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       #Post#: 16725--------------------------------------------------
       Haringey 52(M) PCN
   DIR By: Vike
       Date: March 3, 2024, 1:12 pm
       ---------------------------------------------------------
       Hi all, my first PCN in years, my last one was appealed and won
       with the help of Pepipoo. I have used this road for over 40
       years but there has been a restriction put in place by Haringey
       recently which I admit I completely failed to notice. A short
       stretch of this road has recently had a No Vehicles restriction
       put in place by Haringey definitely since Feb 2022 as it does
       not appear on Google Maps. I don't know how I missed it,
       probably as I have used this road for so long without this
       restriction. In fact when I went back to check what the PCN was
       all about I was only there for 15 minutes and saw three cars go
       through and that was on a Sunday. In my mind this was put in
       place for revenue.
       I admit I went through the two planters and failed to spot the
       sign. Here is the link to the PCN:
  HTML https://imgur.com/a/RiIFm3T
       My Question to the forum is:
       1) Isn't the council photo supposed to show the signage of the
       restriction together with my VRN so that I know exactly what I
       failed to comply with, rather than just the enigmatic 52(M)
       code? And
       2) Is not the PCN supposed to tell the owner that if they make
       an informal appeal and fail, they still have ANOTHER 14 days to
       pay the discounted penalty from the date of the rejection?
       Many thanks to all who reply.
  HTML https://i.imgur.com/vG1I14U.png
  HTML https://i.imgur.com/dghDKEn.png
       [attachment deleted by admin]
       #Post#: 16727--------------------------------------------------
       Re: Haringey 52(M) PCN
   DIR By: Hippocrates
       Date: March 3, 2024, 1:23 pm
       ---------------------------------------------------------
       The PCN is unenforceable as per other threads.  They cannot
       serve a charge certificate 28 days from the date of notice. Back
       later.
       #Post#: 16728--------------------------------------------------
       Re: Haringey 52(M) PCN
   DIR By: fraser.mitchell
       Date: March 3, 2024, 1:33 pm
       ---------------------------------------------------------
       --- Quote ---
       > 1) Isn't the council photo supposed to show the signage of the
       restriction together with my VRN so that I know exactly what I
       failed to comply with, rather than just the enigmatic 52(M)
       code? And
       --- End Quote ---
       There is no legal requirement for any photographs at all on the
       PCN. Any photographs you might see on their website are stills
       from the video. It is commonplace, though, to see photos on the
       PCN of the car at the relevant location, but often the camera is
       not positioned to show the sign and the car going past it.
       --- Quote ---
       > 2) Is not the PCN supposed to tell the owner that if they make
       an informal appeal and fail, they still have ANOTHER 14 days to
       pay the discounted penalty from the date of the rejection?
       --- End Quote ---
       The reoffer of the discount when rejecting informal challenges
       is not a legal right, funnily enough, but most councils to
       commit to re-offering it, but there is no legal requirement to
       put anything about this on a Regulation 9 PCN (one served to car
       or driver at the roadside), nor on a Regulation 10 PCN, (one
       served to the keeper on the V5 )
       However, your's is a postal PCN, so there is only one
       opportunity to submit representations. These are formal reps,
       there is no informal challenge stage.  The discount period
       remains extant until its end date, but some councils play
       hard-ball and refuse to re-offer the discount if their rejection
       is past the discount end-date. Most councils do, howver,
       re-offer the discount. If they didn't, they'd make a rod for
       their own back, because with no discount re-offer, it is then a
       total no-brainer to take the council to adjudication, the
       penalty does not increase, nor are there any additional costs.
       The council, though, have to prepare an evidence pack.
       #Post#: 16729--------------------------------------------------
       Re: Haringey 52(M) PCN
   DIR By: Hippocrates
       Date: March 3, 2024, 1:34 pm
       ---------------------------------------------------------
       Dear London Borough of Haringey,
       I bring a collateral challenge against this PCN, on the ground
       that it does not comply with the mandatory requirement of
       section 4(8)(a)(v) of, and paragraph 5(2)(a) of Schedule 1 to
       the London Local Authorities and Transport for London Act 2003.
       It follows that the penalty charge notice is invalid and must be
       cancelled.
       Yours faithfully,
       **************
  HTML https://www.ftla.uk/civil-penalty-charge-notices-(councils-tfl-and-so-on)/pcn-haringey-council-52(m)-failing-to-comply-with-a-prohibition-on-certain-types/msg9338/#msg9338
       This case was won as they adduced no evidence.  2230567864
       Costs application to follow.
       #Post#: 16734--------------------------------------------------
       Re: Haringey 52(M) PCN
   DIR By: Vike
       Date: March 3, 2024, 3:00 pm
       ---------------------------------------------------------
       Hi OP here. Thank you all for your replies.
       If I have understood correctly, you say that I should appeal on
       the grounds that the PCN does not comply with the mandatory
       requirement of section 4(8)(a)(v) of, and paragraph 5(2)(a) of
       Schedule 1 to the London Local Authorities and Transport for
       London Act 2003.
       By looking at your link to the other thread, I understand this
       to be that they said that:
       "If the Penalty Charge is not paid before the end of the period
       of 28 days beginning with the date of this notice, an increased
       charge £195.00 may be payable. We may then send you a Charge
       Certificate seeking payment of this increased amount."
