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       #Post#: 80563--------------------------------------------------
       Re: Redbridge - failing to comply with a restriction on vehicles
   DIR By: Hippocrates
       Date: July 11, 2025, 5:38 am
       ---------------------------------------------------------
       I mean what you are going to say.
       #Post#: 80680--------------------------------------------------
       Re: Redbridge - failing to comply with a restriction on vehicles
   DIR By: bigred247
       Date: July 12, 2025, 5:25 am
       ---------------------------------------------------------
       [member=24]Hippocrates[/member]
       Should I say "I rely upon my initial representation"? I have
       quoted my representation below. Do you feel this needs
       adjusting?
       --- Quote from: bigred247 link ---
       >
       > I just cooked up this draft as a backup just in case. Not sure
       its that great but worth a punt. I'll hold of til 1130pm'ish
       otherwise will make reps.
       >
       > [quote]Dear Sir/Madam,
       >
       > I am writing to make formal representations against the
       issuance of the above Penalty Charge Notice, served for an
       alleged contravention under code 52M — Failing to comply with a
       restriction on motor vehicles (motor vehicles prohibited) at
       Rutland Road on 26 May 2025.
       >
       > My representation is based on the following grounds:
       >
       > 1) Unenforceable and Ambiguous Signage – “Term Time Only”
       > The restriction signage at this location displays the
       following text:
       >
       > “Mon–Fri 8.00–9.15am and 2.45–4.00pm – Term-time only”
       >
       > There is no indication of specific dates or term periods. It
       is not lawful or reasonable to expect a motorist to know or
       check school term dates while driving. The signage therefore
       fails to clearly convey the restriction and has been found
       unenforceable in similar cases at London Tribunals.
       >
       > Adjudicators have repeatedly ruled that “term-time only”
       restrictions must show defined date ranges or risk being
       invalid, as seen in publicly referenced cases on the London
       Tribunals website under Adequacy of Signs and Lines.
       >
       > 2) No Advance Warning / Safe Diversion
       > There is no advance signage before this restriction to warn
       unfamiliar drivers or allow a legal diversion. The restriction
       appears suddenly and is difficult to comply with safely.
       >
       > 3) Request for Evidence
       > I request the following:
       >
       > - The Traffic Management Order in force for this restriction.
       > - Evidence of how term-time dates are communicated to drivers
       at this location.
       > - Certification of the enforcement camera.
       >
       > Due to the lack of clear signage and the legal ambiguity of
       “term-time only” restrictions, I respectfully request
       cancellation of this PCN.
       --- End Quote ---
       [/quote]
       #Post#: 80685--------------------------------------------------
       Re: Redbridge - failing to comply with a restriction on vehicles
   DIR By: bigred247
       Date: July 12, 2025, 5:36 am
       ---------------------------------------------------------
       [member=24]Hippocrates[/member]
       Can “Conor Costelloe v London Borough of Merton Case No.
       2240078999” be used here?
       where the adjudicator said:


       “The use of the phrase "during terms times" is not authorised
       for the simple reason that it requires motorists to know what
       the term time are so it is just about non-compliance, it is
       about a lack of clarity as to when the restriction operates. If
       an advance warning sign is needed and it is not clear, the
       Adjudicator is entitled to conclude the overall signage is
       inadequate. The application is refused.”
       #Post#: 80687--------------------------------------------------
       Re: Redbridge - failing to comply with a restriction on vehicles
   DIR By: Hippocrates
       Date: July 12, 2025, 5:42 am
       ---------------------------------------------------------
       Request for evidence: I would omit as they will address this in
       the NOR.
       Attack the blue plate with cases and the signage and how they
       are easily missed.
       #Post#: 80689--------------------------------------------------
       Re: Redbridge - failing to comply with a restriction on vehicles
   DIR By: bigred247
       Date: July 12, 2025, 6:11 am
       ---------------------------------------------------------
       @Hippocrates, I've expanded more on the blue sign. What do you
       think?
       --- Quote ---
       > I am writing to appeal against the issuance of the Penalty
       Charge Notice, served for an alleged contravention under code
       52M — Failing to comply with a restriction on motor vehicles
       (motor vehicles prohibited) at Rutland Road on 26 May 2025.
       >
       > My appeal is based on the following grounds:
       >
       > 1) Unenforceable and Ambiguous Signage – “Term Time Only”
       > The restriction signage at this location includes the
       following text:
       >
       > “Mon–Fri 8.00–9.15am and 2.45–4.00pm – Term-time only”
       >
       > This restriction is fundamentally unclear for the following
       reasons:
       >
       >
       >
       - There is no specification of dates, months, or defined term
       periods on the signage itself.
       >
       - Term dates are not universal — they vary across schools,
       boroughs, and types of institution (e.g. academies, private
       schools).
       >
       - A driver is not under any legal duty to research or know
       school calendars in the area they are driving through.
