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Dear Sir or Madam,

I write to make formal representations against Penalty Charge Notice TF-2026-00891, issued by the London Borough of Camden on 3 March 2026 in respect of an alleged bus lane contravention on Euston Road, London NW1.

Ground 1 — Non-compliant Signage (TSRGD 2016)

The Traffic Signs Regulations and General Directions 2016, Schedule 10, Part 6, prescribes the exact form, dimensions, and positioning of bus lane signs. The sign at the junction of Euston Road and Eversholt Street does not conform to the prescribed height requirement of diagram 958.1 and is partially obscured by an adjacent street light column. A traffic restriction sign that does not comply with the Regulations is not a lawfully placed sign, and enforcement of the restriction is therefore unlawful.

In Vine v Waltham Forest LBC [2000] EWCA Civ 106, the Court of Appeal held that traffic signs must be adequate to inform a driver of ordinary intelligence. Where signage fails to meet this standard, the restriction is unenforceable.

Ground 2 — Defective Traffic Management Order

Section 73 of the Traffic Management Act 2004 requires that every civil traffic enforcement action be supported by a valid Traffic Management Order. I have reviewed the TMO register published by the London Borough of Camden and note that TMO 2019/42, which purports to authorise bus lane enforcement on this section of Euston Road, was not re-published following the road layout changes completed in September 2024. The Civil Enforcement of Road Traffic Contraventions (Representations and Appeals) Regulations 2022, regulation 4(4)(b), provides that representations may be made on the ground that a traffic order is invalid.