URI:
   DIR Return Create A Forum - Home
       ---------------------------------------------------------
       FreeTrafficLegalAdvice
  HTML https://ftla.createaforum.com
       ---------------------------------------------------------
       *****************************************************
   DIR Return to: Civil penalty charge notices (Councils, TFL and so ...
       *****************************************************
       #Post#: 13971--------------------------------------------------
       Re: Lambeth - windscreen PCN - code 12s - Cutcombe Road (A)
   DIR By: H C Andersen
       Date: January 18, 2024, 1:10 pm
       ---------------------------------------------------------
       'Penalty exceeded the amount applicable in the circumstances of
       the case'.
       The circumstances being that the authority had no legal basis to
       demand a penalty from you as the 'owner' because they were not
       empowered to issue a new NTO to you pursuant to regulations
       20(1) and 20(4)(b) of the General Provisions etc. Regulations
       because the precedent conditions in Regulation 5(4)(d) had not
       been met by the owner i.e. the authority was not in possession
       of a statement of liability signed by you or evidence that the
       owner was a 'vehicle-hire firm' and that a 'hiring agreement'
       (both defined terms) were in effect.
       In this case, the authority have simply accepted the say-so of a
       leasing company that the vehicle in question was subject to a
       3-year lease, however, this claim, even if correct, does not
       meet the legal standard required and therefore the authority's
       purported cancellation of that NTO was ultra vires and it must
       therefore follow that their issue of a new NTO was similarly
       unlawful.
       As a thought.
       #Post#: 13990--------------------------------------------------
       Re: Lambeth - windscreen PCN - code 12s - Cutcombe Road (A)
   DIR By: taffer87
       Date: January 19, 2024, 4:22 am
       ---------------------------------------------------------
       --- Quote from: H C Andersen link ---
       >
       >
       > 'Penalty exceeded the amount applicable in the circumstances
       of the case'.
       >
       > The circumstances being that the authority had no legal basis
       to demand a penalty from you as the 'owner' because they were
       not empowered to issue a new NTO to you pursuant to regulations
       20(1) and 20(4)(b) of the General Provisions etc. Regulations
       because the precedent conditions in Regulation 5(4)(d) had not
       been met by the owner i.e. the authority was not in possession
       of a statement of liability signed by you or evidence that the
       owner was a 'vehicle-hire firm' and that a 'hiring agreement'
       (both defined terms) were in effect.
       >
       > In this case, the authority have simply accepted the say-so of
       a leasing company that the vehicle in question was subject to a
       3-year lease, however, this claim, even if correct, does not
       meet the legal standard required and therefore the authority's
       purported cancellation of that NTO was ultra vires and it must
       therefore follow that their issue of a new NTO was similarly
       unlawful.
       >
       > As a thought.
       >
       --- End Quote ---
       Thanks is that relevant for the PCN and NTO issued under TMA
       2004 or do I need to change the references?
       Also here is the NTO in my name if that adds any other points I
       should add?
  HTML https://i.ibb.co/MBLQ3Dv/lambeth-nto-page-1-of-4.jpg
  HTML https://ibb.co/0s3vdj7
  HTML https://i.ibb.co/JsqyJHJ/lambeth-nto-page-2-of-4.jpg
  HTML https://ibb.co/2kSs4d4
  HTML https://i.ibb.co/d2wzsJZ/lambeth-nto-page-3-of-4.jpg
  HTML https://ibb.co/C73TpsL
  HTML https://i.ibb.co/sFmkGpL/lambeth-nto-page4-of-4.jpg
  HTML https://ibb.co/tbmktwy
       #Post#: 14002--------------------------------------------------
       Re: Lambeth - windscreen PCN - code 12s - Cutcombe Road (A)
   DIR By: taffer87
       Date: January 19, 2024, 9:07 am
       ---------------------------------------------------------
       --- Quote from: John U.K. link ---
       >
       > Have VW leasing received a noitice of cancellation of the
       original PCN?
       >
       --- End Quote ---
       here is the council letter to the lease company.. it technically
       doesn't say it is a "Notice of Acceptance" does it need to be
       quite explicit to count as a Notice of Acceptance? If so could
       be an appeal point once it gets to London Tribunals
  HTML https://i.ibb.co/BZWzdSs/lambeth-letter-to-lease-company.png
  HTML https://ibb.co/2tVnmfK
       #Post#: 14009--------------------------------------------------
       Re: Lambeth - windscreen PCN - code 12s - Cutcombe Road (A)
   DIR By: John U.K.
