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       #Post#: 13086--------------------------------------------------
       Re: Code 62 - for parking on Driveway with all 4 wheels
   DIR By: Chaseman
       Date: December 30, 2023, 9:09 am
       ---------------------------------------------------------
       The NTO repeats the wording of the original PCN and their
       rejection of the informal challenge "one or more wheels on or
       over any part of the road other than the carriageway" and the
       photos show this clearly not to be the case. Are the photos
       yours or the Council's? Either way I cannot see how you can fail
       to succeed with an appeal either against NTO or at LT if the
       Council continues to play dumb.
       #Post#: 13087--------------------------------------------------
       NTO Stage: Code 62 - for parking on Driveway with all 4 wheels
   DIR By: Adam_a2z
       Date: December 30, 2023, 9:22 am
       ---------------------------------------------------------
       The photos are the council's, taken by the CEO.
       #Post#: 13090--------------------------------------------------
       Re: NTO Stage: Code 62 - for parking on Driveway with all 4
       wheels
   DIR By: Chaseman
       Date: December 30, 2023, 9:39 am
       ---------------------------------------------------------
       --- Quote from: Adam_a2z link ---
       >
       > The photos are the council's, taken by the CEO.
       >
       --- End Quote ---
       So much the better. The Council's own photos show the car with
       all wheels on the driveway and they are claiming that one or
       more is on the footpath. This is just Kafkaesque. Or Byzantine.
       Choose your own adjective.
       #Post#: 13226--------------------------------------------------
       Re: Code 62 - for parking on Driveway with all 4 wheels
   DIR By: ivanleo
       Date: January 2, 2024, 2:56 pm
       ---------------------------------------------------------
       Here you go:
       [indent]
       Dear London Borough of Redbridge,
       I challenge liability on the ground that the alleged
       contravention did not occur. As the CEO's own photos show, the
       conduct alleged on the face of the PCN did not occur because all
       the wheels are on a private driveway and not on the highway, it
       follows that the PCN must be cancelled.
       Yours faithfully,
       [/indent]
       #Post#: 13230--------------------------------------------------
       Re: Code 62 - for parking on Driveway with all 4 wheels
   DIR By: fraser.mitchell
       Date: January 2, 2024, 5:25 pm
       ---------------------------------------------------------
       --- Quote from: cp8759 link ---
       >
       > Here you go:
       >
       > [indent]
       > Dear London Borough of Redbridge,
       >
       > I challenge liability on the ground that the alleged
       contravention did not occur. As the CEO's own photos show, the
       conduct alleged on the face of the PCN did not occur because all
       the wheels are on the carriageway, it follows that the PCN must
       be cancelled.
       >
       > Yours faithfully,
       > [/indent]
       >
       --- End Quote ---
       On the property of the owner, surely ?
       #Post#: 13232--------------------------------------------------
       Re: Code 62 - for parking on Driveway with all 4 wheels
   DIR By: Chaseman
       Date: January 2, 2024, 7:49 pm
       ---------------------------------------------------------
       --- Quote from: Incandescent link ---
       >
       > [quote author=cp8759 link=topic=1069.msg13226#msg13226
       date=1704229017]
       > Here you go:
       >
       > [indent]
       > Dear London Borough of Redbridge,
       >
       > I challenge liability on the ground that the alleged
       contravention did not occur. As the CEO's own photos show, the
       conduct alleged on the face of the PCN did not occur because all
       the wheels are on the carriageway, it follows that the PCN must
       be cancelled.
       >
       > Yours faithfully,
       > [/indent]
       >
       --- End Quote ---
       On the property of the owner, surely ?
       [/quote]
       Quite so. Or "none of the wheels are on the footpath".
       #Post#: 13235--------------------------------------------------
       Re: Code 62 - for parking on Driveway with all 4 wheels
   DIR By: mrmustard
       Date: January 3, 2024, 2:54 am
       ---------------------------------------------------------
       I agree that the PCN is 100% wrong but if the car is usually
       parked like that it is inconsiderate to the blind, to wheelchair
       and power chair users, to families with buggies etc. Time to buy
       a shorter car or park elsewhere.
       #Post#: 14091--------------------------------------------------
       Notice of Rejection - Code 62 - for parking on Driveway with all
       4 wheels
   DIR By: Adam_a2z
       Date: January 21, 2024, 10:09 am
       ---------------------------------------------------------
       Hi All.
       Please see attached Notice of Rejection of Representation.
       Please advice if I shall proceed to The Tribunal and on what
       grounds?
       [attachment deleted by admin]
       #Post#: 14104--------------------------------------------------
       Re: Code 62 - for parking on Driveway with all 4 wheels
   DIR By: ivanleo
       Date: January 21, 2024, 12:33 pm
       ---------------------------------------------------------
       Well the obvious ground to carry on is that none of the wheels
       were over the footpath, what you really need to decide is
       whether you'd like to appeal on your own or whether you'd like
       one of us to represent you, if you'd like me to do so please
       drop me a PM.
       Obviously the outcome cannot be guaranteed, but we only
       recommend appealing if you're more likely than no to win the
       appeal.
       #Post#: 14105--------------------------------------------------
       Re: Code 62 - for parking on Driveway with all 4 wheels
   DIR By: H C Andersen
       Date: January 21, 2024, 12:37 pm
       ---------------------------------------------------------
       Your parking is exactly the nuisance which the law is designed
       to prevent and a purposive interpretation would find that you
       were in contravention.
       So, would it be permissible for an adjudicator to disregard the
       words 'any person who causes or permits any vehicle to be parked
       in Greater London with one or more wheels on or over any part of
       a road other than a carriageway..' in order to deliver the
       intention of the legislation which is to prevent motorists
       obstructing pedestrians' right to pass freely and preventing
       damage to the footway?
       I think you could succeed, but IMO you need to reword your
       appeal which almost invited the response you've received.
       As a cautionary word on the intention of the legislation aspect,
       read s.15(4) which refers to authorities' power to disapply the
       prohibition and which does not refer to 'wheels' on or over but
       'a vehicle on or over'.
       Perhaps...'I can see that the boot of my car extended over the
       footway which was not my intention and for which I apologise,
       [if true...I must not have pulled forward fully as I usually
       do...' But not: none of my wheels was on the footway so I can
       park this way as I've done since time immemorial'! A little OTT
       I grant you, but don't push your luck by simply quoting
       'wheels'.
       Perhaps there's a body of adjudication decisions which would
       allow the adjudicator to take a strict view of the meaning and
       application of 'wheels'.
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