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#Post#: 92705--------------------------------------------------
ULEZ signage challenge
By: roythebus Date: October 3, 2025, 9:20 am
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On Facebook, a chap called Noel Wilcox is challenging the
legality of the LEZ charges. Here's a copy of what he's posted
so far. I've suggested he posts on here where he's more likely
to get sensible and free help.
"Ok ladies and Gents many of you have asked why I won the
Adjudicator’s decision so here is the explanation, I have come
under a lot of abuse on here for keeping my cards very close to
my chest, the personal attacks that I have received, such as I
haven't got a clue what I am doing, I am a Fraud I just shrugged
my shoulders and pushed on. There was even a Facebook page set
up calling me Noel Willcox the scam.
I am being shut down by TFL and the Judiciary.
The ULEZ signage is completely different and a lot more complex
but I will provide the evidence when I can, The ULEZ signage has
taken me a long time to map together.
I do know the Road Traffic Law, TSRGD 2016, and DFT
authorisations inside out I have studied it for 4 years.
I am not on here insulting anyone but please be very careful of
misinformation. I will need everyone to come together and
support me, I am doing everything I can with limited resources.
🚨 Why the LEZ Signs Are Unlawful 🚨
Between 2016 and 2023, Transport for London (the Defendant in my
case) took money from me under the Low Emission Zone (LEZ) using
signs that were not lawfully authorised.
Here’s why ⬇️
✅ The Law
Traffic signs must either:
Appear in the Traffic Signs Regulations and General Directions
2016 (TSRGD 2016), or
Be specifically authorised by the Secretary of State for
Transport.
If not, the sign is not valid in law — meaning any money taken
under it is unlawful.
✅ The LEZ Problem
The LEZ signs were authorised in 2008, tied to the 2002
regulations.
In 2016, those regulations were revoked and replaced by TSRGD
2016.
The Defendant did not re-authorise or update the LEZ signs until
July 2022 then deployed the expansion in August 2023
That left a seven-to-eight-year gap (April 2016 – August 2023)
where the Defendant charged drivers without lawful signage.
✅ Case Law
Davies v Heatley [1971] RTR 145: “If a sign does not conform to
the regulations in all respects, then it is not a traffic sign
in law.”
Oxfordshire CC v Bus Lane Adjudicator [2010] EWHC 894 (Admin):
charges based on non-compliant signs are unenforceable.
📌 Bottom line: The Defendant took money from drivers
without lawful authority."
#Post#: 92709--------------------------------------------------
Re: ULEZ signage challenge
By: H C Andersen Date: October 3, 2025, 9:28 am
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We would need to see the SoS's original authorisation.
This power doesn't exist by virtue of TSRGD(RTRA s64(1)(a)),
it's a power given under s64(1)(b) of the RTRA. Therefore my
question would be why anyone thinks that 64(1)(b) authorisations
are in any way linked to s64(1)(a) regs?
#Post#: 92732--------------------------------------------------
Re: ULEZ signage challenge
By: roythebus Date: October 3, 2025, 10:54 am
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From the limited amount of info I've read on the FB anti-ULEZ
group, there's a couple of pages quoting regulations which state
"low emission zone", no mention of the Ultra Low Emission Zone".
So in my view the argument falls down. I've invited the OP to
post on here.Whether he will or not remains to be seen.
#Post#: 92744--------------------------------------------------
Re: ULEZ signage challenge
By: 666 Date: October 3, 2025, 12:53 pm
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[quote author=roythebus link=topic=8272.msg92705#msg92705
date=1759501240]
I am being shut down by TFL and the Judiciary.
The LEZ signs were authorised in 2008, tied to the 2002
regulations.
In 2016, those regulations were revoked and replaced by TSRGD
2016.
[/quote]
1. "I am being shut down ..." smacks of FOTLery. What exactly
does he mean?
2. "... those regulations were revoked ...". So far as I can
find, only specific parts were revoked.
#Post#: 92750--------------------------------------------------
Re: ULEZ signage challenge
By: Amy Violin Date: October 3, 2025, 1:36 pm
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I’ve explained this to him:
On the material you’ve sent me, what’s publicly available, and
my own knowledge, my view is as follows:
*1. Who does the authorising (and what “special authorisation”
means).*
You’re correct that a sign must either appear in the TSRGD or be
specially authorised. But the authorisation is the Secretary of
State’s, issued under s.64–65 of the Road Traffic Regulation Act
1984, often on application from the authority. It is not a “TfL
special authorisation”; it is a freestanding authorisation
issued by the Secretary of State under s.64-65 RTRA 1984. The
ULEZ signs were specifically authorised in 2018 (GT50/139/0171),
with further authorisations in 2019–2020 and again in 2022
(GT50/139/0183), plus associated 2023 approvals for VMS.

*2. “At all times” / hours panel - mandatory or optional?*
Your Facebook post asserts that the DfT authorisation ‘requires
operating hours’ and, for a 24/7 scheme, mandates ‘AT ALL
TIMES’. That’s not what the authorisations say. The 2018
authorisation expressly provides that ‘the reference to the
times of operation may be varied or omitted’ for the entry signs
(A, B, D, E, F). That is what we call ‘dispositive’ - hours text
is optional. The 2022 authorisation again ties the lawful
variants to the TfL drawings and notes (e.g. Sign A on
GT50/139/0183-1), which include the ability to vary the bottom
panel text or omit it entirely.
