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       #Post#: 77114--------------------------------------------------
       Re: CDER GROUP TFL
   DIR By: bwolf9999
       Date: June 19, 2025, 2:38 am
       ---------------------------------------------------------
       Morning
       Here is the email, the agent arrived the next morning at 7am.
       He did show me the warrant.
       He also showed me a long list of account activity that never
       happened as far as I know, it had a list of emails that I didnt
       ever receive, letters I didn't receive and another visit, it
       also showed they only updated my address in May so any letters
       were going to my previous address, I have letters from the
       traffic enforcement agency etc from February/ March to my
       current address so I am wondering if I have a case as they didnt
       update their records meaning I didnt get any of their previous
       correspondence
       [attachment deleted by admin]
       #Post#: 77119--------------------------------------------------
       Re: CDER GROUP TFL
   DIR By: H C Andersen
       Date: June 19, 2025, 3:27 am
       ---------------------------------------------------------
       Pl stop mixing the procedures.
       TEC have nothing to do with the PCN as such, for our purposes
       they simply authorise the use of Schedule 12 action to issue a
       warrant.
       You were shown the warrant. Did it have your correct details
       i.e. your name and address which is where it was being executed?
       Where is your email dealing with the 'payment plan'?
       Pl consolidate and repost:
       The Notice of Enforcement;
       Your email response(as above);
       Their response.
       #Post#: 78281--------------------------------------------------
       Re: CDER GROUP TFL
   DIR By: bwolf9999
       Date: June 26, 2025, 6:32 am
       ---------------------------------------------------------
       Hi HC Anderson
       Sorry for the delay.
       I have attached the notice of enforcement and the email
       conversation here, as I say , the enforcement agent was here the
       next morning after this email.
       As an aside, after requesting the account history like the
       enforcement agent advised where he showed me on his phone a long
       list of apparent emails and letters that I did not receive, they
       have twice now sent me what look like edited activity lists with
       only visits listed, the agent clearly showed me a list of emails
       and letters, I have emailed them again saying the agents list of
       activity was much longer and asked them again to provide it.
       Cheers
       [attachment deleted by admin]
       #Post#: 78288--------------------------------------------------
       Re: CDER GROUP TFL
   DIR By: H C Andersen
       Date: June 26, 2025, 7:35 am
       ---------------------------------------------------------
       I don't know where you're going with this.
       You can continue to correspond with them and place your car at
       risk - if on the highway or at the premises specified on the
       warrant. If you're happy to do this then write to the council,
       after all the enforcement agent is THEIR agent. You have the
       hard evidence in the form of the NoE which does not offer 7
       clear days and you could argue that it and any subsequent fees
       are therefore invalid.
       I suggest you get BAO on this for you.
       #Post#: 78291--------------------------------------------------
       Re: CDER GROUP TFL
   DIR By: bwolf9999
       Date: June 26, 2025, 7:46 am
       ---------------------------------------------------------
       Hi mate
       Sorry, its been a few days and you have understandably forgotten
       my case .
       This is the one where I have paid as the agent turnt up at my
       door the morning after CDER emailed saying they couldnt arrange
       a payment plan over email. I paid as I had no choice really
       While taking the payment the agent said I could try and claim
       the money back as he showed me a long list of 'activity' on my
       account that i know did not happen, letters , emails etc.
       So, I want to claim it back somehow as I think they are pulling
       a fast one , they didnt send me any emails or letters, just the
       one NOE. And now after 2 requests for that activity they keep
       sending edited versions with no mention of letters or emails
       Sorry the email conversation you requested didnt upload first
       time , attached now
       [attachment deleted by admin]
       #Post#: 78308--------------------------------------------------
       Re: CDER GROUP TFL
   DIR By: H C Andersen
       Date: June 26, 2025, 9:36 am
       ---------------------------------------------------------
       Thanks for the reminder.
       As you've paid, then pl stop corresponding direct with CDER,
       it's a waste of time. They are the authority's agents, so
       complain to them.
       If you don't want to use BAO, then use TfL's complaints
       procedure.
