Penalty Fare Notice No Railcard - HELP !

[pyrrhic]

Hello,

On 08/10, my sister received a Train Penalty Fare for the reason "No Supporting Document" (AKA, No Railcard presented): It was issued at 16:35 from Watford Junction to Garston. Her ticket was an open return, with the departure time of 8.34am to 8.39am. To be clear, she presented a valid ticket costing £3. As I understand it, the issue was that she bought a valid Anytime Day Return Standard Ticket ticket using the 16-17 Saver Card discount. The usual price (without railcard) is £4.40. She is now charged £100 plus the full single fare amount (£3), and it declares that the penalty is reduced to £50 + full single fare applicable if paid within 21 days.

I doubt she will get a successful appeal but I am please asking for any help for the reason that she is 17 years old and was confused; she presented a valid Hertfordshire Saver Card as she was previously unaware that this card is meant to cover bus travel rather than train travel. This journey was taken within Hertfordshire so I understand her confusion. I understand that she was unaware and that she had never been asked to present a railcard before, but is there any loophole / grace I can draw upon here ?

I attach her ticket and the penalty fare notice below.

Thank you for your help.

 

[AlterEgo]

We need to see the whole penalty fare notice with her details redacted. The only line of appeal here is likely to be technical.

 

[pyrrhic]

We need to see the whole penalty fare notice with her details redacted. The only line of appeal here is likely to be technical.

Woops I uploaded the wrong image, here you go:

 

[AlterEgo]

Invalid penalty fare. Wrong fare charged.

The appropriate fare at that time of day is £2.20 Off Peak Day Single. They've unlawfully charged her the £3.00 Anytime Day Single. You can successfully appeal the Penalty fare on this sole ground as per the law: https://www.legislation.gov.uk/uksi/2018/366/regulation/9

6) b) provides the grounds for appeal. It has not been issued in accordance with the regulations.

 

[John R]

You might want to put your draft appeal on here, so that posters here can review it before it's sent. Note that the first and second appeals are often rejected regardless of the validity of the appeal, so don't be surprised if you have to go to the third appeal to get a positive response.

 

[pyrrhic]

Invalid penalty fare. Wrong fare charged.

The appropriate fare at that time of day is £2.20 Off Peak Day Single. They've unlawfully charged her the £3.00 Anytime Day Single. You can successfully appeal the Penalty fare on this sole ground as per the law: https://www.legislation.gov.uk/uksi/2018/366/regulation/9

6) b) provides the grounds for appeal. It has not been issued in accordance with the regulations.

Hello, Does this mean the whole fine would be revoked or simply reduced? Thank you. Additionally - I want to remind that the time she travelled was 4pm, when the penalty fare was issued. I don't know if this changes anything.

 

[WesternLancer]

Hello, Does this mean the whole fine would be revoked or simply reduced? Thank you. Additionally - I want to remind that the time she travelled was 4pm, when the penalty fare was issued. I don't know if this changes anything.

A successful appeal would mean no fine is due. So it would be revoked.

The correct train fare may still have to be paid however.

 

[Skimpot flyer]

I’m assuming that by stating ‘I understand that she was unaware and that she had never been asked to present a railcard before’, your sister has incorrectly applied a 16-17 Railcard discount on previous trips?
She must not do this in future, as a second offence will flag up she’s had a Penalty Fare before, and may cause the Train Operating Company to look at her online purchase history

 

[WesternLancer]

Presumably this was the card held. Bus use only.

May well be a good idea if your sister does get a 16-17 railcard if she uses the train enough to be worth while and remains eligible. But important to replace with a 16-25 Railcard when becomes 18 and not be tempted to keep buying the more generously discounted 16-17 tickets.

SaverCard in Hertfordshire

Discount bus travel for Hertfordshire residents.

www.hertfordshire.gov.uk

 

[pyrrhic]

Thank you for your responses. I am unsure whether to include the accidental nature of presenting an invalid railcard as I fear that this will look bad? Please let me know what to add.

