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       #Post#: 997--------------------------------------------------
       Code 85 Parked without a valid virtual permit, Ashford, Kent
   DIR By: Circle87
       Date: July 7, 2023, 8:39 am
       ---------------------------------------------------------
       Picture upload is not working so I have posted links to the
       evidence here:
  HTML https://imgur.com/a/qwvMePW
       Back of the PCN here:
  HTML https://imgur.com/gallery/vuIIsqY
       UPDATE: Ashford BC have declined my appeal, to which their
       response I have attached in the attachment sections.
       I have tried to type this according to the Forum guidelines but
       if i've missed anything please let me know and I will edit this
       post with the required details.
       Dear all,
       I recently parked in a council car park in a space which was
       apparently permit holders only. As per the photo evidence
       attached, the sign is very small, a piece of paper attached to
       the fence behind, no bay markings or anything "noticeable".
       Personally i'm shocked this has happened as I legitimately
       didn't see the small-ass sign. I paid for a full days ticket
       £5.80 via the RingGoApp (I have evidence of receipt but can't
       attach) and have confirmation of receipt. However the issue is
       that this space is permit holders only. Can you please tell me,
       from the evidence pictures attached, if this is fair and
       justified? I didn't even see the sign behind as it's not
       displayed clearly and in a noticeable place. I drove into the
       car park and only noticed the space was free and available after
       driving past it and seeing it in my rear view mirror. I reversed
       in so didn't even see the sign! How could I see that!? I then
       got out my car, grabbed my bag and went on my way. I didn't buy
       a physical ticket as I parked up and walked straight out paid my
       ticket on the RingoApp. To add to that, I was in a rush to catch
       the train so nothing caught my eye to allow me to realise that I
       shouldn't park there? If someone ripped that sign off, or if I
       was dyslexic there is no way to tell that this particular bay
       has special conditions. Any honest replies most welcome. I've
       already appealed online and I may want to take this further but
       need help first to see if I have grounds to take this to court
       if they reject my appeal (which knowing my stupid luck, they
       will). Thoughts? Pay up and shush up? Or throw my toys out the
       pram and take it further? I can pop down to the car park and
       take a video of the place if needed to get some perspective.
       Sorry for my rushed post, I'm just angry and frustrated.
       The Ashford Borough Council PCN Challenge and Payment website
       is:
  HTML https://www.ashford.gov.uk/parking/penalty-...parking-ticket/
       The PCN is AS09113666
       Reg: GF23OER
       Many thanks. Circle.[attach=1]
       [attachment deleted by admin]
       #Post#: 1005--------------------------------------------------
       Re: Code 85 Parked without a valid virtual permit, Ashford, Kent
   DIR By: ivanleo
       Date: July 7, 2023, 10:23 am
       ---------------------------------------------------------
       I've had a few PCNs from Ashford before, never paid one though.
       This is fairly clear-cut, as the terms and condition board makes
       no mention of permit holders, so there's no reason why you would
       look for permit holder signs. Here's some draft reps you can
       send when you get the Notice to Owner:
       [indent]
       Dear Ashford Borough Council,
       I contest liability for PCN AS09113666 on the grounds that the
       alleged contravention did not occur. The terms and conditions
       board which is required to convey the main requirements created
       by the off-street parking places order makes no mention
       whatsoever of any permit parking places, it simply indicates
       that payment must be made, vehicles must park wholly within a
       marked bay, and vehicles parked in a disabled persons' bay must
       display a blue badge.
       I have complied with all of those requirements, and it follows
       that on this occasion a contravention did not occur.
       Yours faithfully,
       [/indent]
       Don't expect them to accept, but I think they'd really struggle
       at the tribunal with this one.
       #Post#: 1008--------------------------------------------------
       Re: Code 85 Parked without a valid virtual permit, Ashford, Kent
   DIR By: Circle87
       Date: July 7, 2023, 10:34 am
       ---------------------------------------------------------
       Thank you. There is a notice board which is across the other
       side of the car park and the text is not visible from that far
       away. But as you rightly pointed out there is no mention of any
       "permit holder" on the board. It does say "reserved bay" so can
       I say that a reserved bay and permit holder bay are two separate
       things? If so I will copy and paste your appeal text into the
       Challenge and Appeal box on the council's website. Here is the
       link to the evidenced notice board again if you need it:
       Parking Ticket
  HTML https://imgur.com/gallery/qwvMePW
       It's pictures 4 and 7.
       I have also had a reply declining my appeal which I hastedly
       sent off before coming here. It's attached in the documents
       upload section.
       [attachment deleted by admin]
       #Post#: 1009--------------------------------------------------
       Re: Code 85 Parked without a valid virtual permit, Ashford, Kent
   DIR By: ivanleo
       Date: July 7, 2023, 10:46 am
       ---------------------------------------------------------
       Yes I've read all of that, and my advice remains to wait for the
       Notice to Owner and then send what I've drafted. Nothing on the
       main terms and conditions board makes any reference to permits,
       so the point still stands.
       #Post#: 1010--------------------------------------------------
       Re: Code 85 Parked without a valid virtual permit, Ashford, Kent
   DIR By: Circle87
       Date: July 7, 2023, 10:49 am
       ---------------------------------------------------------
       Ok perfect! Yes very clear cut (I edited my reply post with a
       few details) and I understand.
       So, I'll wait for the Notice To Owner and write with the exact
       text. Thank you!
