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       #Post#: 87425--------------------------------------------------
       A new line of attack against PCNs on Charlton Road J/W D'Arcy
       Drive, Harrow
   DIR By: Bustagate
       Date: August 27, 2025, 8:32 am
       ---------------------------------------------------------
       I see that the general view, e.g.
       [member=2249]stamfordman[/member] Re: PCN - Charlton Road J/W
       D'Arcy DR HA3 - Driving through central reservation
  HTML https://www.ftla.uk/civil-penalty-charge-notices-(councils-tfl-and-so-on)/pcn-charlton-road-jw-d-arcy-dr-ha3-driving-through-central-reservation/msg70412/#msg70412<br
       />is that there's no chance challenging PCNs for going between
       the
       traffic islands on Charlton Road.
       I should like to propose the following representations:
       [indent]The alleged contravention is 38L,
       [indent]Failing to comply with a sign indicating that vehicular
       traffic must pass to the specified side of the sign[/indent]
       But what does the Keep Left sign, diagram 610, actually mean?
       It's TSRGD 2016 Schedule 3 Part 4 Paragraph 3
  HTML https://www.legislation.gov.uk/uksi/2016/362/schedule/3/part/4/paragraph/3/made:
       [indent](1) Except as provided in sub-paragraphs (2) to (5), the
       requirement conveyed by the sign is that vehicular traffic
       passing the sign must keep to the left of the sign where the
       arrow is pointed downwards to the left, or to the right of the
       sign where the arrow is pointed downwards to the right.
       (2) Sub-paragraph (3) applies on an occasion where a vehicle is
       being used for at least one of the purposes set out in
       sub-paragraph (4) and the observance of the requirement in
       sub-paragraph (1) would be likely to hinder the use of the
       vehicle for that purpose.
       (3) The requirement conveyed is that the vehicle must not
       proceed beyond the sign in such a manner or at such a time as to
       be likely to endanger any person.
       (4) The purposes are—
       [indent](a) fire and rescue authority;
       (b) Scottish Fire and Rescue Service;
       (c) ambulance;
       (d) blood service;
       (e) providing a response to an emergency at the request of an
       NHS ambulance service;
       (f) bomb or explosive disposal;
       (g) special forces
       (h) police; and
       (i) National Crime Agency.
       [/indent]
       (5) The requirement in sub-paragraph (1) does not apply to a
       tramcar or trolley vehicle [/indent]
       Note that it doesn't say that Harrow council vehicles are
       allowed to pass the sign on the "wrong" side.
       Now let's look at the TMO which applies to Charlton Road. This
       is The Harrow (Prescribed Route) (Width Restriction) Traffic
       Order 2007
  HTML https://www.whatdotheyknow.com/request/harrow_width_restriction_tmos/response/2866464/attach/2/8814463%202007%2007%20AMND.pdf.<br
       />
       Article 3 and Column 4 of the Schedule impose a restriction of
       6'6" on the lanes at either side of the road.
       Between the traffic islands, Article 2 and column 3 of the
       Schedule specify the following restrictions:
       [indent]2. No person shall cause any vehicle to proceed in a
       length of carriageway specified in columns 2 and 3 of the
       Schedule to this order.
       . . .
       4. Nothing in Articles 2 and 3 of this Order shall apply to :-
       [indent](a) any vehicle being used for ambulance, fire brigade
       or police purposes;
       (b) anything done with the permission or at the direction of a
       police constable in uniform;
       (c) any person who causes any vehicle to proceed in accordance
       with any restriction or requirement indicated by traffic signs
       placed pursuant to section 66 or section 67 of the Road Traffic
       Regulation Act 1984;
       (d) any vehicle specified in column 6 of the Schedule to this
       Order;
       (e) to any vehicle being lawfully used in connection with the
       maintenance of public services maintained by the London Borough
       of Harrow. [LBH2012/30]
       [/indent]
       Note in particular article 4(e). This permits vehicles which are
       being lawfully used in connection with the maintenance of public
       services in Harrow to use the "Prohibited length". But we have
       seen that TSRGD 2016 Schedule 3 Part 4 Paragraph 3 does not
       exempt such vehicles from the requirement to pass on the
       "correct" side of the diagram 610.
       It follows that vehicles on Harrow Council business, e.g.
       rubbish collection, are not being lawfully used when they pass
       between the traffic islands. There is therefore no difference in
       law between my passage between the traffic islands and that by
       vehicles delivering pubic services for Harrow Council.
