Transport for Wales Rail - Fraud Enquiry - 'Misusing Multiflex Tickets'

[harmonica]

I have received an email from TWR stating that they I have misused their Multiflex tickets.

It seems as though I misunderstood how these tickets work and I thought they were Day Return tickets rather than single journey. So I used them in the morning, and then again the. same ticket to return home. When I scanned the ticket on the return journey, it opened the gate so I believed it to be valid. I did this for many months.

It was a genuine mistake and I feel slightly annoyed it took them so long to tell me let alone to even allow their systems to let me use a ticket that should have been not valid as it had already been used.

TWR are asking me to respond with any mitigating circumstances within 14 days, before they decide whether to pass the information to British Transport Police to progress the matter further.

I have spoken to a couple solicitors who have quoted me £700-900 to negotiate an out of court settlement.

Is there a template response anywhere that can assist me in approaching the rail operator directly to simply pay the fares I haven't paid?

 

[Fawkes Cat]

I have received an email from TWR stating that they I have misused their Multiflex tickets.

It seems as though I misunderstood how these tickets work and I thought they were Day Return tickets rather than single journey. So I used them in the morning, and then again the. same ticket to return home. When I scanned the ticket on the return journey, it opened the gate so I believed it to be valid. I did this for many months.

It was a genuine mistake and I feel slightly annoyed it took them so long to tell me let alone to even allow their systems to let me use a ticket that should have been not valid as it had already been used.

TWR are asking me to respond with any mitigating circumstances within 14 days, before they decide whether to pass the information to British Transport Police to progress the matter further.

I have spoken to a couple solicitors who have quoted me £700-900 to negotiate an out of court settlement.

Is there a template response anywhere that can assist me in approaching the rail operator directly to simply pay the fares I haven't paid?

Welcome to the forum.

It would help us to give you our best advice if we knew exactly what the railway are saying. So if you could show us the email (with your personal details redacted - you won't want the whole internet to see that) that would be really helpful.

 

[harmonica]

This is the Email they sent me:

Good morning.

This office is the investigating authority for Transport for Wales Rail Limited (TfW)

You are receiving this email as your travel patterns have recently been flagged for our attention. It seems you are using Multiflex tickets for 2 or more journeys.

When you complete a journey, the ticket is used and cannot be used again.

No break of journey is permitted for a Multiflex ticket and from the terms and conditions: “Each ticket can only be activated and used for one single journey which must be completed within 4 hours of activation.”

However, we can see many instances of you misusing Multiflex tickets. For example, you used the ticket with number XXXXXXX on XX August 2025 this ticket was scanned on a train and used to exit at the XXXXX station, but then you used the ticket for an additional 1 journey.

It is your responsibility to ensure you have the correct ticket for travel and purchased at the first available opportunity.

Therefore, we are satisfied we have sufficient evidence to legally escalate this matter with the information we have available to us namely under either:

The Regulation of Railways Act 1889 Section 5(3)

If any person —

1. Travels or attempts to travel on a railway without having previously paid his fare, and with intent to avoid payment thereof.
2. Having paid his fare for a certain distance, knowingly and wilfully proceeds by train beyond that distance without previously paying the additional fare for the additional distance, and with intent to avoid payment thereof.

Or, the legislations which carries the higher penalty:

Fraud Act 2006, Section 2 Fraud by false representation

1. A person is in breach of this section if he—
2. dishonestly makes a false representation, and
3. intends, by making the representation—

(i) to make a gain for himself or another, or

(ii) to cause loss to another or to expose another to a risk of loss.

However, before deciding which avenue to pursue we would like to give you this opportunity to present any mitigating circumstances.

We recommend that you seek independent legal advice from a solicitor versed in criminal law who is registered with the Law Society. It may also be an advantage if they have experience in Rail Fare Law as this is a specialist area.

If you do not respond to this letter within 14 days, we can pass this information to British Transport Police to progress the matter further.

Yours sincerely,

Retail Fraud Team

 

[furlong]

What are the two stations in question?

I think there is a degree of ambiguity in the wording used in the app. In particular, the most obvious statement they should have included - that to make a return journey you'll need to use two separate tickets - is not there and you're left to work that out by a careful study of the text based on unusual and inaccurate self-contradictory terminology such as "single bidirectional".

The use of "bidirectional" here is incorrect, meaning "functioning in two directions". While the product as a whole may be considered bidirectional, any single ticket is only valid in one direction so is not "bidirectional".