       Date: January 19, 2024, 9:36 am
       ---------------------------------------------------------
       As I understand it (but see what the experts say) in order to
       accept the transfer of liability (see also pots replies #47 &
       #50 from PMB and HCA) they have to cancel the original PCN & NtO
       and re-issue to you. They have specifically declined to cancel.
       It's a mess, but it needs an expert to give you definitive
       advice as to next step.
       See also this Lambeth doc on Representations both VW & you have
       received,note especially the 2nd paragraph and the 4th. ground.
  HTML https://i.ibb.co/t8qBVy5/NTO-to-VWFS-Lambeth-p3.png
  HTML https://imgbb.com/
       #Post#: 14013--------------------------------------------------
       Re: Lambeth - windscreen PCN - code 12s - Cutcombe Road (A)
   DIR By: H C Andersen
       Date: January 19, 2024, 10:19 am
       ---------------------------------------------------------
       My point remains the same. If anything it's enhanced by the
       council's letter which is typically legally ignorant. Where ANY
       reps are made then the council are under this duty:
       5) If the enforcement authority accepts the representations—
       (a)it must cancel the relevant enforcement notice,
       (b)its decision notice must state that the enforcement notice
       has been cancelled
       
       *- Enforcement notice is a regulatory term which covers a NTO.
       OP, in my draft please insert 'Appeals' before Regulation (5)...
       #Post#: 14236--------------------------------------------------
       Re: Lambeth - windscreen PCN - code 12s - Cutcombe Road (A)
   DIR By: taffer87
       Date: January 24, 2024, 2:52 am
       ---------------------------------------------------------
       thanks for this. Seems like this will be a pretty solid appeal
       point for London Tribunals
       --- Quote from: H C Andersen link ---
       >
       >
       > My point remains the same. If anything it's enhanced by the
       council's letter which is typically legally ignorant. Where ANY
       reps are made then the council are under this duty:
       >
       >
       > 5) If the enforcement authority accepts the representations—
       >
       > (a)it must cancel the relevant enforcement notice,
       >
       > (b)its decision notice must state that the enforcement notice
       has been cancelled
       >
       > *- Enforcement notice is a regulatory term which covers a NTO.
       >
       > OP, in my draft please insert 'Appeals' before Regulation
       (5)...
       >
       --- End Quote ---
       #Post#: 14279--------------------------------------------------
       Re: Lambeth - windscreen PCN - code 12s - Cutcombe Road (A)
   DIR By: ivanleo
       Date: January 24, 2024, 2:51 pm
       ---------------------------------------------------------
       I don't see that Lambeth's actions will stand up to scrutiny,
       I'd send HCA's draft for now and let's see what drivel comes
       back in the rejection.
       #Post#: 14289--------------------------------------------------
       Re: Lambeth - windscreen PCN - code 12s - Cutcombe Road (A)
   DIR By: ivanleo
       Date: January 24, 2024, 5:50 pm
       ---------------------------------------------------------
       [member=832]taffer87[/member] has sent me the terms of the lease
       and they don't create a permanent disposition in any event, so
       it's hard to see how one could lose this case.
       #Post#: 14657--------------------------------------------------
       Re: Lambeth - windscreen PCN - code 12s - Cutcombe Road (A)
   DIR By: taffer87
       Date: January 31, 2024, 7:02 am
       ---------------------------------------------------------
       received a rejection notice today. should i submit the london
       tribunal in person appeal saying i rely on my previous
       representation and will provide further points after reviewing
       the evidence pack presented by Lambeth?
  HTML https://i.ibb.co/2s0gwQQ/IMG-2736.jpg
  HTML https://ibb.co/CMphqZZ
  HTML https://i.ibb.co/zNDfvD5/IMG-2737.jpg
  HTML https://ibb.co/WsjKJj3
  HTML https://i.ibb.co/56njgbS/IMG-2738.jpg
  HTML https://ibb.co/80dxL1f
  HTML https://i.ibb.co/ZL1PQQF/IMG-2739.jpg
  HTML https://ibb.co/5MxyQQS
  HTML https://i.ibb.co/vzSmfsB/IMG-2740.jpg
  HTML https://ibb.co/12kKBsn
  HTML https://i.ibb.co/ZLNsSC5/IMG-2741.jpg
  HTML https://ibb.co/X2VBDT1
       #Post#: 14670--------------------------------------------------
       Re: Lambeth - windscreen PCN - code 12s - Cutcombe Road (A)
   DIR By: H C Andersen
       Date: January 31, 2024, 9:20 am
       ---------------------------------------------------------
       There should be a law against councils acting in this way!
       *****************************************************
       Page 6 of 10
   DIR Previous Page
   DIR Next Page