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       #Post#: 70302--------------------------------------------------
       Re: Code:31 J Entering & Stopping in a Box Junction
   DIR By: mitaab
       Date: May 6, 2025, 2:53 pm
       ---------------------------------------------------------
       --- Quote from: Hippocrates link ---
       >
       > Nope. I will draft later as this is slightly more complicated
       than the case won.
       >
       --- End Quote ---
       Much obliged!
       #Post#: 70401--------------------------------------------------
       Re: Code:31 J Entering & Stopping in a Box Junction
   DIR By: Hippocrates
       Date: May 7, 2025, 8:16 am
       ---------------------------------------------------------
       I am snowed under with cases but will do a draft later today.
       Best to get it right first time.
       #Post#: 70414--------------------------------------------------
       Re: Code:31 J Entering & Stopping in a Box Junction
   DIR By: mitaab
       Date: May 7, 2025, 9:31 am
       ---------------------------------------------------------
       --- Quote from: Hippocrates link ---
       >
       > I am snowed under with cases but will do a draft later today.
       Best to get it right first time.
       >
       --- End Quote ---
       Fully agree. I look forward to receiving the draft, many thanks!
       Take your time. On the LA website, it says "The amount
       outstanding on the Penalty Charge Notice will increase to
       £160.00 on Wed, 14 May 2025. Please pay £80.00 now." Plenty of
       time.
       #Post#: 70427--------------------------------------------------
       Re: Code:31 J Entering & Stopping in a Box Junction
   DIR By: Hippocrates
       Date: May 7, 2025, 11:21 am
       ---------------------------------------------------------
       That date is wrong. It increases on day 15 from the date of the
       PCN.
       #Post#: 70632--------------------------------------------------
       Re: Code:31 J Entering & Stopping in a Box Junction
   DIR By: Hippocrates
       Date: May 9, 2025, 4:58 am
       ---------------------------------------------------------
       Dear Council
       I make these two collateral challenges:
       The PCN
       The PCN wrongly states which action triggers the period in which
       the council may serve a charge certificate: “If the Penalty
       Charge is not paid before the end of the period of 28 days
       beginning with the date of service of this notice an increased
       charge of £240.00 (less money paid) may be payable and a  Charge
       Certificate may be sent on you seeking this amount.” The law
       states at Schedule 1 5:
       1)Where a penalty charge notice is served on any person and the
       penalty charge to which it relates is not paid before the end of
       the relevant period, the enforcing authority may serve on that
       person a statement (in this paragraph referred to as a “charge
       certificate”) to the effect that the penalty charge in question
       is increased by 50 per cent.
       (2)The relevant period, in relation to a penalty charge notice
       is the period of 28 days beginning—
       (a)where no representations are made under paragraph 1 above,
       with the date on which the penalty charge notice is served;
       Further, the PCN does not inform me with regard to the service
       of a Charge Certificate if representations are not made by the
       end of the said period. Please refer to Case No: 224038612A.
       The website
       The date regarding the increase to £160 is clearly wrong. It is
       essential that appellants are correctly informed of the
       statutory dates of what and when to pay.
       In light of the above, please cancel the PCN
       ***
       Keep a screenshot of the website and adduce it as evidence. I
       cannot access as do not have the PCN and VRM details!
       #Post#: 75299--------------------------------------------------
       Re: Code:31 J Entering & Stopping in a Box Junction
   DIR By: mitaab
       Date: June 7, 2025, 3:48 pm
       ---------------------------------------------------------
       Notice of Rejection!
       Received the NoR, in which the LA completely turned a blind eye
       to my ground of representations, as recommended by
       [member=24]Hippocrates[/member], and didn't mention a single
       word about it. Is this act not considered 'frivolous, vexatious
       or wholly unreasonable'?
       NoR_1:
  HTML https://ibb.co/MxvXh3Mn
       NoR_2:
  HTML https://ibb.co/TDgQzvCZ
       #Post#: 75304--------------------------------------------------
       Re: Code:31 J Entering & Stopping in a Box Junction
   DIR By: Pastmybest
       Date: June 7, 2025, 4:10 pm
       ---------------------------------------------------------
       I made this argument to the TPT with regards to a fail to
       concider It won the day as the adjudicator did not find on the
       other arguments
       Extract from the appeal decision by the adjudicator
       3. When Mr Yousef made both informal and formal representations
       to the council in respect of the PCN he referred to the grounds
       of appeal as detailed above but in rejecting those challenges
       the council did not address the limb of his appeal that was
       concerned with the method of payment using a premium rate
       telephone number. It was therefore Mr Allen’s submission that in
       failing to respond to this ground of appeal there had been a
       procedural impropriety on the part of the council, a further
       ground of appeal and that the PCN should not then be enforced.