According to the app:

"Multiflex consists of 12 single bidirectional ticket(s), valid for 3 months."

"tickets can be used in either direction between your chosen origin and destination stations" - that's "either" as in "one or the other" not "either" as in "any, perhaps both, it doesn't matter".

So while I think if you read it all carefully you'll conclude a return journey needs two tickets, it is easy to see how someone who skims through it could be left thinking one ticket might cover a return journey.

How far could one take the argument that a "single bidrectional ticket" allows one return journey?

 

[John R]

Perhaps the best response is to apologise that you misinterpreted the description @furlong has set out as meaning a return journey, and offer to repay the amount due.

I agree that “single bidirectional journey” could be construed as a single (as in “just the one”) return trip.

 

[Titfield]

There are numerous examples of email responses to Train Operating Companies regarding ticketing irregularities on this forum.

The basic premise is that you should engage with the TOC and be honest, contrite and apologetic.

I would not say it was a genuine mistake but it was a misunderstanding as to what the ticket entitled.

Have you worked out what the difference in fares is?

Phrasing that the system allows you to misuse the tickets will be quite challenging and require some thought.

It does seem odd that a ticket which has been scanned (and therefore has been used) does not have some safeguard in place to prevent its reuse. It is problematic though for a TOC to differentiate between someone knowingly exploiting a loophole repeatedly and someone simply believing that as the system says "yes" it was ok to do that.

The TOC may well argue that with a non standard product such as the multiflex it is incumbent on the purchaser to make sure they knew the terms and conditions of use and if in doubt to seek a definitive answer as any diligent and honest person would.

 

[harmonica]

What are the two stations in question?

I think there is a degree of ambiguity in the wording used in the app. In particular, the most obvious statement they should have included - that to make a return journey you'll need to use two separate tickets - is not there and you're left to work that out by a careful study of the text based on unusual and inaccurate self-contradictory terminology such as "single bidirectional".

The use of "bidirectional" here is incorrect, meaning "functioning in two directions". While the product as a whole may be considered bidirectional, any single ticket is only valid in one direction so is not "bidirectional".

According to the app:

"Multiflex consists of 12 single bidirectional ticket(s), valid for 3 months."

"tickets can be used in either direction between your chosen origin and destination stations" - that's "either" as in "one or the other" not "either" as in "any, perhaps both, it doesn't matter".

So while I think if you read it all carefully you'll conclude a return journey needs two tickets, it is easy to see how someone who skims through it could be left thinking one ticket might cover a return journey.

How far could one take the argument that a "single bidrectional ticket" allows one return journey?

I agree, and coupled with the ability to use the ticket again later in the day seems as though their system isn't terribly supportive of helping the customer understand how the ticket can be used. Ironically, as of the 30th of September, the Multiflex ticket is no longer available for the journey I would normally take as they have now implemented a tap on tap off system with debit cards for the South Wales metro area.

But... I'm not interested in trying to argue the system was flawed. I'd like to just simply pay what needs to be paid and avoid any court involvement.

Any advice on how to begin the conversation without shelling out for a solicitor?

 

[harmonica]

There are numerous examples of email responses to Train Operating Companies regarding ticketing irregularities on this forum.

The basic premise is that you should engage with the TOC and be honest, contrite and apologetic.

I would not say it was a genuine mistake but it was a misunderstanding as to what the ticket entitled.

Have you worked out what the difference in fares is?

Phrasing that the system allows you to misuse the tickets will be quite challenging and require some thought.

It does seem odd that a ticket which has been scanned (and therefore has been used) does not have some safeguard in place to prevent its reuse. It is problematic though for a TOC to differentiate between someone knowingly exploiting a loophole repeatedly and someone simply believing that as the system says "yes" it was ok to do that.

The TOC may well argue that with a non standard product such as the multiflex it is incumbent on the purchaser to make sure they knew the terms and conditions of use and if in doubt to seek a definitive answer as any diligent and honest person would.

The difference is about £3.20 per direction, but I don't know how many times I did it. They simply say it's been 'many instances' .Do I ask the TOC to work out the figure?

 

[John R]

The difference is about £3.20 per direction, but I don't know how many times I did it. They simply say it's been 'many instances' .Do I ask the TOC to work out the figure?

I don’t think that would be unreasonable to ask.

