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#Post#: 90339--------------------------------------------------
Re: PCN - Kingsbury Road - parked without clearly displaying a
valid pay and display ticket or voucher
DIR By: Moaya
Date: September 17, 2025, 4:42 am
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It looks like they have just got in before the 56 day limit.
I will send my appeal as below unless you good folk advise
otherwise. Many thanks.
Dear Sir/Madam,
I make representations on the following grounds: The
contravention did not occur. As the authority will see from
their evidence (the CEO's photos) the restriction in effect is
given in the traffic sign which states: Pay by phone or Text or
Pay at the machine and display ticket. Clearly, displaying a
ticket is an optional matter for a motorist and therefore the
contravention grounds of 'Parked without displaying a ...ticket
or voucher' cannot be correct or even permissible contravention
grounds because, among other matters, they deny the owner the
defence of having purchased parking rights By Phone or Text.
Contravention grounds must be correct and comprehensive in order
to alert an owner to their possible applicable defences. If the
authority believes that use of these grounds where payment By
Phone or by Text or by purchasing and displaying a ticket are
valid then they must explain the legal basis for this assertion
when London Councils' Schedule of Contravention Descriptions
already lists the correct grounds i.e. Parked without payment of
the parking charge. I would also like to draw your attention to
the following case Lydia Russo v Plymouth City Council
(PL00004-2401, 12 March 2024) which was argued on similar
grounds and the adjudicator concluded the contravention did not
occur.
In addition, by the councils own admission they did not consider
the Lydia Russo vs Plymouth case cited above. Therefor as in the
case of Ivan Bachkov v London Borough of Newham (2250079444, 20
June 2025) they have failed to consider all the evidence
provided with the representations, so there has been substantial
non-compliance with the requirements of paragraph 1(7) of
Schedule 1 of the London Local Authorities and Transport for
London Act 2003.
Kind Regards,
#Post#: 90595--------------------------------------------------
Re: PCN - Kingsbury Road - parked without clearly displaying a
valid pay and display ticket or voucher
DIR By: Moaya
Date: September 19, 2025, 4:14 am
---------------------------------------------------------
Good Morning,
I have received a date for the hearing. This would be my first,
so I would appreciate any advice on what to expect and what I
need to prepare.
HTML https://imgur.com/a/tJSBX67
Thanks
#Post#: 108050--------------------------------------------------
Re: PCN - Kingsbury Road - parked without clearly displaying a
valid pay and display ticket or voucher
DIR By: Moaya
Date: January 30, 2026, 10:37 am
---------------------------------------------------------
Hello All,
I have received the evidence pack from the council. My tribunal
hearing is on the 12th of February.
Can anyone advise on the next steps and what to expect?
Thanks.
#Post#: 108051--------------------------------------------------
Re: PCN - Kingsbury Road - parked without clearly displaying a
valid pay and display ticket or voucher
DIR By: John U.K.
Date: January 30, 2026, 10:47 am
---------------------------------------------------------
In the Evidence Pack there should be
a 2-3 page document saying why they think the appeal should be
dismissed,
and
a list of contents.
Post these here and the experts here will let you know if they
need to see anything else.
EDIT
--- Quote ---
>
HTML https://imgur.com/a/tJSBX67
--- End Quote ---
Imgur cannot be seen in the UK - please use
ibb.co
HTML https://imgbb.com/
or
HTML https://imgpile.com/
for posting images.
Wherever possible, use the BBCode.)
#Post#: 108074--------------------------------------------------
Re: PCN - Kingsbury Road - parked without clearly displaying a
valid pay and display ticket or voucher
DIR By: Moaya
Date: January 30, 2026, 1:57 pm
---------------------------------------------------------
Ok thanks, I have attached the documents.
HTML https://imgpile.com/p/zedQBMS
#Post#: 108741--------------------------------------------------
Re: PCN - Kingsbury Road - parked without clearly displaying a
valid pay and display ticket or voucher
DIR By: Moaya
Date: February 4, 2026, 1:27 pm
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Can anyone offer any guidance on my case please, it is on the
12th of February.
Many thanks in advance.
#Post#: 108759--------------------------------------------------
Re: PCN - Kingsbury Road - parked without clearly displaying a
valid pay and display ticket or voucher
DIR By: fraser.mitchell
Date: February 4, 2026, 4:36 pm
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You wrote this in your original representations:-
--- Quote ---
> Therefor as in the case of Ivan Bachkov v London Borough of
Newham (2250079444, 20 June 2025) they have failed to consider
all the evidence provided with the representations, so there has
been substantial non-compliance with the requirements of
paragraph 1(7) of Schedule 1 of the London Local Authorities and
Transport for London Act 2003.
