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       #Post#: 6594--------------------------------------------------
       Failure to identify driver
   DIR By: Bertieboo
       Date: October 3, 2023, 5:59 am
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       on 16/12/2022 my wife received an ITP from Devon ans Cornwall
       Police for speeding 'on the A30 Roseworthy Eastbound@ for
       'exceeding 60mph'. The alledged recorded speed was 69mph.
       we would not recall 100% who was driving ( we are both insured
       on the vehicle) so we asked for assistance in identifying the
       driver (letter to the 21/12/2022).
       The images they sent on 17/1/2023 showed the rear of the
       vehicle. Identity of the driver was impossible - 'unfortunately
       in this instance the images are rear facing only. You may be
       able to refer to the offence location, time, diary entries, or
       phone records (both bizarre requests) to identify who was
       driving at the time of the alleged offence.'
       My wife replied on 26th January ' my husband and I have thought
       very carefully about this matter and understand our obligations
       to take all reasonable steps to identify who was driving. We re
       unable to be certain who was driving at the time. We are aware
       that it is a further offence to make a false declaration and
       regretfully we just cannot truthfully identify who was driving.'
       D&CP responded on 6/2/2023 saying we have failed to comply with
       section 172 and the case is forwarded for court proceedings.
       She received the SJP on 26/6/2023. we replied under Section 4
       NOT GUILTY
       Section 5 - we sent reasons for the not guilty plea.
       Summons received to attend Court on 13/12/2023.
       What do we do now?
       #Post#: 6609--------------------------------------------------
       Re: Failure to identify driver
   DIR By: Southpaw82
       Date: October 3, 2023, 7:09 am
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       Presumably your wife’s defence will be that she did not know who
       the driver was and could not work it out, having exercised
       reasonable diligence. That then begs the question, what
       reasonable diligence did she carry out?
       #Post#: 6613--------------------------------------------------
       Re: Failure to identify driver
   DIR By: Bertieboo
       Date: October 3, 2023, 8:14 am
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       We were both in the car. We were travelling for a week from
       Herefordshire to Devon, then Cornwall, then back home. We had 4
       dogs in the car - 3 our own and one border collie we were
       looking after. It was very stressful. Our dogs were caged and
       the collie restrained. The collie barked, whined and
       occasionally was very argumentative with our other dogs. We
       shared the driving, with the passenger basically keeping them
       distracted, quiet etc. We had to use google maps to see where
       the camera was and to then think who was driving then...which we
       couldn't answer. We were being honest. The easiest way would
       have been to say I was driving..but we were not sure.
       #Post#: 6614--------------------------------------------------
       Re: Failure to identify driver
   DIR By: Bertieboo
       Date: October 3, 2023, 8:19 am
       ---------------------------------------------------------
       Attached is the pleas made and enclosed with the posted plea
       [attachment deleted by admin]
       #Post#: 6615--------------------------------------------------
       Re: Failure to identify driver
   DIR By: AntonyMMM
       Date: October 3, 2023, 8:30 am
       ---------------------------------------------------------
       Only "knowingly or intentionally" naming the wrong driver would
       be an offence - the pragmatic approach in this sort of
       situation, is usually to name the mostly likely driver.
       The case has now been progressed to court and trials aren't
       carried out on paper submissions so your wife will have to
       attend and answer the charge. If she can convince the court that
       she did use "reasonable diligence" and could not identify the
       driver then she should be acquitted - but courts are very
       sceptical and will expect a very detailed account of what she
       did to try - and why it failed.
       We do sometimes hear of examples of courts being sympathetic to
       a registered keeper in this position and finding them not
       guilty, but she needs to understand that it is a risk and the
       costs for losing will be significant.
       #Post#: 6624--------------------------------------------------
       Re: Failure to identify driver
   DIR By: NewJudge
       Date: October 3, 2023, 9:03 am
       ---------------------------------------------------------
       --- Quote ---
       > Summons received to attend Court on 13/12/2023.
       > What do we do now?
