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       #Post#: 43481--------------------------------------------------
       Re: Munday road E16 - London newham - parked on disabled bay by
       mistake 
   DIR By: taffer87
       Date: November 1, 2024, 6:42 am
       ---------------------------------------------------------
       --- Quote from: H C Andersen link ---
       >
       > Reg. 5 of the 'Appeals' regs:
       >
       > Representations against the enforcement notice
       > 5.—(1) The recipient may make representations against the
       enforcement notice to the enforcement authority which served it
       on the recipient.
       >
       > 5(2) The representations must be—
       >
       > (a)made in the form determined by the enforcement authority,
       and
       >
       > (b)to either or both of the following effects—
       >
       > (i)that in relation to the alleged contravention, one or more
       of the grounds specified in paragraph (4) apply;
       >
       > (ii)that, whether or not any of those grounds apply, there are
       compelling reasons why, in the particular circumstances of the
       case, the enforcement authority should cancel the penalty charge
       and refund any sum paid to it on account of the penalty charge.
       >
       >
       > Initiating an appeal
       >
       > 2.—(1) An appeal must be made by delivering a notice of appeal
       to the proper officer.
       >
       > (2) A notice of appeal—
       >
       > (a)must be in writing and signed by—
       >
       > (i)the appellant, or
       >
       > (ii)a person authorised to do so by the appellant,
       >
       > (b)must state the name and address at which the appellant
       wishes documents in connection with the appeal to be sent,
       >
       > (c)must state the date and any reference number of the
       disputed decision and the name of the enforcement authority, and
       >
       > (d)may include any representations which the appellant desires
       to make in addition to the original representations.
       >
       >
       > Further representations by the parties
       > 4.—(1) Any party may deliver representations in relation to
       the matters referred to in regulation 5(2)(b), 8(5) or 11(3), as
       appropriate in the circumstances, to the proper officer at any
       time before the appeal is determined.
       >
       --- End Quote ---
       Thank you
       #Post#: 44236--------------------------------------------------
       Re: Munday road E16 - London newham - parked on disabled bay by
       mistake 
   DIR By: taffer87
       Date: November 6, 2024, 8:46 am
       ---------------------------------------------------------
       Is it also the case that the authority must submit (to the
       adjudicator) within 7 days post service of notice of appeal by
       the adjudicator the original PCN and related representations? If
       authority doesn't do that and there is nothing in appeal portal
       then is that a good enough point on its own under the Appeal
       regulations?
       #Post#: 44241--------------------------------------------------
       Re: Munday road E16 - London newham - parked on disabled bay by
       mistake 
   DIR By: taffer87
       Date: November 6, 2024, 9:16 am
       ---------------------------------------------------------
       "Action upon receipt of notice of appeal and copy of such notice
       3.—(1) Upon receiving a notice of appeal the proper officer
       must—
       (a)send an acknowledgement of its receipt to the appellant, and
       (b)enter particulars of the appeal in the register.
       (2) If the proper officer is satisfied that the notice of appeal
       is made in accordance with paragraph 2, the proper officer must
       send to the enforcement authority—
       (a)a copy of the notice of appeal, and
       (b)the directions extending the period for appealing (if any).
       (3) Where an enforcement authority receives a copy of a notice
       of appeal sent to it under sub-paragraph (2), the authority
       must, within seven days of the day on which it receives that
       copy, deliver to the proper officer of a copy of each of the
       following—
       (a)the original representations,
       (b)the relevant penalty charge notice (if any), and
       (c)the notice of rejection."
  HTML https://www.legislation.gov.uk/ukdsi/2022/9780348231564
       #Post#: 44583--------------------------------------------------
       Re: Munday road E16 - London newham - parked on disabled bay by
       mistake 
   DIR By: taffer87
       Date: November 8, 2024, 7:57 am
       ---------------------------------------------------------
       [member=1]cp8759[/member]
       [member=428]H C Andersen[/member]
       Any views on the above 7 day rule and any past cases on this
       point please?
       #Post#: 44592--------------------------------------------------
       Re: Munday road E16 - London newham - parked on disabled bay by
       mistake 
   DIR By: H C Andersen
       Date: November 8, 2024, 8:25 am
       ---------------------------------------------------------
       I'm not certain what point you're making.
       Nothing comes to you until a minimum of 7 days before the
       hearing. As I understand it, the purpose of what you've posted
       (which by the way is the draft SI and not the final version
       which is
       here:
  HTML https://www.legislation.gov.uk/ukdsi/2022/9780348232752/schedule/1)<br
       />is to ensure that the administrative loop is closed- remember,
       all that the tribunal know is that you have submitted a
       form/completed online requesting a hearing to dispute what you
       claim is a PCN and NOR at which point they don't know if this is
       proper or not (e.g. that you're not an armchair anarchist trying
       to throw the tribunal into disarray with specious applications).
       Sending this to the authority and getting the underlying
       specified docs closes this loop and means they're dealing with a
       proper application.
       #Post#: 44687--------------------------------------------------
       Re: Munday road E16 - London newham - parked on disabled bay by
       mistake 
   DIR By: ivanleo
       Date: November 8, 2024, 6:52 pm
       ---------------------------------------------------------
       --- Quote from: taffer87 link ---
       >
       > Is it also the case that the authority must submit (to the
       adjudicator) within 7 days post service of notice of appeal by
       the adjudicator the original PCN and related representations? If
       authority doesn't do that and there is nothing in appeal portal
       then is that a good enough point on its own under the Appeal
       regulations?
       >
       --- End Quote ---
       Yes and no. I have got a couple of decisions on this point where
       I had other things to argue, but most adjudicators would use
       their powers to grant the council an extension of time (even if
       no extension has been sought). It's certainly not something an
       argument I would rely on, especially where there's something
       more solid to go on as is the case here.
