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       #Post#: 54858--------------------------------------------------
       Re: Bromley council. Charge Certif. PCN code 27, parked on
       Albemarle road blocked with flower pot.no sig
   DIR By: ivanleo
       Date: January 24, 2025, 4:27 am
       ---------------------------------------------------------
       Easy peasy lemon squeezy:
       [indent]
       Dear London Borough of Bromley,
       I challenge liability on the basis of a procedural impropriety:
       no regulation 9 PCN was served, so the council was not
       authorised to serve a Notice to Owner.
       I did see the CEO when I returned to my car, 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 he was
       unable to do so and I drove off.
       In the circumstances a postal PCN could have been served under
       regulation 10, but a Notice to Owner cannot be served in these
       circumstances.
       It follows that the PCN must be cancelled.
       Yours faithfully,
       [/indent]
       Send this online and take a dated & timed screenshot of the
       confirmation page.
       #Post#: 55028--------------------------------------------------
       Re: Bromley council. Charge Certif. PCN code 27, parked on
       Albemarle road blocked with flower pot.no sig
   DIR By: Justicenow
       Date: January 25, 2025, 6:52 am
       ---------------------------------------------------------
       Thank you for this advice. I appreciate it very much and
       understand that for the PCN to be considered served in person at
       the spot, it should have been attached on a stationary car and
       stay on it. But as it wasn’t the council should have posted the
       PCN to my address before issuing the NTO. The CEO should not
       throw himself on a moving vehicle risking an injury. I submit my
       appeal as suggested on the basis that the PCN wasn’t served
       properly. Let’s see what the council will respond with.
       However, [member=428]H C Andersen[/member], in your comment you
       are asking if my car was parked less than 50 cm to the dropped
       kerb in a special enforcement area? And if it was then it’s a
       contravention? There are no signs there to say it’s a special
       enforcement area, shouldn’t it be clearly signposted? That part
       of the road is not a functioning carriageway anymore, at least
       in that little bit of the island, since they blocked it, would
       this regulation still apply here? Just curious to know. Thank
       you very much once again.
       #Post#: 55038--------------------------------------------------
       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 25, 2025, 7:30 am
       ---------------------------------------------------------
       No, that's not my point. Rather, the issue for me is that IMO
       you were clearly in contravention of one of two mutually
       exclusive statutory prohibitions i.e. if you were >50cm then
       this is a contravention in itself, and if you weren't then this
       is being 'parked adjacent to'.
       IMO, you were >50cm therefore you would be fortunate in that the
       CEO's grounds won't fly.
       I highlighted the relevant part of the statutory* prohibition.
       cp's reasoning is predicated on your account and that there
       aren't photos of the PCN having been affixed to the car. The
       rules regarding service are:
       a)fixing a penalty charge notice to the vehicle, or
       (b)giving a penalty charge notice to the person appearing to the
       civil enforcement officer to be in charge of the vehicle.
       We haven't seen the CEO's notes, but if they do not support
       (b)(which wouldn't need photos) then there is no reason why the
       procedural grounds should not succeed. My argument, if accepted
       by an adjudicator, doesn't rely upon a PCN being served anyway.
       But even if you were to succeed on the narrow point of procedure
       in this case, IMO you were in contravention of one of two
       statutory prohibitions and subject to the yellow line waiting
       restriction if this was in effect at the time.
       In short, don't park there because for any competent CEO this
       would be open house.
       *- being statutory it doesn't require signs nor an understanding
       of SEAs on the part of the motorist.
       #Post#: 55067--------------------------------------------------
       Re: Bromley council. Charge Certif. PCN code 27, parked on
       Albemarle road blocked with flower pot.no sig
   DIR By: ivanleo
       Date: January 25, 2025, 9:38 am
       ---------------------------------------------------------
       --- Quote from: H C Andersen link ---
       >
       > No, that's not my point. Rather, the issue for me is that IMO
       you were clearly in contravention of one of two mutually
       exclusive statutory prohibitions i.e. if you were >50cm then
       this is a contravention in itself, and if you weren't then this
       is being 'parked adjacent to'.
       >
       --- End Quote ---
       You're giving a very, very narrow reading to the words "parked
       adjacent to", it is pretty obvious that on a purposive
       interpretation this means on the side of the road where the
       dropped kerb is. Honestly I would be concerned in advancing this
       argument because the adjudicator might think the appellant is
       taking the proverbial.
