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       #Post#: 18938--------------------------------------------------
       31J Entering and stopping ina box junction when prohibited
   DIR By: Donostio
       Date: April 3, 2024, 11:48 am
       ---------------------------------------------------------
       Hello
       PCN just arrived in the post from the London Borough of Merton
       £130 or £65 reduced charge.
       Going against me:
       I have entered before the exit was clear.
       The back of my car / back wheels were in the box for at least 30
       seconds
       For me:
       I wasn't causing an obstruction . was almost clear of the box.
       Due me being pretty much out of the box (I thought I was out of
       it enough) I didn't think it necessary to move to the lane on
       the right which DID have room for me (lesson learnt - next time
       I will move to the right if there is space!).
       Is it worth appealing? Is there any precedent?
       Thank you for any advice.
       Video (me with the roof rack):
  HTML https://youtu.be/RpnLiq-Lu6g
       Image (me with the roof rack):
  HTML https://imagizer.imageshack.com/img922/7196/O8ECoz.jpg
  HTML https://imagizer.imageshack.com/img924/8454/iZXkOx.jpg
  HTML https://imagizer.imageshack.com/img924/4978/6MEF5T.jpg
       #Post#: 18959--------------------------------------------------
       Re: 31J Entering and stopping ina box junction when prohibited
   DIR By: ivanleo
       Date: April 3, 2024, 3:47 pm
       ---------------------------------------------------------
       --- Quote from: Donostio link ---
       >
       > Is it worth appealing? Is there any precedent?
       >
       --- End Quote ---
       [member=1448]Donostio[/member] it is definitely worth making a
       representation to the council, the Merton notice of rejection
       for moving traffic PCNs is full of errors, see these cases (both
       my handy work):
       Giles Kennedy v London Borough of Merton (2220586920, 8 October
       2022)
  HTML https://drive.google.com/file/d/1B9N4JSUcCy2BR3QdqX0o3HKrzA7y0jOg/view
       Commercial Plant Services Ltd v London Borough of Merton
       (2240027331, 13 March 2024)
  HTML https://drive.google.com/file/d/1Ca_n8qFSL_WwGgxfAdfsu_-05leHw6EA/view
       Just put a representation in during the initial 14 days and if
       they reject they will reoffer the discount, if the rejection is
       then full of errors (which is likely, they've not fixed the
       template in two years so I doubt they'll fix it now) it's an
       easy win at the tribunal.
       There's also the argument as per Commercial Plant Services Ltd v
       London Borough of Merton (2230446542, 11 December 2023)
  HTML https://drive.google.com/file/d/12WAmwX1nH1yqp3f0FLxr4s2QtG5C2Zat/view<br
       />but we need the PCN number and number plate to check for that.
       If you post the rest of the PCN we can also check for other
       errors.
       #Post#: 18960--------------------------------------------------
       Re: 31J Entering and stopping ina box junction when prohibited
   DIR By: Donostio
       Date: April 3, 2024, 3:58 pm
       ---------------------------------------------------------
       Thank you.
       Plate: EN14NXK
       PNC: MT87744271
       I think I've uploaded both sides of the PCN letter.
       Thanks again
       [attachment deleted by admin]
       #Post#: 18961--------------------------------------------------
       Re: 31J Entering and stopping ina box junction when prohibited
   DIR By: Donostio
       Date: April 3, 2024, 3:59 pm
       ---------------------------------------------------------
       .
       [attachment deleted by admin]
       #Post#: 18963--------------------------------------------------
       Re: 31J Entering and stopping ina box junction when prohibited
   DIR By: ivanleo
       Date: April 3, 2024, 4:20 pm
       ---------------------------------------------------------
       [s]Here you go:
       [indent]
       [s]Dear London Borough of Merton,
       I challenge liability for PCN MT87744271 on the basis that the
       information referenced in the second paragraph of the second
       page of the PCN does not convey the contents of paragraph 1(4)
       of Schedule 1 to the London Local Authorities and Transport for
       London Act 2003, and it follows that the PCN must be cancelled.
