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       #Post#: 2603--------------------------------------------------
       PCN 62 - Croydon Council - Parking on a footpath or on other
       than carriageway, Croydon
   DIR By: CPBadger
       Date: August 5, 2023, 3:41 am
       ---------------------------------------------------------
       Good morning,
       I previously posted this topic on PePiPoo and had some very
       useful responses, on the strength of which I decided to take the
       council on. Unfortunately now I need to respond to the Council
       my original thread seems to have disappeared so I've lost the
       responses! So I'd be very grateful for any suggestions.
       I was parked in a private estate which is served by a public
       road, on the intersection between the public road and a private
       road which provides access to the garages. It is where the
       footpath of the public road would be if the private road didn't
       exist. I was given a PCN 62 for 'parking on a footpath or on
       other than carriageway'.
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       My position is that clearly the private road meets the
       definition of a carriageway (and consequently cannot also be a
       footpath). As the private road is fully connected to the public
       road with no barriers or signs to indicate that it is private or
       that it is anything other than a continuous carriageway, parking
       on the intersection of the two cannot be considered to be
       parking on a footpath.
       It is unreasonable to think that without any signage residents
       (or other members of the public) will understand that this
       section of the road is considered to be a footpath. Looking at
       historic google photos, 2 of the 5 photos show cars parked in
       this space, which supports my position.
       Grateful for any cases, definitions or arguments (with links if
       possible) to support my position. I have a week or so to
       respond.
       CPBadger
       #Post#: 2618--------------------------------------------------
       Re: PCN 62 - Croydon Council - Parking on a footpath or on other
       than carriageway, Croydon
   DIR By: DancingDad
       Date: August 5, 2023, 9:24 am
       ---------------------------------------------------------
       Original post on PPP
  HTML http://forums.pepipoo.com/index.php?showtopic=150047&hl=
       I must say that IMO this is a crossover leading to the private
       road/driveway and as such part of the main highway but not
       regarded as carriageway... no different to parking on a
       crossover into someone's drive or a car park.
       But that is my opinion and there is certainly scope to argue as
       this is a bit more then a car park or driveway
       #Post#: 2622--------------------------------------------------
       Re: PCN 62 - Croydon Council - Parking on a footpath or on other
       than carriageway, Croydon
   DIR By: guest179
       Date: August 5, 2023, 9:45 am
       ---------------------------------------------------------
       +1.
       As I posted on Pepipoo, if the authority's view is that you were
       parked on a footway then the only footway must be that area
       bounded by the parallel arcs of inlaid stones. Therefore, as
       this gives vehicle access to a carriageway the 'footway' must be
       a vehicle crossover. In which case the council would have
       records of installing this crossover.
       Yeah!
       #Post#: 2635--------------------------------------------------
       Re: PCN 62 - Croydon Council - Parking on a footpath or on other
       than carriageway, Croydon
   DIR By: Pastmybest
       Date: August 5, 2023, 12:08 pm
       ---------------------------------------------------------
       +2 you are parked on a junction alongside a pavement, bad
       parking but not something the council can do you for
       #Post#: 2714--------------------------------------------------
       Re: PCN 62 - Croydon Council - Parking on a footpath or on other
       than carriageway, Croydon
   DIR By: ivanleo
       Date: August 6, 2023, 8:46 am
       ---------------------------------------------------------
       This was my original reply:
       --- Quote from: cp8759 date ---
       >
       > This is a very interesting case that raises multiple complex
       points of law. The starting point is the definition of a "road"
       found at section 142 of the Road Traffic Regulation Act 1984:
       >
       > [indent]
       > in England and Wales, means any length of highway or of any
       other road to which the public has access, and includes bridges
       over which a road passes, and[/indent]
       >
       > If the road is not adopted it might not be a highway, but it
       can still be a road to which the public has access. I certainly
       cannot see any physical barrier or signage indicating that
       members of the public cannot walk up and down that road as they
       wish.