       Mr Allen provided case law in support of his submission,
       specifically The King (On the application of Halton Borough
       Council) and Road User Charging Adjudicators and Damian Curzon
       [2023] EWHC 303 Admin, provided at evidence tab 23 and it was
       his view I should determine the appeal without adjourning to
       enable the council to respond to his submissions in these
       respects.
       4. In considering Mr Allen’s submissions it was my view that the
       council should have a further opportunity to address the issues
       relating to the use of a premium phone line to pay the PCN and
       the issue of procedural impropriety and I adjourned the hearing
       to enable the council to respond by January 8th 2024. To date
       the council has not responded and so I have considered the
       appeal on the basis of the evidence that is available to me.
       5. In The King (On the application of Halton Borough Council)
       and Road User Charging Adjudicators and Damian Curzon [2023] Mr
       Justice Fordham considered the extent to which there had been
       procedural impropriety on the part of the council and or their
       agents in the consideration of representations made to them
       following the issue of PCNs and he said, “The "procedural
       impropriety" enquiry is straightforward and clear-cut. It would
       ask: has there been consideration at all?” and whilst the
       council did deal with the other limbs of Mr Yousef’s appeal, I
       cannot find there has been any consideration of the submissions
       in respect of the premium phone line and for this reason alone I
       would find there has been a procedural impropriety and I would
       allow the appeal.
       #Post#: 75308--------------------------------------------------
       Re: Code:31 J Entering & Stopping in a Box Junction
   DIR By: mitaab
       Date: June 7, 2025, 4:53 pm
       ---------------------------------------------------------
       --- Quote from: Pastmybest link ---
       >
       > I made this argument to the TPT with regards to a fail to
       concider It won the day as the adjudicator did not find on the
       other arguments
       >
       >
       > Extract from the appeal decision by the adjudicator
       >
       > 3. When Mr Yousef made both informal and formal
       representations to the council in respect of the PCN he referred
       to the grounds of appeal as detailed above but in rejecting
       those challenges the council did not address the limb of his
       appeal that was concerned with the method of payment using a
       premium rate telephone number. It was therefore Mr Allen’s
       submission that in failing to respond to this ground of appeal
       there had been a procedural impropriety on the part of the
       council, a further ground of appeal and that the PCN should not
       then be enforced. Mr Allen provided case law in support of his
       submission, specifically The King (On the application of Halton
       Borough Council) and Road User Charging Adjudicators and Damian
       Curzon [2023] EWHC 303 Admin, provided at evidence tab 23 and it
       was his view I should determine the appeal without adjourning to
       enable the council to respond to his submissions in these
       respects.
       > 4. In considering Mr Allen’s submissions it was my view that
       the council should have a further opportunity to address the
       issues relating to the use of a premium phone line to pay the
       PCN and the issue of procedural impropriety and I adjourned the
       hearing to enable the council to respond by January 8th 2024. To
       date the council has not responded and so I have considered the
       appeal on the basis of the evidence that is available to me.
       > 5. In The King (On the application of Halton Borough Council)
       and Road User Charging Adjudicators and Damian Curzon [2023] Mr
       Justice Fordham considered the extent to which there had been
       procedural impropriety on the part of the council and or their
       agents in the consideration of representations made to them
       following the issue of PCNs and he said, “The "procedural
       impropriety" enquiry is straightforward and clear-cut. It would
       ask: has there been consideration at all?” and whilst the
       council did deal with the other limbs of Mr Yousef’s appeal, I
       cannot find there has been any consideration of the submissions
       in respect of the premium phone line and for this reason alone I
       would find there has been a procedural impropriety and I would
       allow the appeal.
       >
       --- End Quote ---
       Much obliged, [member=156]Pastmybest[/member].
       Prior to receiving your post, I was hesitating between paying
       the £80 and going to the Tribunal. Now I have decided to take it
       all the way to the Tribunal.
       #Post#: 75317--------------------------------------------------
       Re: Code:31 J Entering & Stopping in a Box Junction
   DIR By: Hippocrates
       Date: June 8, 2025, 1:30 am
       ---------------------------------------------------------
       Take your pick as to your representative.  ;D I have made a
       formal complaint under The Nolan Principles.
       #Post#: 75392--------------------------------------------------
       Re: Code:31 J Entering & Stopping in a Box Junction
   DIR By: Pastmybest
       Date: June 8, 2025, 11:35 am
       ---------------------------------------------------------
       --- Quote from: Hippocrates link ---
       >
       > Take your pick as to your representative.  ;D I have made a
       formal complaint under The Nolan Principles.
       >
       --- End Quote ---
       I will not be doing any cases at tribunal whilst i continue my
       recuperation so take it Hippo, use the quote if yu want or the
       case is on cp's file also the high court ruling
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