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       #Post#: 54759--------------------------------------------------
       Re: Bromley council. Charge Certif. PCN code 27, parked on
       Albemarle road blocked with flower pot.no sig
   DIR By: John U.K.
       Date: January 23, 2025, 12:43 pm
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       Please to post up all sides of the NtO, redacting only yr name &
       address.
       #Post#: 54784--------------------------------------------------
       Re: Bromley council. Charge Certif. PCN code 27, parked on
       Albemarle road blocked with flower pot.no
   DIR By: Justicenow
       Date: January 23, 2025, 2:10 pm
       ---------------------------------------------------------
       --- Quote from: John U.K. link ---
       >
       > Please to post up all sides of the NtO, redacting only yr name
       & address.
       >
       --- End Quote ---
       Please see the pages of the NTO here
  HTML https://www.dropbox.com/scl/fi/v9ipq63ruapznqf3zk1ki/NTO-parking-fine.pdf?rlkey=sv1vavs284n77viepg7fnsdhg&st=35a52wgl&dl=0
       #Post#: 54809--------------------------------------------------
       Re: Bromley council. Charge Certif. PCN code 27, parked on
       Albemarle road blocked with flower pot.no sig
   DIR By: fraser.mitchell
       Date: January 23, 2025, 4:29 pm
       ---------------------------------------------------------
       OK, so I presume you parked here ?
  HTML https://maps.app.goo.gl/DuGrsRFqkcLsmrYs9
       The PCN was served because you were parked adjacent to a dropped
       kerb.  I have captured the GSV view that shows a dropped kerb on
       each side of the now-unused stub of road. If you were parked
       obstructing either of those dropped kerbs then the contravention
       is made out, as far as I can see.
       A look at the CEO photos on the Bromley webpages, shows your car
       parked in the middle of the road stub, and when compared to my
       GSV view, clearly demonstrates a contravention. It is difficult
       to see how any car could park in this very small stub of a road
       and not block the dropped footways, frankly.
       There may be a 'technical' appeal which other posters may
       suggest, so wait a bit to see if anything turns up.  I had a
       quick look on the Bromley council web pages which lists the
       statutory grounds for representations, but only allows one to be
       selected, which is not correct; an appellant can select more
       than one in accordance with the regulations.
       See here, Chapter 2 5(2)(b) (i) and (ii)
  HTML https://www.legislation.gov.uk/ukdsi/2022/9780348232752/part/2/chapter/2
       Would this failure not fully to follow the above regulation win
       at the adjudicators, London Tribunals ? One would hope so, but
       you'd have to risk the full PCN penalty to find out.
       #Post#: 54812--------------------------------------------------
       Re: Bromley council. Charge Certif. PCN code 27, parked on
       Albemarle road blocked with flower pot.no sig
   DIR By: ivanleo
       Date: January 23, 2025, 4:35 pm
       ---------------------------------------------------------
       Photos:
  HTML https://i.imgur.com/66G3Yxz.jpeg
  HTML https://i.imgur.com/NEix64q.jpeg
       The most blatantly obvious ground of appeal is that the PCN was
       not served, hence service of a Notice to Owner is a procedural
       impropriety.
       [member=3567]Justicenow[/member] did you see the CEO? Or did you
       come back to your car and not see anything untoward at all?
       #Post#: 54823--------------------------------------------------
       Re: Bromley council. Charge Certif. PCN code 27, parked on
       Albemarle road blocked with flower pot.no sig
   DIR By: Severndroog
       Date: January 23, 2025, 5:17 pm
       ---------------------------------------------------------
       I use that road regularly and have spotted vehicles parked on
       that stub. It clearly is a stub, rather than a nonfunctional
       road.  The kerb is yellow lined. In order to park there the
       driver has to ignore the bollard, but I don’t think it has a
       keep left sign on it. It’s hard to see that parking there causes
       any sort of obstruction to road traffic but it does
       inconvenience pedestrians with wheelchairs/walking
       frames/buggies wishing to cross the road using the dropped
       kerbs.
       Will be fascinating to see the outcome.