       #Post#: 1019--------------------------------------------------
       Re: Code 85 Parked without a valid virtual permit, Ashford, Kent
   DIR By: guest179
       Date: July 7, 2023, 5:30 pm
       ---------------------------------------------------------
       You knew the car park otherwise you would have checked the
       noticeboard. You're a frequent flier, yes?
       So you're presumed to have read the noticeboard, not reading it
       is not a defence.
       The sign in the bay is clear IMO.
       But there's nothing in the noticeboard to alert a driver to the
       presence of permit bays or the penalty for misuse.
       It could go either way at adjudication IMO depending on the
       council's reasoning. I've won similar cases but IMO any reps
       after a NTO must be smart and not just say 'but the noticeboard
       doesn't say'.
       If it were me, I would make reps*. I would not pretend I did not
       see the sign, it's clear. Your argument would be that when you
       checked the board you couldn't find any mention of the existence
       of permit bays and so thought that the sign must have been left
       over from a previous use. As the council's case is based upon a
       breach of the terms and conditions and as they must accept that
       there isn't any reference on the noticeboard then they must
       explain why they consider that for every other condition of use
       they consider it necessary to set these out on the board but for
       the use of this bay by permit holders only they consider that it
       is sufficient and legally acceptable to hang a notice on chicken
       wire at the back of a bay.
       Test their reasoning by asking directed and targeted questions
       because how they respond, if at all, and their reasoning could
       be powerful weapons at adjudication.
       *- are you the registered keeper and are your V5C details
       current?
       #Post#: 1020--------------------------------------------------
       Re: Code 85 Parked without a valid virtual permit, Ashford, Kent
   DIR By: Circle87
       Date: July 7, 2023, 5:57 pm
       ---------------------------------------------------------
       Thank you. I'm not saying me not seeing the sign is a valid
       reason for parking there. I legitimately did not see or notice
       the sign there. However, the notice board I did see, because yes
       I frequent the carpark and because it's a massive board, unlike
       the A4 paper stuck behind the bay on the fence with chicken
       wire.
       I am the owner and registered keeper of the car, correct.
       I will wait for the NTO to come through the post.
       I will copy and paste the appeal text in which CP8759 has kindly
       drafted above. Should I also include something along the lines
       of:
       "I have checked the board and could not find any mention of the
       existence of permit bays and so I thought that the sign must
       have been left over from a previous use. If this case is an
       apparant breach of the terms and conditions, the council must
       accept that there isn't any reference on the noticeboard to any
       permit holder bays.
       I therefore ask you to explain why the council consider that for
       every other condition of use they consider it necessary to set
       these out on the board, however, for the use of this bay by
       permit holders only they consider that it is sufficient and
       legally acceptable to hang a notice on plastic wire at the back
       of a bay?".
       I am preparing my draft to appeal so that when the NTO comes
       through I am fully prepared.
       Just FYI as I mentioned earlier they have already refused my
       appeal within the discounted rate period (attached) and I hope
       this and my initial appeal email will not jeopardise this.
       Thanks for all your help again.
       [attachment deleted by admin]
       #Post#: 1026--------------------------------------------------
       Re: Code 85 Parked without a valid virtual permit, Ashford, Kent
   DIR By: ivanleo
       Date: July 8, 2023, 6:22 am
       ---------------------------------------------------------
       --- Quote from: Circle87 link ---
       >
       > Should I also include something along the lines of:
       > "I have checked the board and could not find any mention of
       the existence of permit bays and so I thought that the sign must
       have been left over from a previous use.
       >
       --- End Quote ---
       Well you can't say that because it's not true: you've told us
       you didn't see the sign, so it would be a false representation
       to say that you saw it and thought it didn't apply. Making a
       false representation to the council is a criminal offence, see
  HTML https://www.legislation.gov.uk/uksi/2022/576/regulation/18
       Representations should not include demands for explanations,
       they should simply put your case forwards (maybe it's just me
       but saying "I therefore ask you to explain why..." reminds me
       too much of FMOTL arguments along the lines of "I require you to
       do X or else you agree you owe me £1,000,000"). It's a
       representation, not a fishing expedition, if they don't bother
       to explain their position that's their problem.
       What you could say is "even if I had seen the sign, I would have
       assumed it didn't apply because...".
       #Post#: 1042--------------------------------------------------
       Re: Code 85 Parked without a valid virtual permit, Ashford, Kent
   DIR By: Circle87
       Date: July 8, 2023, 2:18 pm
       ---------------------------------------------------------
       Thank you. That makes sense. To clarify, I didn't see the sign
       attached on the fence at the back of the bay, but I have seen
       and read the board.
       In which case, I will stick to simply appealing with your
       original text. I will wait for the NTO and refer back here when
       that time comes.
       #Post#: 1064--------------------------------------------------
       Re: Code 85 Parked without a valid virtual permit, Ashford, Kent
   DIR By: guest179
       Date: July 9, 2023, 12:40 pm
       ---------------------------------------------------------
       Representations should not include demands for explanations,
       This is simply a personal preference, there's no legal or IMO
       logical impediment to doing so. Why, who, when, what are the
       staples of good set-ups in formulating arguments. They cause the
       recipient to consider their own logic and reasoning as well as
       making it clear that the questioner is on to them. FMOTL
       arguments are misguided statements of law, not directed
       questioning.
       But if you claim you didn't see the sign until after the PCN was
       issued - you did see the sign, you just didn't see it before the
       PCN was issued - then say so. My suggested reps could be tweaked
       to accommodate this variation.
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