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       #Post#: 3771--------------------------------------------------
        52M Wandsworth Hillbrook Road Jct. Brudenell Road charge cert
   DIR By: Ken Masters
       Date: August 23, 2023, 1:01 pm
       ---------------------------------------------------------
       Porting over from this thread:
  HTML http://forums.pepipoo.com/index.php?showtopic=148778
       PCN is WA87399625 (not received)
       Wandsworth Council
       VRN LM53HJC
       See below charge certificate for a 12.12.2022 contravention
       allegation.
  HTML https://ibb.co/dKpx89x
       date of charge cert 22.02.23
       Was advised to wait for order for recovery and that the amount
       of the PCN should have been £130
       I have now received the OfR order for recovery.
       Will fill in the enclosed stautory declaration ticking the box
       stating that I did not receive the original PCN and get it
       witnessed by a commissioner for oaths. Then send the form to the
       Traffic Enforcement Centre.
       Anything else I should do at this stage?
       Thanks in advance.
       #Post#: 3937--------------------------------------------------
       Re:  52M Wandsworth Hillbrook Road Jct. Brudenell Road charge
       cert
   DIR By: ivanleo
       Date: August 27, 2023, 10:07 am
       ---------------------------------------------------------
       Send the completed form to tec@justice.gov.uk and then check the
       amount due on the council website once a week. Once it drops
       down to £65 it means the council has re-issued the PCN, to speed
       things up I'd then call the council and ask them to email you a
       copy.
       #Post#: 4874--------------------------------------------------
       Re:  52M Wandsworth Hillbrook Road Jct. Brudenell Road charge
       cert
   DIR By: Ken Masters
       Date: September 11, 2023, 9:22 am
       ---------------------------------------------------------
       Thank you for your guidance as ever cp8759!
       Following stat dec transmission - Wandsworth have reissued the
       PCN:
  HTML https://ibb.co/4ZbTSz8
       Earlier advice suggests the amount at £110 is incorrect and
       should be £130 - are there any grounds for appeal in this
       matter?
       #Post#: 4880--------------------------------------------------
       Re:  52M Wandsworth Hillbrook Road Jct. Brudenell Road charge
       cert
   DIR By: Pastmybest
       Date: September 11, 2023, 10:03 am
       ---------------------------------------------------------
       Yes without looking to much first the wrong amount then you have
       the time delay between the CC and OfR that is likely to win on
       its own
       #Post#: 4939--------------------------------------------------
       Re:  52M Wandsworth Hillbrook Road Jct. Brudenell Road charge
       cert
   DIR By: ivanleo
       Date: September 11, 2023, 5:48 pm
       ---------------------------------------------------------
       Have you got the revoking order from TEC?
       I heard TEC had quite a backlog and I wonder if the council
       jumped the gun and reissued the PCN before TEC issue the
       revoking order (which would be completely unlawful).
       Also the grounds of appeal on the council website don't match
       the statutory grounds:
  HTML https://i.imgur.com/H8iXoTV.png
       The TMO is The Wandsworth (School Streets) (No. 1) Order 2022
  HTML https://drive.google.com/uc?id=189AzXFXEc0UNH5iU-Zag8m1yG5Xgmaxu.
       #Post#: 5018--------------------------------------------------
       Re:  52M Wandsworth Hillbrook Road Jct. Brudenell Road charge
       cert
   DIR By: Ken Masters
       Date: September 12, 2023, 12:13 pm
       ---------------------------------------------------------
       Thank you both.
       Link below to the order stating the order for recovery be
       revoked:
  HTML https://ibb.co/hFfj8Vf
       Looks like the order is dated 30.8 whilst the PCN is 06.09.
       I can pen a basic appeal then along the lines of:
       - amount is wrong
       - grounds for appeal on council website don't match statutory
       grounds
       - time between charge cert and order for recovery was over 8
       months.
       Anything else I should add at this stage?
       #Post#: 5092--------------------------------------------------
       Re:  52M Wandsworth Hillbrook Road Jct. Brudenell Road charge
       cert
   DIR By: ivanleo
       Date: September 13, 2023, 6:10 pm
       ---------------------------------------------------------
       I think you've got all the key points, type up a draft and post
       it on here for review.
       #Post#: 5220--------------------------------------------------
       Re:  52M Wandsworth Hillbrook Road Jct. Brudenell Road charge
       cert
   DIR By: Ken Masters
       Date: September 15, 2023, 11:44 am
       ---------------------------------------------------------
       Kindly advise on amendments needed:
       Dear Sir/Madam,
       Ref: PCN WA87399625
       I would like to appeal the above PCN on the following grounds.
       1. The PCN states a penalty charge of £110 for contravention
       code 52M Failing to comply with a prohibition on certain types
       of vehicles (motor vehicles).