 

[Titfield]

I don’t think that would be unreasonable to ask.

Surely you know how many multiflex tickets you have bought?

If you have used the ticket correctly sometimes and incorrectly sometimes it makes it more difficult to sustain the argument that you genuinely thought it was a ticket which could be used for a round trip journey.

 

[SuspectUsual]

The difference is about £3.20 per direction, but I don't know how many times I did it. They simply say it's been 'many instances' .Do I ask the TOC to work out the figure?

Presumably the worst case scenario would be that every ticket you’ve bought was inadvertently used twice? Can you look at your payment history and estimate from there?

 

[gray1404]

Are you dealing with a company called Transport Investigations Limited, another company or Transport for Wales directly?

 

[Gloster]

Be aware that a solicitor, even one who specialises in railway ticketing matters, cannot guarantee that they can negotiate an out of court settlement, but you will have to pay them their fees whatever. The experts on this forum can in most cases provide as good advice as a solicitor in this sort of matter and where they can’t they can give suggestions as to what to do next.

 

[AdamWW]

It does seem odd that a ticket which has been scanned (and therefore has been used) does not have some safeguard in place to prevent its reuse. It is problematic though for a TOC to differentiate between someone knowingly exploiting a loophole repeatedly and someone simply believing that as the system says "yes" it was ok to do that.

If I remember correctly how they work, they are a bit dangerous even if you do understand how they're supposed to be used.

You activate a ticket in the morning to head out. It shows as valid.

You then activate another one to go home and now have two tickets showing as valid but it's a criminal offence to use one of them.

It would be nice to have a way of manually marking one as used since the app can't do that.

 

[John R]

Surely you know how many multiflex tickets you have bought?

I guess that depends on how easy it is to look at the historic records going back over several months.

 

[Titfield]

I guess that depends on how easy it is to look at the historic records going back over several months.

I presumed that the OP knew the price of a book of 10 (as I think that is how they were sold) and using their bank records could calculate the number of books bought and the amounts paid.

If you were under the misapprehension that a single ticket was a return then the op would owe the price of all the multiflex books purchased because they have purchased exactly half the number of tickets needed.

 

[John R]

I presumed that the OP knew the price of a book of 10 (as I think that is how they were sold) and using their bank records could calculate the number of books bought and the amounts paid.

If you were under the misapprehension that a single ticket was a return then the op would owe the price of all the multiflex books purchased because they have purchased exactly half the number of tickets needed.

Yes, I would agree with the latter point. I am not clear how they were sold, or recorded, and given that TfW seems to have a good handle on the OP's purchasing history, it seemed easier to say "sorry, I misunderstood the terms, tell me how much I owe."

 

[WesternLancer]

Are you dealing with a company called Transport Investigations Limited, another company or Transport for Wales directly?

This is an important question to answer.
@harmonica can you clarify?

 

[Egg Centric]

I have received an email from TWR stating that they I have misused their Multiflex tickets.

It seems as though I misunderstood how these tickets work and I thought they were Day Return tickets rather than single journey. So I used them in the morning, and then again the. same ticket to return home. When I scanned the ticket on the return journey, it opened the gate so I believed it to be valid. I did this for many months.

It was a genuine mistake and I feel slightly annoyed it took them so long to tell me let alone to even allow their systems to let me use a ticket that should have been not valid as it had already been used.

TWR are asking me to respond with any mitigating circumstances within 14 days, before they decide whether to pass the information to British Transport Police to progress the matter further.

I have spoken to a couple solicitors who have quoted me £700-900 to negotiate an out of court settlement.

Is there a template response anywhere that can assist me in approaching the rail operator directly to simply pay the fares I haven't paid?

Have you ever been stopped travelling incorrectly on one or otherwise engaged with them, such as responding to their emails?

If the answer is no then whoever bought these tickets should just ignore this entirely imo. It's not a crime to buy them (in good faith). It's a crime for you to have misused them like that. But there's nothing connecting you to the purchaser.

 

[harmonica]

This is an important question to answer.
@harmonica can you clarify?

Are you dealing with a company called Transport Investigations Limited, another company or Transport for Wales directly?

The email came directly from Transport for Wales Rail Ltd

 

[gray1404]

Have you ever been stopped travelling incorrectly on one or otherwise engaged with them, such as responding to their emails?