       #Post#: 44688--------------------------------------------------
       Re: Munday road E16 - London newham - parked on disabled bay by
       mistake 
   DIR By: ivanleo
       Date: November 8, 2024, 6:55 pm
       ---------------------------------------------------------
       --- Quote from: H C Andersen link ---
       >
       > Nothing comes to you until a minimum of 7 days before the
       hearing.
       >
       --- End Quote ---
       No sure what you mean by that, I've got some cases where the
       tribunal scheduled the case months in advance (typically where
       I've been lucky enough to get a Saturday hearing slot, which get
       booked up months in advance) and I have had evidence packs from
       some authorities as much as 2 / 3 month prior to the hearing.
       I've also had cases where the authority submitted its evidence a
       couple of days before the hearing and the adjudicator wouldn't
       disregard it and simply adjourned the hearing to give me time to
       respond.
       #Post#: 45176--------------------------------------------------
       Re: Munday road E16 - London newham - parked on disabled bay by
       mistake 
   DIR By: taffer87
       Date: November 12, 2024, 5:09 am
       ---------------------------------------------------------
       Also tagging [member=428]H C Andersen[/member] and
       [member=1]cp8759[/member]
       All thanks so much for your help. I have received the council
       evidence bundle and extracted case summary and formal reps here.
       Interestingly they still have not included the notice of
       acceptance sent to VWFS against VWFS' representations in their
       evidence bundle. Also they continue to completely ignore the
       majority of the points in my formal reps other than the first
       point.
       Please if you could kindly guide / assist in me making a case to
       tribunal. Hearing is in 2 weeks time and I will do it via phone.
       Most bizarrely they have also incorrectly stated that my permit
       for the canning town CT zone has expired as it was renewed and
       is active and I can provide proof of this.
       Regards
  HTML https://i.ibb.co/G7VCTcP/redacted-evidence-bundle-extract-inc-formal-reps.jpg
  HTML https://ibb.co/R2CQyzH
       #Post#: 45189--------------------------------------------------
       Re: Munday road E16 - London newham - parked on disabled bay by
       mistake 
   DIR By: Enceladus
       Date: November 12, 2024, 6:21 am
       ---------------------------------------------------------
       You could mention the matter of the expired permit. It looks
       like Newham are attempting to imply that even if the disabled
       bay was not correctly positioned on the ground in compliance
       with the traffic order, then you were still in contravention as
       you were parked where a Resident's Parking Permit was required.
       Hoever you only have to answer to the contravention alleged and
       not some similar contravention. The PCN says "Parked in a permit
       space or zone without a valid virtual permit or clearly
       displaying a valid physical permit where required (dedicated
       disabled bay)". So the allegation is specific to a "disabled
       bay", of some flavour. Not just any Resident Permit Only bays.
       I suggest you mark up a copy of the map that's in the evidence
       pack, show where you were actually parked, in relation to the
       the disabled bay they say is shown on the map. Scan and upload
       the marked up map in your evidence pack, to support your
       assertion that the bay is not where it should be.
       Also in your opening post you've put the below. Did you include
       that in your submission to the Tribunal? It's worth a shot but I
       believe there is permission for the sign. See do they produce
       the authorisation. Actually is it in the evidence pack? If so
       then please post it up. That said, to the best of my knowledge
       we've never won a case against Newham challenging this sign
       where there is also a DISABLED legend on the carriageway. Maybe
       somebody else can produce such a case?
       "Ground 3
       The sign governing the bay is not contained within The Traffic
       Signs Regulations and General Directions 2016 nor have the
       Council obtained DfT permission to use it. There is no provision
       within the legislation to use the term "Residents" nor a permit
       identifier for anything other than a dedicated bay reserved for
       an individual disabled person.Therefore the traffic sign is a
       nullity and cannot be enforced, making the PCN invalid."
       #Post#: 45198--------------------------------------------------
       Re: Munday road E16 - London newham - parked on disabled bay by
       mistake 
   DIR By: H C Andersen
       Date: November 12, 2024, 7:29 am
       ---------------------------------------------------------
       OP, I think your further reps should start with the first-level
       issue i.e. whether you may be regarded as the owner for the
       purposes of the TMA.
       Read this:
  HTML https://www.londoncouncils.gov.uk/sites/default/files/2024-05/tec_agenda_reports_-_18_october_2023_2_2.pdf
       It's the Chief Adjudicator's, Anthony Chan's, Annual Report to
       London Councils. See page 13, Transfer of Liability.
       (I can't seem to copy from the report..if anyone knows how this
       can be done pl advise).
       ..Adjudicators have found that despite the restrictive statutory
       provisions which are re-stated in case law parties are still not
       grasping provisions.
       ..Adjudicators have noticed that some authorities have allowed
       transfer even when the required evidence has not been provided.
       To mimic the pompous language used by the authority....
       The Appellant would like to bring to the adjudicator's attention
       the comments of Adjudicator Chan in his 2022/2023 annual report
       to the Transport and Environment Committee of London Councils
       where he highlighted that 'despite the restrictive statutory
       provisions which are re-stated in case law parties are not
       grasping[the transfer of liability mandatory] provisions.
       On this point, you would invite the adjudicator to scrutinise
       the authority's evidence that establishes, as opposed to merely
       implies, that the statutory provisions have been complied with
       by both the registered keeper and the authority which is a
       pre-condition to the hirer being considered the 'owner' for
       regulatory purposes. You would submit that absent proof of a
       legal transfer of liability then enforcement against you as
       'owner' is a procedural impropriety.
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