       Unlawful Demand for Money - CDER on behalf of Transport for
       London
       This complaint relates to the authority's enforcement agents
       CDER in respect of Penalty Charge Notice  ********. I would
       stress that I am not complaining about the penalty itself but
       the subsequent enforcement procedures engaged by the agent to
       recover the debt. Specifically, their failure to comply with the
       mandatory requirements of Schedule 12(your finance dept.
       officers will know the chapter and verse of these) in that a
       Notice of Enforcement was issued which did not give me 7 'clear
       days' notice. The evidence in this regard is objective and
       enclosed i.e. a NoE dated 2 June with a latest date for payment
       of 9 June. As only 7 days in total were given, then it is
       axiomatic that these could not be 'clear days' because Sundays
       are excluded. For information, the NoE was not received until 6
       June, but this is secondary.
       I have paid your agent in order to prevent further action and
       the remedy I require is that the council refund the Compliance
       and Enforcement fees (£75 and £235 respectively) and that a
       lawful NoE is issued.
       Please do not pass this to your enforcement authority staff who
       either do not know the requirements and/or fail to maintain
       adequate oversight of TfL's agents' actions. This should be
       referred to suitably experienced finance or legal staff.
       My payment details are as follows:
       **********
       Encl: copy of NoE dated 2 June 2025
       I cannot find on online or email Complaints portal, perhaps
       others know.
       #Post#: 78315--------------------------------------------------
       Re: CDER GROUP TFL
   DIR By: bwolf9999
       Date: June 26, 2025, 10:20 am
       ---------------------------------------------------------
       Ok, thank you, awesome.
       And it was £560 in the end :(
       #Post#: 78320--------------------------------------------------
       Re: CDER GROUP TFL
   DIR By: H C Andersen
       Date: June 26, 2025, 10:31 am
       ---------------------------------------------------------
       Forget the penalty charge element, IMO.
       The enforcement fees come to £310; the court registration fee is
       £10; and the penalty is £240. Total £560.
       You've already made two attempts to get TEC to cancel the OfR
       and CC without success(or it would seem any hope of success).
       But if you want to chance your arm and try and get the whole
       £560 refunded based upon CDER's misapplication of mandatory
       enforcement procedures.....!
       #Post#: 84803--------------------------------------------------
       Re: CDER GROUP TFL
   DIR By: bwolf9999
       Date: August 8, 2025, 11:02 am
       ---------------------------------------------------------
       --- Quote from: H C Andersen link ---
       >
       > Forget the penalty charge element, IMO.
       >
       > The enforcement fees come to £310; the court registration fee
       is £10; and the penalty is £240. Total £560.
       >
       > You've already made two attempts to get TEC to cancel the OfR
       and CC without success(or it would seem any hope of success).
       But if you want to chance your arm and try and get the whole
       £560 refunded based upon CDER's misapplication of mandatory
       enforcement procedures.....!
       >
       --- End Quote ---
       Hi mate
       So...
       This is the reply I got to my letter, what are your thoughts ? I
       used the exact template you gave me.
       Cheers
       #Post#: 84810--------------------------------------------------
       Re: CDER GROUP TFL
   DIR By: 404BrainNotFound
       Date: August 8, 2025, 11:52 am
       ---------------------------------------------------------
       Your case discloses a compelling basis for restitutionary relief
       grounded in statutory irregularity and procedural abuse under
       the civil enforcement framework. While you have discharged the
       underlying balance of £560 following enforcement by CDER Group,
       that payment was extracted in circumstances which, on your
       account, render the process invalid under both Schedule 12 of
       the Tribunals, Courts and Enforcement Act 2007 and the Taking
       Control of Goods Regulations 2013.
       Let me set out the legal position with clarity. The Notice of
       Enforcement issued to you by CDER Group bears the date 2 June
       2025, with a demand for payment by 6:00am on 9 June 2025. This
       fails, on its face, to satisfy the mandatory requirement of
       Regulation 7(1) of the 2013 Regulations, which provides that a
       notice of enforcement must afford the debtor not less than seven
       clear days before enforcement action may be taken. Clear days
       exclude the day of service and the day of compliance, and
       further disregard Sundays and bank holidays. Even under a
       generous construction, the notice period in your case was
       non-compliant, thereby vitiating the enforcement process from
       the outset.
       Moreover, you have reported that CDER’s enforcement agent,
       during a visit to your property, displayed on a mobile device an
       extended account history purporting to show a series of letters,
       emails, and possibly a prior visit, none of which you ever
       received. This log, crucial to justifying the escalation of
       fees, has not been disclosed to you despite multiple requests.
