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#Post#: 126595--------------------------------------------------
Subhired my car to a car rental company.
DIR By: Pixel7
Date: August 2, 2026, 1:01 pm
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Hi all.
I gave my car to a car rental company who hired the car out to a
third party.
due to this i have received a few pcn's from tfl and other
london councils as well private car parks.
when appealing i unknowingly appealed as the hire company and
uploaded only the agreement between the hire company and the
third party client.
turns out the hire agreement was missing some time stamps of
when the hire started and ended. due to this tfl and camden
council have rejected transferring of liability to the third
party hirer.
i am now as a last resort appealing via the london tribunal and
have drafted the following with the help of ai.
i just wanted to double check this double check this by someone.
______________________________________________________________________________________________________________________________________________________________
Updated Appeal Text for the Adjudicator
Subject: Formal Appeal Against PCN [Insert PCN Number] –
Rectification of Representation Error and Proof of Custody Chain
I am appealing this Penalty Charge Notice as the Registered
Keeper [source: 1]. I object to Transport for London’s (TfL)
decision to hold me liable, as the vehicle was entirely out of
my physical custody and operational control during the material
time.
1. Clarification of the Initial Representation
I wish to clarify an administrative error made during the
initial representations to TfL. Upon receiving the notice, I
unknowingly submitted the appeal under the name of my vehicle
management operator, , using the documentation they provided me
[source: 1, 4]. This prompted TfL to reject the representation
and demand a letter from an accountant or solicitor to verify
corporate authority. I am now lodging this formal tribunal
appeal in my proper legal capacity as the individual Registered
Keeper, which renders TfL’s demand for third-party professional
certification completely redundant.
2. Evidential Break in the Chain of Custody
The enclosed documentation provides an absolute, uninterrupted
paper trail showing I had no access to the vehicle during the
contravention dates in June 2026:
Primary Commercial Tier: On 8th June 2026, I entered into a
formal contract transferring "full operational custody,
management, and commercial control" of vehicle LS19 YXP to
Sainex Motor Group Ltd [source: 1].
Secondary Consumer Tier: subsequently sub-hired the vehicle to
an end-user, , for the specific period of 09/06/2026 to
30/06/2026 [source: 5]. All alleged contraventions occurred
firmly within this window.
3. Technical Defect in Sub-Hire Agreement
The consumer hire agreement lists the correct dates but omits
the exact start and end times [source: 5]. Because the
Congestion Charge is a time-restricted scheme, a consumer hire
contract must feature precise timestamps to legally shift
liability to the driver under Schedule 2 of the Road Traffic
(Owner Liability) Regulations 2000. Because the sub-hire
contract is technically flawed, TfL cannot hold the end-driver
liable. However, their lawful recourse is to hold the
intermediate commercial operator (S liable as the primary
corporate custodian of the asset [source: 1], rather than
penalising the remote registered keeper.
I respectfully request that the Adjudicator allow this appeal
and direct TfL to cancel this notice against me.
#Post#: 126607--------------------------------------------------
Re: Subhired my car to a car rental company.
DIR By: tincombe
Date: August 2, 2026, 3:25 pm
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It's nonsense.
Starting at the beginning, what are your grounds of appeal?
If they are they you are a 'vehicle hire company' and that the
vehicle was hired under a 'hiring agreement' to someone who had
signed a 'statement of liability', then we know where we are.
So, are you a vehicle hire company and does your agreement with
the car rental company include the following mandatory
elements(as regards penalty charges) and did they sign a
statement of liability and have these been presented in
evidence?
HTML https://www.legislation.gov.uk/uksi/2000/2546/schedule/2/made
If not, then you will not succeed under the grounds of hiring
etc.
But as we don't know your grounds of appeal, then .......!
From what I've seen so far in many posts 'the help of AI' is an
oxymoron!
It is irrelevant, except from the point of view of
misrepresentation(read the statement of truth you signed), what
the 'car rental company's' Ts and Cs are, they are not the
registered keeper and therefore by default not the person liable
for penalties.
But all might not be lost. If, as seems very likely, you fail at
adjudication you would have at least attempted to mitigate your
losses and therefore if you were to sue the car rental company,
you would have at least done your bit.
#Post#: 126609--------------------------------------------------
Re: Subhired my car to a car rental company.
