service” rather than the required “date of notice”.
• It fails to clearly and correctly convey when an increased charge applies.

This amounts to procedural impropriety and renders the PCN unenforceable.

⸻

REQUESTED OUTCOME

I respectfully request that this Penalty Charge Notice be cancelled in full on the basis that:
1. The alleged contravention did not occur due to inadequate and unsafe signage.
2. The PCN itself is defective and non-compliant with statutory requirements.
3. The circumstances demonstrate no deliberate contravention but rather a failure of proper signage, consultation, and notice.

⸻

SUPPORTING EVIDENCE
• Video footage showing the driver’s perspective and poor signage visibility
• Photographic evidence of high-mounted, obscured signs
• Map and receipts showing essential local service destinations
• Extracts from the London Local Authorities and Transport for London Act 2003

Submitted the following reps for both PCNs:


"The contravention did not occur because:

1.  The signage pertaining to term time is proscribed and there are no warning signs.
2.  Your website as per the attached screenshots fetters discretion and limits to one ground of representation which flies in the face of the law and the PCN thereby causing confusion.

In light of the above, please cancel."

I can possibly use your point 2 in my appeal as well.  Have sent you a DM

https://www.ftla.uk/the-flame-pit/moving-traffic-pcns-missing-mandatory-information-the-london-local-authorities-a/msg86653/#msg86653

This is an excellent point, and I will add this to the appeal as extra ammunition.  I will also take another video in landscape mode today.  I still don't have clarity on which option to select as the reason for the appeal while submitting it as the procedural impropriety option is missing.

That would be a killer appeal, but it needs to be watertight.

Didn't understand the point about watertight ? What else can be added here ?