       >
  HTML > In [url=http://"
  HTML http://bit.ly/3lPvv3Q"]Bowen
       & Ors v Isle of
       Wight Council [2021] EWHC 3254 (Ch)[/url] the High Court
       explained at 49 that:
       >
       > [indent]In my judgment, a road will be a "road to which the
       public has access", and thus within the definition of "road" in
       section 142 of the 1984 Act, provided that the general public do
       as a matter of fact exercise access to it and provided that
       those members of the public "have not obtained access either by
       overcoming a physical obstruction or in defiance of prohibition
       express or implied" (in the words of Lord Sands in Harrison v
       Hill, as approved and applied by the Divisional Court). The
       enquiry is thus essentially a factual one. If the conditions are
       satisfied, it is, as the Divisional Court sought—apparently
       unsuccessfully—to make clear in Cox v White, irrelevant to
       enquire further whether the presence of the public on the road
       was merely by the tolerance of the owners or whether the
       tolerance is to be taken to have given implicit permission. The
       simplicity of the resulting test is welcome, for at least two
       reasons: first, it avoids the need for courts, when considering
       such matters as motoring offences, to become embroiled in, or
       confused by, subtle distinctions regarding when an owner's
       inaction does and does not imply permission; second, it avoids
       importing into the statutory definition a distinction that is
       wholly irrelevant to the statutory purpose of providing for the
       safety of those who may reasonably be expected to be on roads
       and affected by what happens on them.[/indent]
       >
       > The "private" road quite clearly appears to be a road to which
       the public have access, and if it comes to it you and your
       neighbours can easily give evidence about this.
       >
       > I would make a very simple challenge:[indent]
       >
       > Dear London Borough of Croydon,
       >
       > The CEO's photos clearly show that my vehicle was parked on
       the carriageway of the unnamed service road that leads to the
       front doors of numbers 49 to 57 Eskmont Ridge, and to a number
       of garages. While I appreciate I was parked right at the
       junction, this is not in itself unlawful and it does not mean
       that I was parked on the footway. I trust you will now cancel
       the PCN and have words with the CEO about this overzealous
       enforcement.
       >
       > Yours faithfully,[/indent]
       >
       --- End Quote ---
       Council response:
  HTML https://gcdnb.pbrd.co/images/6UaHw3trQaK2.png
       Have you now got a Notice to Owner? If so, please post it up.
       #Post#: 2732--------------------------------------------------
       Re: PCN 62 - Croydon Council - Parking on a footpath or on other
       than carriageway, Croydon
   DIR By: CPBadger
       Date: August 6, 2023, 11:24 am
       ---------------------------------------------------------
       Thanks all, much appreciated.
       I would argue that to the eye this looks more like a carriageway
       than a crossover because there is no ramp, there is such a wide
       entrance point and the road is not signed as 'private'.  Also on
       one side the pavement doesn't have a dropped kerb onto the
       crossover - it is instead directed from the pavement onto the
       public road.
       With this in mind, is there a requirement for how 'clear and
       obvious' a crossover must be in order to be considered as such?
       Agree it was bad parking.  It was only there for 30 mins because
       I was blocked by the binmen.
       Best regards,
       CPBadger
       #Post#: 2733--------------------------------------------------
       Re: PCN 62 - Croydon Council - Parking on a footpath or on other
       than carriageway, Croydon
   DIR By: ivanleo
       Date: August 6, 2023, 11:36 am
       ---------------------------------------------------------
       You posted the informal rejection on pepipoo on 18 July (though
       you've hidden the date of issue for some reason), have you
       received a Notice to Owner?
       #Post#: 2734--------------------------------------------------
       Re: PCN 62 - Croydon Council - Parking on a footpath or on other
       than carriageway, Croydon
   DIR By: guest179
       Date: August 6, 2023, 11:53 am
       ---------------------------------------------------------
       [member=367]CPBadger[/member], we're not saying it is a
       crossover, the argument is that if the council claim it's
       footway then it must be a vehicle crossover because
       self-evidently it [assists] 'vehicles entering or leaving the
       carriageway across the footway..' to the garages.
       Of course it's not a crossover, it's a carriageway giving access
       to the garages, but the council have got to be faced with the
       stupidity of their position which is unavoidable by extension of
       the argument in their initial rejection!
       #Post#: 2929--------------------------------------------------
       Re: PCN 62 - Croydon Council - Parking on a footpath or on other
       than carriageway, Croydon
   DIR By: CPBadger
       Date: August 8, 2023, 2:56 pm
       ---------------------------------------------------------
       Thank you, I was confused about the definition of 'crossover'.
       All clear now!
       Yes cp8759, I've now received a Notice to Owner, which I'll
       respond to this week.
       Many thanks,
       CPBadger
       #Post#: 2930--------------------------------------------------
       Re: PCN 62 - Croydon Council - Parking on a footpath or on other
       than carriageway, Croydon
   DIR By: CPBadger
       Date: August 8, 2023, 3:25 pm
       ---------------------------------------------------------
       Here is the Notice to Owner:
  HTML https://ibb.co/d26x1SD
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