Deemed-service / date-of-service arithmetic
Every statutory window runs from the 'date of service', and a posted notice is deemed served in the ordinary course of post (not the date printed on it). If the authority miscounts — treating representations or an appeal as out of time when, with correct deemed-service dating, they were in time, or escalating (enforcement notice / charge certificate) before a window it computed from the wrong start date has actually closed — the escalation is invalid. A genuinely distinct arithmetic/timing ground, but the exact current provision setting the deemed-service rule for these London notices still needs pinning (Interpretation Act 1978 s.7 and the LLA 1996 Sch 1 service-by-post provisions are the likely basis).
Legal basis
London Local Authorities Act 1996, Schedule 1 — para 12 (service by post), para 2(3) (28-day representations window from date of service), para 6(1) (28-day appeal-to-adjudicator window from date of service), para 8 (charge certificate 50% uplift only after service-linked 'relevant period') — read with Interpretation Act 1978 s.7 (deemed service in the ordinary course of post). Both in force. Applies to London bus-lane PCNs (LLA 1996 regime, London Tribunals), NOT London parking PCNs or the outside-London TMA 2004 regime.
How to identify this in your case
Work out when each notice was actually deemed delivered (typically ~2 working days after the date on it, if posted), then recount the 28 days. If the authority rejected your challenge as 'late' or escalated before your recounted deadline, the timing is wrong.
Sample appeal wording
formal
Replace [PARKING DATE], [NtK DATE] etc. with your own dates before sending.
Beat It writes this argument automatically
Scan your PCN — our AI checks if this ground applies to your specific ticket, drafts a properly-cited appeal letter, and submits it to the council on your behalf. Only pay if you win.
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