       --- End Quote ---
       First of all, there is no "we" involved here. The proceedings
       are only issued against one of you - presumably your wife.
       She will have to attend court on the appointed date and face a
       trial. The prosecution will produce their evidence which they
       say, supports the charge. That will be evidence of the request
       made by the police and evidence of your wife's reply.  Without
       any evidence from your wife she will undoubtedly be convicted.
       She has the opportunity to take advantage of the statutory
       defence which says this:
       "A person shall not be guilty of an offence.....if he shows that
       he did not know and could not with reasonable diligence have
       ascertained who the driver of the vehicle was."
       Unfortunately your explanation demonstrates that she has
       exercised no diligence whatsoever. It simply describes the
       circumstances prevailing at the time the speeding offence was
       alleged to have taken place and that, due to those circumstances
       you cannot, between you, recall who was driving. The requirement
       to exercise diligence (in establishing who the driver was)
       begins when the request is served. She seems to have done
       nothing since then (not that you've explained here, anyway).
       The camera's function is to identify the vehicle, not the driver
       and your protestations that it was facing the "wrong" way are
       irrelevant. The suggestions that the police made to help you
       establish who was driving are not bizarre. In fact they are
       among the suggestions that you might receive on here had you
       asked how to tackle your situation before your wife responded to
       the s172 request. One of the parties might, for example check
       their phone records and note that a call was in progress at the
       relevant time and so indicate that (hopefully) they were not
       driving.
       I'm afraid from your explanation your wife faces almost certain
       conviction. If it was as simple as turning up to say "can't
       remember who was driving, guv" (which is effectively what she
       has already said) everybody would do it and speeding enforcement
       would be impossible. The offence carries six points, a hefty
       fine and an endorsement code (MS90) which will probably see
       increased insurance premiums for up to five years.
       #Post#: 6625--------------------------------------------------
       Re: Failure to identify driver
   DIR By: Bertieboo
       Date: October 3, 2023, 9:08 am
       ---------------------------------------------------------
       Our ‘reasonable diligence’ was asking if there was a front
       facing photo (didn’t help) but which helped us to also find the
       camera location to work out who was driving. If it comes down to
       ‘what is most likely’, then we can say who. We didn’t think it
       was right to guess (could the police have other photographic
       evidence proving or disproving our plea?)
       Can we put this forward to the court in writing now or do we
       have to travel to the court to answer the summons?
       The summons reason is ‘For a case management hearing (deft to
       attend). What does that mean?
       #Post#: 6634--------------------------------------------------
       Re: Failure to identify driver
   DIR By: BertB
       Date: October 3, 2023, 10:56 am
       ---------------------------------------------------------
       Unless your wife has been dual charged with both speeding and
       failure to furnish, the opportunity to plead guilty to the
       speeding is gone. But again, there is no 'we' or 'our'. It is
       just your wife that has been charged.
       However it looks like you are suggesting it would be you putting
       your hands up as the most likely driver which now becomes
       impossible to do, even with the dual charge. Only your wife can
       do a deal to admit to the speeding in return for dropping the
       FTF charge.
       Just asking for pictures will not pass the test of reasonable
       diligence though. If you think about it, if just not knowing was
       a defence, we would all use it. It sounds like the actual
       journey was quite memorable. How far were you driving and how
       many times did you swap on that journey?
       Diary entries and Phone records are not bizarre requests.
       Obviously It doesn't quite work when you are both together in
       the vehicle, but its intention is to identify if someone had a
       reason to be on that journey. Likewise, phone records can show
       travel timeline in maps, whether phone calls were made, or texts
       sent that indicated who might be driving.
       #Post#: 6637--------------------------------------------------
       Re: Failure to identify driver
   DIR By: Gilan02
       Date: October 3, 2023, 11:06 am
       ---------------------------------------------------------
       Was the camera location not specified on the NIP?
       #Post#: 6644--------------------------------------------------
       Re: Failure to identify driver
   DIR By: Bertieboo
       Date: October 3, 2023, 11:58 am
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       Yes it was
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