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#Post#: 124472--------------------------------------------------
Re: Redbridge - Grove Park Code 11u - Parked without payment of
parking charge
DIR By: Glitch
Date: July 13, 2026, 3:58 am
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Attempt 3.
I've picked up on Sec of State guidelines for TMA 2004 in a
similar case - exercising discretion.
I guess an Adjudicator will say they only look at law not
guidelines, but these reps are to Redbridge.
Redbridge Representations PCN AF14295221
I submit this representation for PCN AF14295221 on the grounds
that the alleged contravention did not occur and that the
Penalty charge exceeded the amount applicable in the
circumstances of the case.
On 12th May 2026 at 14:16 I parked in Grove Park. I opened the
Ringo App and out of the three nearby codes suggested it did not
include 6081220 as displayed on the nearest plate. I therefore
had to manually type the code. I started a free, 1 hour parking
session at 14:16.
I returned to my vehicle at approx. 14:35 to find a PCN on my
windscreen. It had been issued 3 minutes after I had booked the
parking session.
When I checked the current Ringo session I discovered I had
booked the wrong Redbridge location, code 6081228, instead of
6081220. The last digit being different and adjacent on an
iPhone keypad.
The contravention code on the PCN is 11u - Parked without
payment of the parking charge. I assert that the contravention
did not occur because there is zero payment due for the first
hour of parking. I paid zero.
The Secretary of State guidelines for the Traffic Management Act
2004 clearly states that:
“An authority has a discretionary power to cancel a PCN at any
point throughout the CPE process. It can do this even when an
undoubted contravention has occurred if the authority deems it
to be appropriate in the circumstances of the case. Under
general principles of public law, authorities have a duty to act
fairly and proportionately and are encouraged to exercise
discretion sensibly and reasonably and with due regard to the
public interest. “
“Enforcement authorities have a duty not to fetter their
discretion, so should ensure that PCNs, NtOs, leaflets and any
other advice they give do not mislead the public about what they
may consider in the way of representations. They should approach
the exercise of discretion objectively and without regard to any
financial interest in the penalty or decisions that may have
been taken at an earlier stage in proceedings.
Authorities should formulate (with advice from their legal
department) and then publish their policies on the exercise of
discretion. They should apply these policies flexibly and judge
each case on its merits. An enforcement authority should be
ready to depart from its policies if the particular
circumstances of the case warrant it.”
The penalty charge has clearly exceeded the amount applicable. A
£110 penalty cannot be relevant for a minor location code error
for an hour free parking.
The back office staff at Redbridge have not exercised their
discretion at the informal stage. The Secretary of State
guidelines have been ignored. They have clearly not acted faired
and proportionately, with due regard to the public interest and
appear more focused on raising revenue through a
disproportionate financial penalty.
Addiitionally, the phone app is not user friendly and
susceptible to user errors, especially for older people. The
geolocation for location code 6081220 (Wanstead High Street) is
inconsistent and does not show as a nearby location in Grove
Park, a turning off Wanstead High Street. The lack of
geolocation assistance means the entry of s 7 digit code on a
small phone screen.
There are London Tribunal cases that support my assertion that a
zero fee is not a payment and RingGo’s inaccuracies are unfair.
In London Tribunal Case 2250307301 the adjudicator allowed an
appeal because you cannot fail to make a payment if it is free.
London Tribunal Case 2250307301 – the adjudicator allowed an
appeal against Redbridge, saying "It seems to me that a PCN
cannot be issued for a failure to “pay” for something which is
free, and for which, by definition, no payment is required. The
Appeal is allowed on this ground and it is unnecessary to
examine the other issued raised by the Appellant."
For the reasons stated above I believe that this PCN should be
cancelled.
#Post#: 124683--------------------------------------------------
Re: Redbridge - Grove Park Code 11u - Parked without payment of
parking charge
DIR By: Glitch
Date: July 14, 2026, 1:33 pm
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Submitted.
#Post#: 126158--------------------------------------------------
Re: Redbridge - Grove Park Code 11u - Parked without payment of
parking charge
DIR By: Glitch
Date: July 29, 2026, 5:25 am
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Redbridge website is rubbish.
Didn't get a confirmation of submission of the formal
Representation.
Said 28 days have expired or PCN has been paid - Both wrong -
can't see the status.
Checked the payment amount - initially £110. Kept checking to
ensure they didn't issue a charge certificate.
No Rejection yet but I suspect it's in the post because amount
has dropped to £55 - re-offering the discount?
Assuming rejection is coming I'm going to Tribunal with this
one.
Adjudicators are usually tied to the law. mandatory regulations
and correct process.
It's pretty clear to me that Redbridge disregard the Sec of
State guidelines.
I assume the Adjudicator will take the line that it's guidelines
and not enforceable, or will they consider 'the general
principals of public law'?
However, if Redbridge ignore that part of the Reps, is it a
failure to consider?
#Post#: 126202--------------------------------------------------
Re: Redbridge - Grove Park Code 11u - Parked without payment of
parking charge
DIR By: Glitch
Date: July 29, 2026, 11:28 am
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As expected.
They have not considered the Sec of State guidelines (because
they almost always ignore them)
They have not considered the geolocation deficiency.
They have not justified the £55/£110 cost of the punishment for
a genuine error.
I am not arguing that the PCN should not have been been issued.
I am asking for fairness, common sense, follow Sec of State
guidelines, plus it's free parking!
I will ask for a refund for the other session!
I will take lucky dip with the £0 'payment' and the geolocation
stuff.
How big a deal is the Sec of State guidelines - I'm taking them
as more important that a road markings could/should
recommendation.
HTML https://i.ibb.co/WNYDfs6L/Document-2026-07-29-171605.jpg
HTML https://ibb.co/V0PHT3ts
HTML https://i.ibb.co/4nkFSHGK/Document-2026-07-29-171704-2.jpg
HTML https://ibb.co/Kpn5sJkb
#Post#: 127224--------------------------------------------------
Re: Redbridge - Grove Park Code 11u - Parked without payment of
parking charge
DIR By: Glitch
Date: August 8, 2026, 4:39 am
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Tribunal appointment in February??? :o
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