       >
       - The restriction therefore fails the legal standard of clarity,
       as it does not make the time and period of the restriction clear
       at the point of compliance.
       >
       > The blue supplementary plate stating "Term Time Only" further
       compounds the ambiguity. It does not indicate which school the
       restriction refers to, which calendar year, or even what
       constitutes “term time” for enforcement purposes. This makes the
       sign effectively meaningless for those unfamiliar with the local
       education schedule — particularly drivers without school-age
       children or visitors to the borough.
       >
       > In Conor Costelloe v London Borough of Merton (Case No.
       2240078999), the adjudicator ruled:
       >
       > [quote]“The use of the phrase 'during term times' is not
       authorised for the simple reason that it requires motorists to
       know what the term times are… it is about a lack of clarity as
       to when the restriction operates... If an advance warning sign
       is needed and it is not clear, the Adjudicator is entitled to
       conclude the overall signage is inadequate.”
       --- End Quote ---
       This case reflects a wider consensus at London Tribunals under
       the category “Adequacy of Signs and Lines”, where adjudicators
       have repeatedly ruled that signage stating “term-time only” is
       unenforceable unless the date ranges are explicitly defined on
       the sign itself. Anything less fails to give motorists the
       certainty required in law.
       The restriction is also discriminatory in practice, as it
       assumes knowledge that only those with school-connected
       responsibilities may possess. This creates an unfair system
       where lawful compliance depends not on clear signage, but on a
       motorist’s parental status or insider knowledge.
       2) No Advance Warning or Safe Diversion
       There is no advance warning signage provided prior to the
       restriction to inform drivers or allow them to divert legally.
       The restriction appears abruptly, leaving motorists — especially
       those unfamiliar with the area — no reasonable opportunity to
       avoid a contravention safely or lawfully. This compounds the
       unfairness and further undermines enforceability.
       Conclusion
       Due to the lack of legally adequate and unambiguous signage —
       particularly the vague “term-time only” blue plate — and the
       absence of advance warning, this restriction fails the required
       standard of clarity under traffic enforcement regulations and
       established London Tribunal case law.
       I respectfully request that the Penalty Charge Notice be
       cancelled.[/quote]
       #Post#: 80727--------------------------------------------------
       Re: Redbridge - failing to comply with a restriction on vehicles
   DIR By: Hippocrates
       Date: July 12, 2025, 10:02 am
       ---------------------------------------------------------
       I like it.
       #Post#: 80734--------------------------------------------------
       Re: Redbridge - failing to comply with a restriction on vehicles
   DIR By: bigred247
       Date: July 12, 2025, 12:01 pm
       ---------------------------------------------------------
       Fantastic. I'm going to go ahead and make the appeal. Will keep
       you folks updated regardless of outcome  ;)
       #Post#: 80741--------------------------------------------------
       Re: Redbridge - failing to comply with a restriction on vehicles
   DIR By: fraser.mitchell
       Date: July 12, 2025, 2:21 pm
       ---------------------------------------------------------
       --- Quote from: Hippocrates link ---
       >
       > I like it.
       >
       --- End Quote ---
       Me too.
       Councils get away with far too much these days, and you're lucky
       having the London Tribunal adjudicators, because I have seen an
       alarming case at the Traffic Penalty Tribunal where an
       adjudicator decided that because no prejudice was caused to the
       appellant, (his opinion, naturally), the blatant procedural
       impropriety the council had committed could be ignored. So it
       seems this adjudicator is happy for a council to do what they
       damn well like in any circumstances.
       #Post#: 95297--------------------------------------------------
       Re: Redbridge - failing to comply with a restriction on vehicles
   DIR By: bigred247
       Date: October 23, 2025, 10:01 am
       ---------------------------------------------------------
       [member=12]Incandescent[/member] [member=24]Hippocrates[/member]
       I had a call with the tribunal earlier today, and the
       adjudicator accepted my appeal based on point 1. He didn't
       bother reading the other points. He completely agreed, and was
       even more satisified due to the citing of the preceding cases in
       the appeal.
       Happy days  ;) I'll post his comments when i receive them via
       email/post.
       Thank you very much folks.
       #Post#: 95335--------------------------------------------------
       Re: Redbridge - failing to comply with a restriction on vehicles
   DIR By: Hippocrates
       Date: October 23, 2025, 1:52 pm
       ---------------------------------------------------------
       --- Quote from: bigred247 link ---
       >
       > [member=12]Incandescent[/member]
       [member=24]Hippocrates[/member]
       > I had a call with the tribunal earlier today, and the
       adjudicator accepted my appeal based on point 1. He didn't
       bother reading the other points. He completely agreed, and was
       even more satisified due to the citing of the preceding cases in
       the appeal.
       > Happy days  ;) I'll post his comments when i receive them via
       email/post.
       > Thank you very much folks.
       >
       --- End Quote ---
       Mr Dodd or Mr Hoare?
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