       Please can you explain to a newbie, why that does not comply
       with the mandatory requirement of section 4(8)(a)(v) of, and
       paragraph 5(2)(a) of Schedule 1 to the London Local Authorities
       and Transport for London Act 2003. Is it that they should have
       said the date of SERVICE of this notice? Or is it something
       else.
       My other concern, now is that if they reject, which knowing
       Haringey is very likely, there is no guarantee that the reduced
       penalty will still apply.
       Thanks again for the help.
       #Post#: 16749--------------------------------------------------
       Re: Haringey 52(M) PCN
   DIR By: Hippocrates
       Date: March 4, 2024, 4:01 am
       ---------------------------------------------------------
       [member=1318]Vike[/member].  Please trust us and no worries for
       asking. We all started in this game from nothing.  I use the
       epithet "game" deliberately because this is what councils rely
       on - peoples' inexperience and fears re the discount.
       The issue, itself, truncates the period in which a Charge
       Certificate may be served and the Tribunal is consistent in its
       decisions on this legal point.  They can only serve a C.C. 28
       days from the date of service.
       cpa8759, Mr Mustard and I have won all our cases on this issue.
       Just keep going. If they continue, I offer to represent you for
       free.
       In my opinion, the legal argument is incontrovertibly correct
       thus making the PCN substantially non-complaint.
       #Post#: 16753--------------------------------------------------
       Re: Haringey 52(M) PCN
   DIR By: Vike
       Date: March 4, 2024, 5:19 am
       ---------------------------------------------------------
       Thank you so much, Hippocrates. I know that councils play the
       game, with the expectation that the accused would give up and
       pay, but I'm now, myself wondering if the time to go to Tribunal
       and the stress involved is worth it for £65. May I ask whether,
       if this went to Tribunal, I would need to go in person? I am
       still working and am already on a warning for too much leave of
       absence.What are the chances of winning on a remote appeal at
       Tribunal?
       #Post#: 16764--------------------------------------------------
       Re: Haringey 52(M) PCN
   DIR By: taffer87
       Date: March 4, 2024, 6:14 am
       ---------------------------------------------------------
       --- Quote from: Vike link ---
       >
       > Thank you so much, Hippocrates. I know that councils play the
       game, with the expectation that the accused would give up and
       pay, but I'm now, myself wondering if the time to go to Tribunal
       and the stress involved is worth it for £65. May I ask whether,
       if this went to Tribunal, I would need to go in person? I am
       still working and am already on a warning for too much leave of
       absence.What are the chances of winning on a remote appeal at
       Tribunal?
       >
       --- End Quote ---
       you can do a telephone hearing - also if you are being offered
       representation for free by experienced members then you should
       take it as will reduce your workload significantly and you can
       if you choose even not attend the actual hearing by phone. Of
       course, no one can guarantee anything but this seems as close to
       that as possible with a clear legal error which has been tested
       at the Tribunal many times already.
       #Post#: 16769--------------------------------------------------
       Re: Haringey 52(M) PCN
   DIR By: Hippocrates
       Date: March 4, 2024, 6:47 am
       ---------------------------------------------------------
       --- Quote from: Vike link ---
       >
       > Thank you so much, Hippocrates. I know that councils play the
       game, with the expectation that the accused would give up and
       pay, but I'm now, myself wondering if the time to go to Tribunal
       and the stress involved is worth it for £65. May I ask whether,
       if this went to Tribunal, I would need to go in person? I am
       still working and am already on a warning for too much leave of
       absence.What are the chances of winning on a remote appeal at
       Tribunal?
       >
       --- End Quote ---
       We are not at Tribunal time as they need to reply first.  I
       would attend in person and you by phone. As stated, in the other
       case they rejected but dodged the issue and filed no evidence.
       A costs application has just been filed this morning for wasting
       everyone's time.
       Bexley and Bromley have similar issues and one was won by me a
       few weeks ago.
       ************************
       Revised draft:
       Dear Haringey Council
       Ref: PCN ZN11391338                VRM  LP16JDK
       
       I make the following representations against the said PCN.
       1. I bring a collateral challenge on the ground that it does not
       comply with the mandatory requirement of section 4(a)(v) of, and
       paragraph 5(2)(a) of Schedule 1 to the London Local Authorities
       and Transport for London Act 2003.
       2. I bring a further collateral challenge since the taken
       without consent ground clearly limits/fetters to theft by its
       very wording that a crime report be provided. Therefore, this
       inaccurate reflection of the statutory ground does not take into
       account that a relative, or friend, may have taken the vehicle
       without the owner’s permission so that the owner would not
       necessarily, if at all, report the matter to the Police in such
       circumstances or, indeed, make an insurance claim.
       In light of the above the penalty charge notice is invalid and
       must be cancelled.
       Yours faithfully
       Name (Registered keeper)
       Address
       #Post#: 16790--------------------------------------------------
       Re: Haringey 52(M) PCN
   DIR By: Vike
       Date: March 4, 2024, 12:26 pm
       ---------------------------------------------------------
       Hi
       Should I clarify point 1 that the reason it does not comply is
       that they put date of notice rather than date of service?
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