       Instead, CDER have provided what appear to be truncated or
       redacted records omitting the very entries shown to you at the
       door. The failure to furnish a complete and accurate record of
       enforcement activity engages both Regulation 24 of the 2013
       Regulations and the common law principles of good faith and
       transparency in enforcement.
       A further difficulty arises in relation to service of notices
       and address verification. You have evidence that both the
       Traffic Enforcement Centre and Transport for London were
       corresponding with you at your correct address as early as
       February 2025, yet CDER did not update their records until May
       2025. This raises significant questions as to whether key
       statutory notices—including the Notice of Enforcement—were
       lawfully served or otherwise came to your attention within the
       prescribed timeframes. These defects are not academic. The
       enforcement fees levied—£75 at compliance stage and £235 at
       enforcement visit—are strictly contingent upon procedural
       compliance. Where there is material non-compliance, those fees
       cannot lawfully be charged.
       Having now paid the sum in full, your remedy lies not in
       resisting enforcement but in challenging the lawfulness of the
       process and seeking restitution of fees unlawfully demanded. The
       legal basis for recovery would be a claim in restitution for
       money had and received, supported by the principle that money
       paid under compulsion or mistake of law is recoverable where no
       legal obligation to pay existed. This is well established in
       authority, including Woolwich Equitable Building Society v IRC
       [1993] AC 70 and, more recently in the enforcement context,
       Burton v Ministry of Justice [2024] EWCA Civ 681.
       Transport for London, as the principal, remains vicariously
       liable for the acts of its agents. It cannot disown
       responsibility merely by referring 'complaints' to CDER Group.
       The standard response you received from TfL, dated 14 July 2025,
       fails entirely to engage with the statutory breach you have
       identified and reflects either a lack of understanding or an
       abdication of legal oversight.
       In these circumstances, I would advise you to pursue the
       following course:
       First, submit a formal pre-action disclosure request under CPR
       31.17 to CDER Group. This is procedurally superior to a subject
       access request. A request under CPR 31.17 entitles you to
       obtain, prior to litigation, specific documents held by a third
       party (in this case, CDER Group) where it is likely those
       documents are relevant to anticipated proceedings and where
       disclosure is necessary to fairly dispose of the claim or save
       costs. Unlike a subject access request under the UK GDPR, which
       provides only for personal data (often in redacted or summarised
       form), CPR 31.17 enables you to demand unredacted original
       records, including audit logs, email dispatch reports,
       correspondence files, and internal system entries used to
       justify enforcement action. These documents will be central to
       the merits of any future claim for restitution.
       Secondly, send a renewed formal complaint to Transport for
       London, expressly relying on the defective notice period and the
       absence of proper service. That complaint should be addressed to
       the legal or enforcement oversight department and demand
       repayment of the compliance and enforcement fees (£310). Your
       letter must make clear that the PCN itself is not in dispute;
       rather, it is the subsequent enforcement which is impugned. You
       may, if appropriate, enclose a draft Particulars of Claim to
       demonstrate the seriousness of your intention to litigate.
       Thirdly, if neither CDER nor TfL respond adequately within 14
       days, you may issue a Part 7 claim in the County Court for
       restitution of the £310. Your cause of action would be for money
       had and received on the grounds that the enforcement was
       unlawful, the fees were improperly levied, and the payment was
       made under compulsion. The claim would be suitable for the small
       claims track and should be supported by a concise witness
       statement and copy documents including the Notice of
       Enforcement, correspondence, and your CPR 31.17 request.
       You may, in the alternative, consider an application under CPR
       84.16 for detailed assessment of the enforcement fees, although
       this is more commonly deployed at an earlier stage and may
       involve technical argument as to timing.
       In conclusion, your legal position is strong. The enforcement
       action taken against you was arguably void for failure to comply
       with mandatory notice provisions. You have a clear statutory and
       equitable basis to seek repayment of fees improperly extracted.
       I would be pleased to assist in the preparation of your CPR
       31.17 request, and, if necessary, TFL particulars of claim.
       Should you proceed promptly and with precision, I am confident
       the matter can be resolved without the need for protracted
       litigation.
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