--- End Quote ---
Clearly you never bothered to look at the top of your PCN/NtO
where it clearly states the legislation under which the PCN was
served, namely the Traffic Management Act 2004, so this clause
of your reps needs removing. These things are important, because
it shows you were not diligent enough in submitting your
original reps. OK, you're not familiar with parking and traffic
law and we understand this. Do you prepare the original reps
using AI apps ?
#Post#: 108815--------------------------------------------------
Re: PCN - Kingsbury Road - parked without clearly displaying a
valid pay and display ticket or voucher
DIR By: Moaya
Date: February 5, 2026, 9:37 am
---------------------------------------------------------
Not familiar with parking and traffic law is an understatement.
No I did not use AI to generate the letter.
In the councils notice of rejection they indicated they did not
consider Lydia Russo v Plymouth City Council (PL00004-2401, 12
March 2024) with this statement" Furthermore, we note your
reference a Traffic Parking Tribunal (TPT) case, but we are
unable to view this on the TPT website. " . Is this not another
point of appeal? Strangely they were able to find this case with
no problem in the evidence pack they sent.
My intention was to find a case in which a case was thrown out
due to the council not considering the evidence put forth to
them. In my ignorance I used the legislation for moving
contraventions as opposed to parking. I believe the relevant
regulations I should have used to put my point across was,
regulation 5(2)(b) of the Civil Enforcement of Parking
Contraventions (England) Representations and Appeals Regulations
2007 which makes clear an Appellant is entitled to have the
points they raise properly considered by the Enforcement
Authority. I hope I am on the right track with this now.
Also in their statement they claim the Russo vs Plymouth City
Council case is irrelevant to my own as in that case a payment
was actually made and in my case no payment was ever made?
Do I need to submit anything to the tribunal before the hearing?
Appreciate all your feedback.
#Post#: 108849--------------------------------------------------
Re: PCN - Kingsbury Road - parked without clearly displaying a
valid pay and display ticket or voucher
DIR By: fraser.mitchell
Date: February 5, 2026, 1:56 pm
---------------------------------------------------------
You can either just say "I rely on my formal representations to
the council", or you prepare new reps with our help based on
your original reps.
#Post#: 108859--------------------------------------------------
Re: PCN - Kingsbury Road - parked without clearly displaying a
valid pay and display ticket or voucher
DIR By: Moaya
Date: February 5, 2026, 3:16 pm
---------------------------------------------------------
Please see below my new draft and kindly give me any feedback.
Do I need to send this to the council or tribunal before the
hearing?
Dear Sir/Madam,
I make representations on the following grounds the
contravention did not occur and there has been a Procedural
impropriety on the part of the Enforcment Authority.
1. The contravention did not occur. As the authority will see
from their evidence (the CEO's photos) the restriction in effect
is given in the traffic sign which states: Pay by phone or Text
or Pay at the machine and display ticket. Clearly, displaying a
ticket is an optional matter for a motorist and therefore the
contravention grounds of 'Parked without displaying a ...ticket
or voucher' cannot be correct or even permissible contravention
grounds because, among other matters, they deny the owner the
defence of having purchased parking rights By Phone or Text.
Contravention grounds must be correct and comprehensive in order
to alert an owner to their possible applicable defences. If the
authority believes that use of these grounds where payment By
Phone or by Text or by purchasing and displaying a ticket are
valid then they must explain the legal basis for this assertion
when London Councils' Schedule of Contravention Descriptions
already lists the correct grounds i.e. Parked
without payment of the parking charge. I would also like to draw
your attention to a precedent in the following case of Lydia
Russo v Plymouth City Council (PL00004-2401, 12 March 2024)
which was argued on similar grounds and the adjudicator
concluded the contravention did not occur. The council has
indicated that case is irrelevant as there is no evidence of
payment in my case. However one wonders if they have read the
judgment in full which stated in point 15 that " the
contravention alleged in the PCN did not occur because there was
no requirement to, and it was not possible to, display a valid
virtual pay & display ticket, even if Mr Russo had obtained one.
"
2. Procedural impropriety. By the councils own admission in the
Notice of Rejection they did not consider the Lydia Russo vs
Plymouth case cited above as they were unable to access it which
I find hard to believe as I was able to locate it a normal
member of the public. I believe the council did not consider the
evidence put forth to them as required by regulation 5(2)(b) of
the Civil Enforcement of Parking Contraventions (England)
Representations and Appeals Regulations 2007 which makes clear
an Appellant is entitled to have the points they raise properly
considered by the Enforcement Authority. I would like to refer
to previous hearing number 2210280742 in which the adjudicator
stated the following " In my judgment an Appellant is entitled
to have the points they raise properly considered by the
Enforcement Authority pursuant to its duty under regulation
5(2)(b). On this occasion the authority has failed to do this. "
Kind Regards,
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