*3. Your reliance on the Traffic Signs Manual (TSM).*
The TSM is purely guidance, not law. The DfT’s own page
describes it as advice on use of TSRGD-prescribed signs; it
doesn’t trump, qualify, or condition a s.64/s.65 authorisation.
Where the Secretary of State has authorised a non-standard sign
(with its own notes and variants), those authorisation terms
then govern.
*4. “2002 Regulations were revoked so LEZ signs became unlawful
(2016–2023 gap).”*
Yes, the 2007 LEZ authorisation _did_ refer to provisions in the
2002 TSRGD but the authorisation itself was made under s.64/65
RTRA 1984 and contains its own ‘survival clause’: it remains
effective ‘until such day as may be appointed by one month’s
notice’ from the Secretary of State. There’s no term in that
authorisation making its validity contingent upon the 2002 TSRGD
remaining on the statute book. They could have quoted from the
Bible or Alice in Wonderland if they so wished. As long as the
text is imported or referenced, it assumes its own legal force
by virtue of then being a term in the attendant authorisation. I
hope that makes sense now. In any event, DfT re-authorised the
later LEZ/ULEZ signage suite in 2022, which independently cures
any alleged lacuna.
*5. “Davies v Heatley” and strict conformity.*
Davies (1971) is not the governing approach in modern civil
enforcement. The Court of Appeal in Herron v Parking Adjudicator
confirmed the test is substantial compliance, not absolute
perfection. It also only referred to a specific set of facts.
Where a sign is expressly authorised by the Secretary of State,
the question is whether what’s on street substantially complies
with that authorisation (including any permitted variants), not
whether it mirrors a TSRGD diagram.
*6. Your tribunal win.*
As previously advised, I’ve read the press reporting of your
adjudication. The adjudicator did not hold that “LEZ signage is
unlawful” per se; he said he was not satisfied _on the evidence
produced_ in that case that TfL had *shown*
authorisation/adequacy, so your PCN(s) failed. That sort of case
turns on the respondent’s evidential default, not a system-wide
declaration. Adjudicators’ decisions (they are decisions, not
rulings) aren’t precedents binding other cases.
*7. County Court proceedings.*
As widely reported, your later damages/declaration claim was
struck out on the basis that a systemic attack on the lawfulness
of enforcement and signage must proceed, if at all, by judicial
review, not by private law claim. That’s orthodox administrative
law. I appreciate you say you’ll appeal, but you’re flogging a
dead horse in my opinion. Your merits of winning are less than
10%. Judicial Reviews are the route to hold public bodies to
account.
*8. Auto Pay and Woolwich.*
If a public authority exacts money ultra vires, restitution
isn’t precluded by contract terms, Woolwich confirms that. But
you only get to engage Woolwich anyway if you first establish
that the exaction lacked lawful authority. Given the extant
authorisations under s.64/65 and the ‘times may be omitted’
clause, your route to ultra vires is blocked on the facts.
*9. “Abuse of process”because TfL enforced during an
adjournment.*
An adjournment in London Tribunals does not stay the entire
scheme. It merely preserves the status of the appealed PCN(s).
There’s no general principle that an adjournment bars ongoing
enforcement absent an express order. Different if you had
interim relief in the High Court - you didn’t.
*10. Your photo with the weight-limit roundel and LEZ/ULEZ
panel.*
The 2022 authorisation explicitly allows the authorised LEZ/ULEZ
symbols to be used on direction/informatory plates and to
replace symbols in diagram 818.4; it also authorises combined
plates. So the mixed assembly you’ve shown is within the four
corners of the authorisation.
*11. What might work (devil’s advocate).*
Your strongest litigation ground is never a sweeping ‘all signs
unlawful’ thesis; it’s targeted, site-specific non-compliance
like wrong x-heights, wrong colour values, missing or misplaced
plates, siting/visibility defects, or evidence that a particular
installation departs from the authorised drawings/notes e.g. an
unauthorised legend, or an omitted note-condition that is
*mandatory*. That sort of granular defect, proven with photos,
schedules and the DfT drawing pack, can still win an *individual
appeal* notwithstanding the general authorisations. But it won’t
invalidate the scheme globally (see Herron).
With respect, the proposition that LEZ/ULEZ signs were unlawful
between 2016 and 2023 because the 2002 TSRGD was revoked is a
misunderstanding of how s.64/65 authorisations operate, and it’s
contradicted by the 2018 and 2022 authorisations, which also
make your ‘AT ALL TIMES is mandatory’ point untenable. If you
can show specific deployments that diverged from the authorised
drawings/notes, that’s different but the blanket claim is simply
not sustainable.
If you send me a transcript of the written judgment I’ll happily
have a look at it to see if I’ve missed anything, but I think
you’ll fail even on a judicial review.
Equally, if you have any questions I’ll do my best to address
them now that I have more time.
Best,
Amy
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