DIR By: Pixel7
Date: August 2, 2026, 3:59 pm
---------------------------------------------------------
--- Quote from: tincombe link ---
>
> It's nonsense.
>
> Starting at the beginning, what are your grounds of appeal?
>
> If they are they you are a 'vehicle hire company' and that the
vehicle was hired under a 'hiring agreement' to someone who had
signed a 'statement of liability', then we know where we are.
>
> So, are you a vehicle hire company and does your agreement
with the car rental company include the following mandatory
elements(as regards penalty charges) and did they sign a
statement of liability and have these been presented in
evidence?
>
>
HTML https://www.legislation.gov.uk/uksi/2000/2546/schedule/2/made
>
> If not, then you will not succeed under the grounds of hiring
etc.
>
> But as we don't know your grounds of appeal, then .......!
>
> From what I've seen so far in many posts 'the help of AI' is
an oxymoron!
>
> It is irrelevant, except from the point of view of
misrepresentation(read the statement of truth you signed), what
the 'car rental company's' Ts and Cs are, they are not the
registered keeper and therefore by default not the person liable
for penalties.
>
> But all might not be lost. If, as seems very likely, you fail
at adjudication you would have at least attempted to mitigate
your losses and therefore if you were to sue the car rental
company, you would have at least done your bit.
>
--- End Quote ---
Im personally not a hire company. I got into an agreement with a
hire company who hire out the car and split the profits.
The grounds of appealing i guess would be that i wasnt in
posession of the car at the time of the contravention.
the car hire agreement between the car rental company and the
customer does have start and end dates but not times.
#Post#: 126620--------------------------------------------------
Re: Subhired my car to a car rental company.
DIR By: stamfordman
Date: August 2, 2026, 5:24 pm
---------------------------------------------------------
The owner is liable though. Was there any paperwork or
discussion about PCNs, NIPs etc with this arrangement?
#Post#: 126625--------------------------------------------------
Re: Subhired my car to a car rental company.
DIR By: Pixel7
Date: August 2, 2026, 5:42 pm
---------------------------------------------------------
--- Quote from: stamfordman link ---
>
> The owner is liable though. Was there any paperwork or
discussion about PCNs, NIPs etc with this arrangement?
>
--- End Quote ---
this is my contract with the car rental company.
HTML https://postimg.cc/y3dWGDwx
they have in turn their own car hire agreement with the hire who
incurred the contraventions.
#Post#: 126632--------------------------------------------------
Re: Subhired my car to a car rental company.
DIR By: fraser.mitchell
Date: August 2, 2026, 6:24 pm
---------------------------------------------------------
It seems to me that despite your agreement with the hire
company, you are still liable, as the owner of the car, and you
hold the V5C.
Best to test your case at adjudication.
#Post#: 126633--------------------------------------------------
Re: Subhired my car to a car rental company.
DIR By: Pixel7
Date: August 2, 2026, 6:26 pm
---------------------------------------------------------
--- Quote from: Incandescent link ---
>
> It seems to me that despite your agreement with the hire
company, you are still liable, as the owner of the car, and you
hold the V5C.
>
> Best to test your case at adjudication.
>
--- End Quote ---
There are 40 odd pcns.
Is it worth appealing at the tribunal or should i cut my losses
and chase the rental company
#Post#: 126649--------------------------------------------------
Re: Subhired my car to a car rental company.
DIR By: tincombe
Date: August 3, 2026, 3:27 am
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I gave my car to a car rental company who hired the car out to a
third party.
due to this i have received a few pcn's from tfl and other
london councils as well private car parks.
when appealing i unknowingly appealed as the hire company and
uploaded only the agreement between the hire company and the
third party client.
But Clause 9 of your agreement states..
'The company shall use reasonable efforts to recover from
renters any fines....."
So what have these efforts been? You have kept them informed,
haven't you, and them you??
And ultimately:
..'The Company shall be responsible for any fees,
penalties.....'
I think you should separate out the private parking charges and
post in that forum before potentially incurring default
judgments, CCJs and visits from bailiffs.
As regards the public penalties, we've no idea where you are
with these. There's a 28-day limit for registering an appeal at
the Environment and Traffic Adjudicators and you'll need to deal
with the NORs in time order. Where any are still within a
reduced payment period you might find it easier to pay these
otherwise any claim you have against the Company might be
reduced because you did not use your best endeavours to mitigate
your losses.
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