       Wandsworth Council's website lists 52M under "moving traffic
       contraventions all charged at the band A higher rate."
       Source:
  HTML https://www.wandsworth.gov.uk/parking/pcns-and-parking-fines/pcn-contravention-codes/#:~:text=If%20you%20receive%20a%20Penalty,%C2%A360%20(Band%20B).
       Band A higher rate is stated as £130. The above PCN meanwhile
       states the penalty charge for a 52M contravention as £110
       meaning it is invalid.
       2. The grounds of appeal on Wandsworth Council website do not
       match statutory grounds.
       There are eight statutory grounds of appeal (plus one more for
       PCNs served by post which isn't stated below) for appealing
       PCNs:
       The contravention did not occur
       The penalty charge exceeded the relevant amount
       The Traffic Regulation Order was invalid
       The motorist was not the owner/keeper of the vehicle at the time
       of the contravention
       The vehicle had been taken without the owner's consent
       The owner is a hire company and have supplied the name of the
       hirer
       There has been a procedural impropriety on behalf of the
       authority
       Penalty charge notice was paid either in full or at a discounted
       rate within the discount period.
       Wandsworth Council's website meanwhile only gives the following
       grounds:
       The contravention did not occur
       The vehicle was on hire
       The vehicle was sold
       Other
       3.The time delay between charge certificate and order for
       recovery.
       The charge certificate is dated 22nd February 2023 whilst the
       Order for Recovery is dated 31st August 2023. This equates to a
       period of 6 months and 9 days between postal dates of both
       documents.
       The time delay falls well outside of code of practice timeframes
       and constitutes further procedural impropriety on behalf of the
       Council.
       Yours sincerely,
       Name
       Registered keeper.
       #Post#: 5321--------------------------------------------------
       Re:  52M Wandsworth Hillbrook Road Jct. Brudenell Road charge
       cert
   DIR By: ivanleo
       Date: September 17, 2023, 1:14 pm
       ---------------------------------------------------------
       Here's a revised draft:
       [indent]
       Dear London Borough of Wandsworth,
       Ref: PCN WA87399625
       I would like to make representations against the above PCN on
       the following grounds.
       1. The PCN states a penalty charge of £110 for contravention
       code 52M Failing to comply with a prohibition on certain types
       of vehicles (motor vehicles).
       Wandsworth Council's website lists 52M under "moving traffic
       contraventions all charged at the band A higher rate."
       Source:
  HTML https://www.wandsworth.gov.uk/parking/pcns-and-parking-fines/pcn-contravention-codes/
       Band A higher rate is stated as £130. The above PCN meanwhile
       states the penalty charge for a 52M contravention as £110
       meaning it is invalid.
       2. The grounds of appeal on Wandsworth Council website do not
       match statutory grounds.
       There are five statutory grounds of appeal, which can be
       summarised as:
       [indent]
       1) the recipient was not the owner at the material time,
       2) the contravention did not occur,
       3) the vehicle was taken without the owner's consent, and
       4) the recipient is a hire firm and the vehicle was on hire, and
       5) the penalty charge exceeded the amount applicable in the
       circumstances of the case.
       [/indent]
       Wandsworth Council's website meanwhile only gives the following
       grounds:
       [indent]
       1) The contravention did not occur
       2) The vehicle was on hire
       3) The vehicle was sold
       4) Other
       [/indent]
       As "other" is not a statutory ground (and merely reflects the
       authority's power to cancel a PCN for non-statutory reasons),
       only 3 of the 5 statutory grounds of appeal are listed.
       The website is therefore misleading as to what grounds are
       applicable.
       3.The time delay between charge certificate and order for
       recovery.
       The charge certificate is dated 22nd February 2023 whilst the
       Order for Recovery is dated 31st August 2023. This equates to a
       period of 6 months and 9 days between postal dates of both
       documents.
       This is an inordinate delay within the meaning of Paul Richard
       Davis v The Royal Borough of Kensington and Chelsea (1970198981,
       30 March 1998), at least absent some good reason to justify the
       delay.
       It follows that the PCN must be cancelled,
       Yours faithfully,
       [/indent]
       Send the representation via the council website, and make sure
       to keep a screenshot of the confirmation screen. It's best to
       put it all in a PDF file and upload it to the website as an
       attachment, in order to get round any character limits and also
       to preserve all indentation and italics formatting.
       #Post#: 5381--------------------------------------------------
       Re:  52M Wandsworth Hillbrook Road Jct. Brudenell Road charge
       cert
   DIR By: Ken Masters
       Date: September 18, 2023, 8:29 am
       ---------------------------------------------------------
       Thank you Sir!
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