If the answer is no then whoever bought these tickets should just ignore this entirely imo. It's not a crime to buy them (in good faith). It's a crime for you to have misused them like that. But there's nothing connecting you to the purchaser.

I agree with this. Unless you were stopped they have no proof who was using the ticket. They are relying on you giving them the evidence they need here. This is despite their very bold claims in the email about having sufficient evidence.

 

[Bletchleyite]

If I remember correctly how they work, they are a bit dangerous even if you do understand how they're supposed to be used.

You activate a ticket in the morning to head out. It shows as valid.

You then activate another one to go home and now have two tickets showing as valid but it's a criminal offence to use one of them.

It would be nice to have a way of manually marking one as used since the app can't do that.

If they're only valid for 4 hours you would think they would invalidate themselves in the app once that time was up!

 

[Titfield]

The OP has said that they wish to avoid court involvement.

If they do not respond then either TfW will drop the matter or it will progress to court.

Is this a risk the OP is willing to take?

The OPs posts suggest that this is a risk they are not willing to take.

I would suggest that the OP drafts a response for review here before then make the final decision whether to send the response.

 

[AdamWW]

If they're only valid for 4 hours you would think they would invalidate themselves in the app once that time was up!

They may do. I'm not sure the 4 hour limit was in place when I last used them. Originally they were valid all day including with a break of journey.

Which I took advantage of on occasion and I wouldn't rule out them coming after me at some point for using them in a way that was valid at the time but which I would struggle now to find evidence for.

 

[Belperpete]

I presumed that the OP knew the price of a book of 10 (as I think that is how they were sold) and using their bank records could calculate the number of books bought and the amounts paid.

If you were under the misapprehension that a single ticket was a return then the op would owe the price of all the multiflex books purchased because they have purchased exactly half the number of tickets needed.

TfW might ask for the price of a standard single, rather than the price of a multiflex single, for each occasion. And they might add on an extra admin charge.

If I were in the OP's shoes, I would start any reply off by explaining why they thought the ticket was valid for a return, by quoting any misleading wording presented in the app when buying the ticket. Burying something important like only being valid for a single journey in the detailed T&Cs that most people won't read, rather than making it obvious up-front in the app, is surely not right.

 

[harmonica]

Just for full information, this is the only explanation I can find when preparing to purchase a Multiflex ticket through the TfW App.

 

[furlong]

Exactly. It first tells you they are 12 return tickets (which is what 'single bidirectional' basically means) and then if you read the rest of the text with that in mind, while it's a bit confusing, it basically reinforces that meaning - no there and back "requirement" - but those words imply you may use one "there and back" should you wish.

If I'd been mislead by this I'd be pushing back and arguing the tickets were valid for a return trip based on the information displayed and relied upon when purchasing them as well as the actions of the barriers. But if you're not that sort of person, while still considering the culpability to be mostly theirs, you could still offer to pay them the actual money they missed out upon (based on purchasing the requisite number of additional multiflexes, pro rata).

 

[AdamWW]

Exactly. It first tells you they are 12 return tickets (which is what 'single bidirectional' basically means) and then if you read the rest of the text with that in mind, while it's a bit confusing, it basically reinforces that meaning - no there and back "requirement" - but those words imply you may use one "there and back" should you wish.

If I'd been mislead by this I'd be pushing back and arguing the tickets were valid for a return trip based on the information displayed and relied upon when purchasing them as well as the actions of the barriers. But if you're not that sort of person, while still considering the culpability to be mostly theirs, you could still offer to pay them the actual money they missed out upon (based on purchasing the requisite number of additional multiflexes, pro rata).

I think it relies on the assumption that the word "single" is taken in the UK rail concept of one way.

 

[WesternLancer]

The email came directly from Transport for Wales Rail Ltd

That’s better than if TIL - Transport Investigations Ltd (a ticket enforcement sub contractor that TfW seem to also use who are difficult to deal with) were involved I suspect. Thanks for clarifying.

 

[Belperpete]

I think it relies on the assumption that the word "single" is taken in the UK rail concept of one way.

But equally "single tickets" can be interpreted as meaning "individual tickets", i.e. you can use them one at a time. They are confusing the term "single ticket" and "single journey". Traditionally, one single ticket would be issued for a return journey, especially with Edmonson tickets (remember the days when ticket collectors would tear them in half and give you back the return half). It would have been clearer if they had explicitly said the tickets were only valid for one single journeys, not for return journeys.