       Yours faithfully,
       [/indent]
       [s]Make representations online and select the reason  The
       penalty charge exceeded the amount applicable in the
       circumstances of the case", make sure to keep a screenshot of
       the confirmation page.
       Please post up the notice of rejection when you get it.
       #Post#: 18969--------------------------------------------------
       Re: 31J Entering and stopping ina box junction when prohibited
   DIR By: MrChips
       Date: April 3, 2024, 4:52 pm
       ---------------------------------------------------------
       I also think the location is wrong in the PCN.  It says
       Durnsford Road adjacent to Bassett House, but that box junction
       is a different one and the one you stopped in is about 100
       metres further north.
       #Post#: 18971--------------------------------------------------
       Re: 31J Entering and stopping ina box junction when prohibited
   DIR By: Donostio
       Date: April 3, 2024, 5:02 pm
       ---------------------------------------------------------
       Thank you Mr Chips
       That is curious. Indeed, I turned left at the junction the
       issuer describes. The junction in the photo I am going straight
       across. Should I mention this also in my appeal or use it later?
       [attachment deleted by admin]
       #Post#: 18976--------------------------------------------------
       Re: 31J Entering and stopping ina box junction when prohibited
   DIR By: MrChips
       Date: April 3, 2024, 5:50 pm
       ---------------------------------------------------------
       Wrong location should be fatal to a PCN.  Merton might argue
       that it's close enough but there is a (quite faded) box junction
       which is right next to Bassett House which fits their
       description much better so it should be possible to demonstrate
       that the location isn't sufficiently correct.
       #Post#: 18977--------------------------------------------------
       Re: 31J Entering and stopping ina box junction when prohibited
   DIR By: ivanleo
       Date: April 3, 2024, 5:50 pm
       ---------------------------------------------------------
       So the location is here:
  HTML https://maps.app.goo.gl/XUTez9J3dYXrQb1f6
       I think the description on the PCN is good enough, but the
       location raises a more fundamental question, see
  HTML https://maps.app.goo.gl/XUTez9J3dYXrQb1f6
       That is a private driveway to an office block, it's not a road
       over which the public have an unfettered right to pass and
       repass at will, it follows that it is not a road within the
       meaning of section 142 of the Road Traffic Regulation Act 1984.
       It's basically a repeat of the One Croydon scenario we saw in
       Kate Gardener v London Borough of Croydon (2220655535, 15
       October 2022)
  HTML https://drive.google.com/file/d/1xbeDoPx79OZNWKNMAWfKm9BoLuDtwlml/view
       Here's a revised draft:
       [indent]
       Dear London Borough of Merton,
       The alleged contravention did not occur, this is because the box
       junction is not placed at the junction of two or more roads or
       outside a police, fire or ambulance station. The box junction
       appears to be situated at the entrance to the private driveway
       to an apartment complex, the Traffic Signs Regulations and
       General Directions 2016 do not permit box junction markings at
       such a location.
       It follows that no contravention can ever occur at this
       location, enforcement must cease and the CCTV enforcement camera
       at this location must be removed. As there is no traffic
       enforcement justification for the camera at this location,
       failure to remove or at least disable the the camera would
       result in the unlawful and unjustified capture of personal data,
       in contravention of the General Data Protection Regulation.
       I further challenge liability for PCN MT87744271 on the basis
       that the information referenced in the second paragraph of the
       second page of the PCN does not convey the contents of paragraph
       1(4) of Schedule 1 to the London Local Authorities and Transport
       for London Act 2003, and it follows that the PCN must be
       cancelled.
       Yours faithfully,
       [/indent]
       Make representations online and select the reason "The penalty
       charge exceeded the amount applicable in the circumstances of
       the case", make sure to keep a screenshot of the confirmation
       page.
       Please post up the notice of rejection when you get it.
       #Post#: 18979--------------------------------------------------
       Re: 31J Entering and stopping ina box junction when prohibited
   DIR By: Donostio
       Date: April 3, 2024, 6:05 pm
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       In case it makes a difference the block is mostly residential
       and includes some retail units.
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