Thanks for clarifying this, but it is interesting that neither Greater Anglia's or Capital Connect's Penalty fare schemes authorise this. I shall make some enquiries with the DfT about the status of this shortly. As Greater Anglia's Penalty fare scheme provided under FOI is newer (on account of them being a newer Toc than Capital Connect) there must have been some point at which Penalty fares should not have been charged.FCC can and do issue Penalty Fares for Greater Anglia and have done since the beginning of the FCC franchise. It is written on the back of warrants for all inspectors.
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On Penalty fare notices used by the Tocs I have noted that there is a space for details of parent/guardian for Under 18s, but of course said person is neither legally obliged to provide this information or nor may they even have one!Penalty Fare notices have a section for the name of a parent or guardian if the notice is being issued to a minor.