Here is my draft, please check it over and offer me some advice please:

I am appealing under the grounds of an invalid penalty fare due to the wrong fare being charged. The penalty of £3 atop the £100 penalty fare has not been issued in accordance with the regulations. The appropriate fare at that time of day (16:35 from Watford to Garston) is £2.20 Off Peak Day Single. You've unlawfully charged me the £3.00 Anytime Day Single. As outlined by the law in https://www.legislation.gov.uk/uksi/2018/366/regulation/9,"(6) In this regulation “the full single fare applicable” is to be determined by reference to— (b)the day and time of the journey that person is making, has made or intends to make, as the case may be".

This is my first documented penalty fare and as you can see, I have bought and presented a valid train ticket. For this reason, I am appealing for the entire fare to be revoked.

 

[John R]

I would delete the bit about presenting a valid ticket. Without the correct railcard it was not valid.

 

[Watershed]

I would also reword the appeal to be slightly less accusative and direct. The person or panel reading it doesn't work for the train company - they work for an appeals company that is (at least in theory) independent of the train company.

You just need to point out that the Regulations were not complied with, and therefore the PF was issued otherwise than in accordance with the Regulations. Therefore, the appeals body is obliged to allow your appeal and overturn the PF.

 

[Skimpot flyer]

I’d leave out the word ‘unlawfully’ too. It’s a tad combative when no valid ticket was held

 

[soccermad]

Thank you for your responses. I am unsure whether to include the accidental nature of presenting an invalid railcard as I fear that this will look bad? Please let me know what to add.

Here is my draft, please check it over and offer me some advice please:

I am appealing under the grounds of an invalid penalty fare due to the wrong fare being charged. The penalty of £3 atop the £100 penalty fare has not been issued in accordance with the regulations. The appropriate fare at that time of day (16:35 from Watford to Garston) is £2.20 Off Peak Day Single. You've unlawfully charged me the £3.00 Anytime Day Single. As outlined by the law in https://www.legislation.gov.uk/uksi/2018/366/regulation/9,"(6) In this regulation “the full single fare applicable” is to be determined by reference to— (b)the day and time of the journey that person is making, has made or intends to make, as the case may be".

This is my first documented penalty fare and as you can see, I have bought and presented a valid train ticket. For this reason, I am appealing for the entire fare to be revoked.

I would say penalty rather than fare in the last phrase of your last sentence ?

 

[pyrrhic]

Hello, my appeal got rejected. Should I just reappeal with the same draft?

 

[furlong]

Please share the wording of the rejection letter, and also the actual words used in the appeal. As your informal approach ("an invalid penalty fare due to the wrong fare being charged") has failed I suggest writing a formal appeal next time, filling in the gaps by quoting also the regulations 17.2(b), 16(3)(a), 17(4) etc.

 

[pyrrhic]

here is the appeal notice:
Thank you for your correspondence concerning the above referenced Penalty Fare Notice issued by West Midlands on Wednesday 08 October 2025.
The Appeals Service (AS) is independent of West Midlands. AS provide a service which gives the recipient of a Penalty Fare Notice the opportunity to dispute the issue. To ensure consistency, AS follow a Code of Practice compliant with the criteria set out in the Railways (Penalty Fares) (Amendment) Regulations 2022 when making assessments of Penalty Fare Notice appeals.
All transport companies operating a Penalty Fare scheme display warning notices which advise transport users of their obligations and the potential consequences in failing to meet these.
The transport user is obliged to show on request a valid ticket. When travelling with a discounted ticket you must be able to display supporting documentation which ensures validity of travel. Please refer to the railcard terms and conditions online at http://www.nationalrail.co.uk.
On assessment your appeal has been declined, however you have the right to re-appeal.
You may submit a further appeal by creating a new appeal online at www.appealservice.co.uk, by fax to 0844 544 8454 or send by post to AS, Regus, Building 1000 Lakeside, Western Road, Portsmouth, PO6 3EZ.
Payment of £53.00 or a further appeal must be received within 14 days of the date of this letter. If making payment, you also have any additional time left on your Penalty clock. Full payment options and information including, what will happen if you do not pay, are detailed with this response.
IMPORTANT: Please note that failure to pay or further appeal within this stated time may result in West Midlands taking further action to recover the outstanding debt.
Finally, as an appeals service which is independent of West Midlands we are unable to investigate complaints concerning West Midlands service or staff conduct. Please therefore contact West Midlands direct with your requests and concerns.