       #Post#: 55069--------------------------------------------------
       Re: Bromley council. Charge Certif. PCN code 27, parked on
       Albemarle road blocked with flower pot.no sig
   DIR By: ivanleo
       Date: January 25, 2025, 9:42 am
       ---------------------------------------------------------
       --- Quote from: Justicenow link ---
       >
       > That part of the road is not a functioning carriageway
       anymore, at least in that little bit of the island, since they
       blocked it, would this regulation still apply here? Just curious
       to know. Thank you very much once again.
       >
       --- End Quote ---
       As far as I'm aware any vehicle that isn't mechanically
       propelled (i.e. a bicycle, pedestrian operated vehicle) and any
       animal (horses, ponies) can still use that carriageway, and I'm
       sure an exempt motor vehicle can as well (such as a police
       motorcyclist). If it isn't a carriageway at all then you'd
       commit a different contravention of being parked on a part of a
       road other than a carriageway, which is also a statutory
       contravention.
       The long and the short of it remains that while we can almost
       certainly get this PCN cancelled on procedural grounds, it is
       actually illegal to park there and if you park there again and
       the council does everything by the book, you might not be able
       to get out of it.
       #Post#: 55086--------------------------------------------------
       Re: Bromley council. Charge Certif. PCN code 27, parked on
       Albemarle road blocked with flower pot.no sig
   DIR By: Justicenow
       Date: January 25, 2025, 11:50 am
       ---------------------------------------------------------
       OK, understood, so it does appear that I am skating on a very
       thin ice here. The CEO might have put in the notes that the PCN
       was served, as it says exactly that in the NTO letter that I
       received recently. He might say that I  prevented him from
       giving me the PCN when he tried to put it on my moving car.
       Will definitely avoid this kind of traps in future, it will be a
       very good lesson to learn (and potentially expensive). Thank you
       for the explanations.
       #Post#: 55087--------------------------------------------------
       Re: Bromley council. Charge Certif. PCN code 27, parked on
       Albemarle road blocked with flower pot.no sig
   DIR By: ivanleo
       Date: January 25, 2025, 11:53 am
       ---------------------------------------------------------
       --- Quote from: Justicenow link ---
       >
       > The CEO might have put in the notes that the PCN was served,
       as it says exactly that in the NTO letter that I received
       recently.
       >
       --- End Quote ---
       I wouldn't worry about that, at the end of the day the NTO is
       just a standard templated document, and the CEO isn't going to
       come to any tribunal hearing to give oral evidence.
       #Post#: 55088--------------------------------------------------
       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 25, 2025, 12:21 pm
       ---------------------------------------------------------
       I posited that >50 means not adjacent which if advanced should
       of course be caveated with a recognition that they should not
       have parked there. But just as it's a very technical argument to
       distinguish between the contraventions of a raised carriageway
       and a dropped kerb, then IMO so it is here, but nonetheless
       could be advanced at least at the NTO stage to test the
       authority's position.
       OP, you misunderstand the point that's being made:
       He might say that I  prevented him from giving me the PCN when
       he tried to put it on my moving car.
       Let's hope the notes DO say this because if so it prevents them
       serving a NTO. This is procedural.
       If a regulation 9 PCN is affixed to the car or handed to the
       person in control then the next stage is a NTO. However, if the
       CEO was prevented then the ONLY course available to the
       authority is the serve a PCN by post.
       #Post#: 55113--------------------------------------------------
       Re: Bromley council. Charge Certif. PCN code 27, parked on
       Albemarle road blocked with flower pot.no sig
   DIR By: fraser.mitchell
       Date: January 25, 2025, 3:58 pm
       ---------------------------------------------------------
       The plain fact here is that as correctly identified by CP8759,
       the council failed to follow the legal process after a
       "drive-away". They served an NtO, not a Reg 10 PCN, (postal
       pcn). By doing this they committed a procedural impropriety and
       also robbed the OP of his option to pay the discounted amount.
       #Post#: 62731--------------------------------------------------
       Re: Bromley council. Charge Certif. PCN code 27, parked on
       Albemarle road blocked with flower pot.no sig
   DIR By: Justicenow
       Date: March 16, 2025, 5:28 am
       ---------------------------------------------------------
       Thank you for all the advice and explanations. Very much
       appreciate all your help.
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