       While Civil Enforcement Officers administering Harrow's PCNs
       have discretion in whether to issue them, they are obliged to
       follow administrative law in doing so. A central principle of
       administrative law was stated by Lord Greene MR in Associated
       Provincial Picture Houses Ltd v Wednesbury Corporation
  HTML https://en.wikipedia.org/wiki/Associated_Provincial_Picture_Houses_Ltd_v_Wednesbury_Corporation:
       [indent]a person entrusted with a discretion must, so to speak,
       direct himself properly in law. He must call his own attention
       to the matters which he is bound to consider. He must exclude
       from his consideration matters which are irrelevant to what he
       has to consider. If he does not obey those rules, he may truly
       be said, and often is said, to be acting
       "unreasonably."[/indent]
       An action which flouts this principle is liable to be quashed as
       "unreasonable". It becomes a nullity, i.e. it is as if it had
       never existed.
       On Charlton Road, it appears that CEOs have taken account of
       irrelevant considerations, viz that there happens to be a TMO
       which appears to &#8722; but does not &#8722; exempt vehicles on
       Harrow Council business from using the lane between the traffic
       islands.
       I submit that this action by the CEOs renders the issuing of a
       PCN to me ultra vires and therefore null. What is sauce for the
       goose is sauce for the gander.
       Of course, if Harrow Council complied with Regulation 18 of The
       Local Authorities’ Traffic Orders (Procedure) (England and
       Wales) Regulations 1996
  HTML https://www.legislation.gov.uk/uksi/1996/2489/regulation/18
       and
       placed signage which truly showed the effect of its TMO, this
       issue would not have arisen. There would be no diagram 610s on
       bollards on the left-hand traffic islands as some vehicles
       (other than the emergency services and related ones) are
       permitted to pass to the right of those traffic islands. I
       submit that the correct way to sign the TMO is to place
       appropriate signs on posts on both traffic islands to show which
       vehicles are permitted to pass between them.
       #Post#: 87430--------------------------------------------------
       Re: A new line of attack against PCNs on Charlton Road J/W
       D'Arcy Drive, Harrow
   DIR By: andy_foster
       Date: August 27, 2025, 8:50 am
       ---------------------------------------------------------
       Drugs are bad, m'kay?
       #Post#: 126459--------------------------------------------------
       Re: A new line of attack against PCNs on Charlton Road J/W
       D'Arcy Drive, Harrow
   DIR By: Bobthebuilder
       Date: August 1, 2026, 6:47 am
       ---------------------------------------------------------
       I’ve just got one of these too. Definitely barely any signage, a
       van was turning around, causing a build up of traffic, car in
       front scared to go though, so went to overtake. What can I do to
       challenge it? Just copy and paste what you said above?
       #Post#: 126471--------------------------------------------------
       Re: A new line of attack against PCNs on Charlton Road J/W
       D'Arcy Drive, Harrow
   DIR By: John U.K.
       Date: August 1, 2026, 7:56 am
       ---------------------------------------------------------
       --- Quote from: Bobthebuilder link ---
       >
       > I’ve just got one of these too. Definitely barely any signage,
       a van was turning around, causing a build up of traffic, car in
       front scared to go though, so went to overtake. What can I do to
       challenge it? Just copy and paste what you said above?
       >
       --- End Quote ---
       For meaningful advice with your own case please have a read of
  HTML https://www.ftla.uk/civil-penalty-charge-notices-(councils-tfl-and-so-on)/read-this-first-before-posting-your-case!-this-section-is-for-council-tfl-dartme/
       and start your own thread in the Civil Penalty forum
  HTML https://www.ftla.uk/civil-penalty-charge-notices-(councils-tfl-and-so-on)/
       #Post#: 126474--------------------------------------------------
       Re: A new line of attack against PCNs on Charlton Road J/W
       D'Arcy Drive, Harrow
   DIR By: NewJudge
       Date: August 1, 2026, 8:10 am
       ---------------------------------------------------------
       --- Quote ---
       > What can I do to challenge it? Just copy and paste what you
       said above?
       --- End Quote ---
       I wouldn’t if I were you.
       The earlier post (from 12 months ago) seems to suggest that a
       dust cart “being lawfully used” (to collect rubbish) cannot take
       advantage of an exemption which allows it to ignore certain
       traffic signs because it would then see it being used
       unlawfully.
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