 

[pyrrhic]

And my letter is posted above, I think its the last day I can appeal so I may reappeal asap and then if I need to reappeal again please help me with another draft... I will quote the additional regulations you said

== Doublepost prevention - post automatically merged: 9 Nov 2025 ==

It won't let me post the message so I'll screenshot it. :

== Doublepost prevention - post automatically merged: 9 Nov 2025 ==

I've uploaded this as I am afraid to overrun the 14 day limit:

I am reappealing in accordance with 17.2(b), which states that a reappeal must be made on one or more grounds quoted in regulation 16.3; which is (a), the penalty fare of £3 atop the £100 was not charged in accordance with the requirements of these Regulations, As outlined in "(6) In this regulation the full single fare applicable is to be determined by reference to (b)the day and time of the journey that person is making, has made or intends to make, as the case may be". The appropriate fare at that time of day (16:35 from Watford to Garston) is £2.20 Off Peak Day Single. You've charged me the £3.00 Anytime Day Single. This is my first documented penalty fare and as you can see, I have bought and presented a valid train ticket while mistakenly buying a ticket with the Railcard discount due to my possession of the Hertfordshire Saver Bus Card which I have used to travel on buses before (but never trains, as on this occasion I assumed the bus card operated on the same grounds as a railcard; I was only freshly turned seventeen at the time and am not very accustomed to travelling on trains outside of TFL bounds). Ultimately, in accordance with(4) If the relevant Appeal Panel, after considering an appeal under this regulation, concludes that any ground specified in regulation 16(3) applies, it must, subject to paragraph (7), allow the appeal, I am hoping you will consider my reappeal.

I know it is not very good

 

[fandroid]

You do not need any of the wording after "£3.00 Anytime Day Single". It's not going to make any difference to their decision, and reduces the impact of the fact that the Penalty Fare Notice was in error.

 

[AlterEgo]

You do not need any of the wording after "£3.00 Anytime Day Single". It's not going to make any difference to their decision, and reduces the impact of the fact that the Penalty Fare Notice was in error.

Agreed. Keep the appeal simple.

 

[pyrrhic]

Help again please

 

[furlong]

So yet again, a response to an appeal that provides reasons that fail to engage with the content of the appeal?

How does this 'acknowledge the points raised by yourself' when it doesn't even refer to them in its decision?

How many more people is this appeals service allowing to be overcharged?

Perhaps once again, people might argue the train company's scheme itself is not compliant with the regulations as the purpose of the function is not only misstated but clearly not being performed - it is not merely 'to examine the circumstances surrounding why a notice has been issued' but rather to decide whether or not to quash the penalty in accordance with any of the criteria set out in the regulations.

Yes, you could make some small improvements to your wording, but I think your final appeal should be broadly the same. (It'll be 18 now rather than 17.)

And then report what happened to Transport Focus inviting them to take the inadequate contents of that letter up with "the Appeals Service" to help it address the evident shortcomings of its process.

 

[pyrrhic]

So yet again, a response to an appeal that provides reasons that fail to engage with the content of the appeal?

How does this 'acknowledge the points raised by yourself' when it doesn't even refer to them in its decision?

How many more people is this appeals service allowing to be overcharged?

Perhaps once again, people might argue the train company's scheme itself is not compliant with the regulations as the purpose of the function is not only misstated but clearly not being performed - it is not merely 'to examine the circumstances surrounding why a notice has been issued' but rather to decide whether or not to quash the penalty in accordance with any of the criteria set out in the regulations.

Yes, you could make some small improvements to your wording, but I think your final appeal should be broadly the same. (It'll be 18 now rather than 17.)

And then report what happened to Transport Focus inviting them to take the inadequate contents of that letter up with "the Appeals Service" to help it address the evident shortcomings of its process.

Thank you for your help, I really appreciate it. What is Transport Focus?

 

[WesternLancer]

Thank you for your help, I really appreciate it. What is Transport Focus?

Home - Transport Focus

Transport Focus is the independent watchdog for transport users. We put the interests of transport users first and aim to get the best deal for passengers and road users.

www.transportfocus.org.uk

Passenger watchdog. Statutory body iirc. Can pursue individual matters or matters of wider concern.
Sometimes quite effectively.