OK it's a subjective judgement but before 2018 there was a two stage appeals process and afterwards it was a three stage one, so it's definitely increased. I didn't pronounce on whether it was any better...
The only reason I brought it up was to highlight the asymmetric way that the process is approached. The origin of the 2018 changes had been a request to increase the Penalty Fare, but because at that time TOCs took revenue risk it suited Government to refuse that and instead require that passenger 'protections' were improved. Now given that there was already a two stage appeal process a real attempt to improve things would have been to overhaul that at the same time as uprating the 'Penalty' to be more effective so that the whole scheme worked better but the 'optics' for Government were better served by 'refusing' the increase because it was TOC money and creating a new third stage appeal process. Remember at that level it's all about PR/press releases and scoring points in Parliament.
Fast forward to 2022 and now the money is going to Government so suddenly they wake up to the need to increase the Penalty Fare. The reason they went ahead without any change to the appeal process is because, in their narrative, it was already dealt with in 2018. All I was doing was making the point that in Government's eyes, there was no need to address the appeals side because to them, it was already sorted. In that world, reality doesn't count for much.