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       #Post#: 41795--------------------------------------------------
       Re: Motorbike 52m PCN Lambeth
   DIR By: Chaseman
       Date: October 21, 2024, 6:18 pm
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       I filed an appeal with LT as a collateral challenge on grounds
       that the Lambeth website was at odds with the PCN and was
       materially misleading on dates as well as demanding penalties be
       paid at risk of escalation to Charge Certificate notwithstanding
       that an appeal was in progress. A secondary line of appeal was
       that Lambeth had rescinded previous LTOs when it introduced a
       new one in 2024 and had not reinstated them hence the LTO under
       which I was charged was not in force at the time. Accompanied by
       Hippocrates I went to the LT to have the appeal heard by Mr EJ
       Houghton in mid-September.
       The adjudicator reserved judgment at the hearing as he wanted a
       complete timeline set out of all actions by Lambeth, what
       appeared on their website and when and what entreaties there
       were to persuade me to pay up. As a secondary matter he wanted
       to think about the LTO point and was not persuaded by the
       evidence we produced as it might not effectively present the
       whole picture. I was able to put this together relatively easily
       together with screen shots that Hippocrates had usefully
       preserved; all the key dates were in the papers we had filed but
       Mr Houghton wanted them in an easily readable summary sheet
       before coming to his decision.
       Written judgment came through on 16 October. Appeal allowed. Key
       paras:
       The main challenge lies on procedural grounds, In bare summary
       the Appellant submits that the
       Council's website was giving incorrect and/or confusing
       information regarding payment dates, and
       that it was still showing a demand for payment after an appeal
       had been lodged. It seems to me that
       even if the Statutory notices are in themselves technically
       correct what is shown on the Council's
       website should be in accordance with those notices; and that if
       it is not, it inevitably has the effect of
       undermining what is st[at]ed in the Notices.
       The motorist is entitled to have
       clear and correct information from a Council as to what is
       required to be paid and when; and in my
       judgement these errors are serious enough for the Appeal to be
       allowed on the basis of a collateral
       challenge.
       He also said he concurred with the view of adjudicator Michael
       Greenslade that a LA should not be seeking any amount beyond the
       prescribed sum
       "or any amount at all" while an appeal was in progress. He did
       not give me a "win" on the LTO point, seemingly requiring me to
       prove a negative rather than
       asking Lambeth to prove positively that the LTO was in force at
       the time.
       For anyone getting a PCN from Lambeth henceforth I would watch
       the website carefully and take screenshots of any obvious
       errors. These were
       abundant in my case and my guess is that no-one at Lambeth is
       going to pick up my case and say "right, we had better overhaul
       the website or else
       we will get more challenges of the same nature". In particular
       watch out for them threatening a CC when the PCN is already
       being taken to the LT.
       Many thanks to Hippocrates and also to cp 8759 for help on this
       one.
       Case ref at LT is 2240362722.
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