       #Post#: 54827--------------------------------------------------
       Re: Bromley council. Charge Certif. PCN code 27, parked on
       Albemarle road blocked with flower pot.no sig
   DIR By: ivanleo
       Date: January 23, 2025, 5:25 pm
       ---------------------------------------------------------
       [member=1905]Severndroog[/member] parking in this way is at
       least two if not three contraventions: obstructing a dropped
       kerb, contravening a single yellow line waiting restriction
       (during prescribed hours), and possibly parking more than 50 cm
       from the carriageway. While we may well be able to help
       Justicenow get his PCN cancelled, parking in this way is clearly
       unlawful.
       #Post#: 54828--------------------------------------------------
       Re: Bromley council. Charge Certif. PCN code 27, parked on
       Albemarle road blocked with flower pot.no sig
   DIR By: fraser.mitchell
       Date: January 23, 2025, 5:26 pm
       ---------------------------------------------------------
       edited
       #Post#: 54829--------------------------------------------------
       Re: Bromley council. Charge Certif. PCN code 27, parked on
       Albemarle road blocked with flower pot.no sig
   DIR By: ivanleo
       Date: January 23, 2025, 5:31 pm
       ---------------------------------------------------------
       --- Quote from: Incandescent link ---
       >
       > [quote author=cp8759 link=topic=4115.msg54812#msg54812
       date=1737671722]
       > [member=3567]Justicenow[/member] did you see the CEO? Or did
       you come back to your car and not see anything untoward at all?
       >
       --- End Quote ---
       But photos of any kind are not a legal requirement, so the
       absence of a PCN yellow envelope is not definite proof of
       non-service.
       [/quote]
       If the matter is raised it is for the council to prove that the
       PCN was served, it is not for the motorist to prove that it
       wasn't, the standard of evidence is the balance of
       probabilities. At this stage I'm simply trying to establish what
       evidence Justicenow can give us.
       #Post#: 54845--------------------------------------------------
       Re: Bromley council. Charge Certif. PCN code 27, parked on
       Albemarle road blocked with flower pot.no sig
   DIR By: Justicenow
       Date: January 23, 2025, 10:03 pm
       ---------------------------------------------------------
       --- Quote from: cp8759 link ---
       >
       > [quote author=Incandescent link=topic=4115.msg54828#msg54828
       date=1737674794]
       > [quote author=cp8759 link=topic=4115.msg54812#msg54812
       date=1737671722]
       > [member=3567]Justicenow[/member] did you see the CEO? Or did
       you come back to your car and not see anything untoward at all?
       >
       --- End Quote ---
       But photos of any kind are not a legal requirement, so the
       absence of a PCN yellow envelope is not definite proof of
       non-service.
       [/quote]
       If the matter is raised it is for the council to prove that the
       PCN was served, it is not for the motorist to prove that it
       wasn't, the standard of evidence is the balance of
       probabilities. At this stage I'm simply trying to establish what
       evidence Justicenow can give us.
       [/quote]
       Thank you for looking into the details. I did see the CEO when I
       returned to my car, after being parked there only for a couple
       of minutes. I started to move the car from that spot while the
       officer was still preparing and printing the ticket. While I was
       moving the car, he tried to stick the envelope on my moving
       car’s windscreen but could not do that properly and I didn’t let
       him take a photo. I was confident that there was no
       contravention because there aren’t any signs there at all. I
       parked on the left side where there is no yellow line, but it is
       a dropped curb on both sides though. Previously, I spoke with
       other road users who had successfully appealed their parking
       tickets, being parked in that same spot, who shared with me
       that, apparently, because of the changes in the road layout and
       flower pot blocking it, the general rules do not apply (which
       might not be true).
       #Post#: 54852--------------------------------------------------
       Re: Bromley council. Charge Certif. PCN code 27, parked on
       Albemarle road blocked with flower pot.no sig
   DIR By: H C Andersen
       Date: January 24, 2025, 3:41 am
       ---------------------------------------------------------
       Interesting legal issue here IMO:
       86Prohibition of parking at dropped footways etc.
       (1)In a special enforcement area a vehicle must not be parked on
       the carriageway adjacent to a footway, cycle track or verge
       where—...(the rest is not germane)
       So is > 50cm adjacent?
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