Penalty Fare Appeal - Invalid Routing

[Swedenorer]

Interestingly at the moment the NRE site will offer this fare on some dates but only if you change at Teddington both for xx14 and xx44 departures from Upper Halliford. It will not offer this fare for tomorrow it will only offer £22.30. The Southern Site also offers the £8.80 fare without the change. The old forum site will not offer it at all for 23/2.

I freely admit the way it seems to be working others might well get different results but what else can you expect from an industry that uses negative easement as a synonym for prohibition.

As for the RPI I bet he looked at this ticket as askance as one at Worthing might look presented with a ticket from Barnham to Littlehampton.

 

[walkingsophie]

This does look like excellent rules abuse! (and expect Yorkie to be right about the routeing changing to NOT LONDON), BUT, as I see it the double back between ClaphamJ/Waterloo is only valid if you are actually travelling the Richmond route (Maps TW+EF). Otherwise there is a double back past New Malden (Map SU), and having chosen your mapped route you cannot switch...

Edit: I don't see how using map SU even allows you to get to Wimbledon...

Double backing at Wimbledon is valid via easement 000012.
I always ensure I go via Twickenham in at least one direction to ensure that I can do the double back between CJ and Waterloo.

== Doublepost prevention - post automatically merged: 10 Feb 2026 ==

First draft:

[Penalty Fare Case Number]

Dear Penalty Services,

I was travelling from Upper Halliford to London Waterloo on the 09/02/2025 1444 service with an Upper Halliford to Hinchley Wood Any Permitted Evening Out Return Ticket. I was charged a penalty fare for Incorrect Route at the gatelines at London Waterloo.
On the national rail planner, if you search for return tickets from Upper Halliford to Hinchley Wood departing at 14:30 and travelling via London Waterloo at an appropriate date in the future (for example 23/02/2026), it will show an itinerary using the Upper Halliford to London Waterloo train I was on. According to NRCoT (13.1.2), The tickets are valid as shown on an itinerary presented by the journey planner on www.nationalrail.co.uk, thus the tickets I produced were valid for my whole journey from Upper Halliford to London Waterloo

Yours Faithfully,
[My name]

Send with the PF notice and my tickets

 

[Fawkes Cat]

First draft:

[Penalty Fare Case Number]

Dear Penalty Services,

I am writing to appeal against the above penalty fare as my ticket was valid for the journey I was making

I was travelling from Upper Halliford to London Waterloo on the 09/02/2025 1444 service with an Upper Halliford to Hinchley Wood Any Permitted Evening Out Return Ticket. I was charged a penalty fare for Incorrect Route at the gatelines at London Waterloo.
On the national rail planner, if you search for return tickets from Upper Halliford to Hinchley Wood departing at 14:30 and travelling via London Waterloo at an appropriate date in the future (for example 23/02/2026), it will show an itinerary using the Upper Halliford to London Waterloo train I was on. I enclose a print of this itinerary. According to NRCoT (13.1.2), The tickets are valid as shown on an itinerary presented by the journey planner on www.nationalrail.co.uk, thus the tickets I produced were valid for my whole journey from Upper Halliford to London Waterloo

I would be grateful for your prompt confirmation that the penalty fare has been cancelled

Yours Faithfully,
[My name]

Send with the PF notice and my tickets

I've suggested 3 additions (n.b. - click to expand the box to see them all). The topping and tailing are to make it easy for SWR to understand quite what you want out of the process - they should be able to work it out easily enough, but as you want something from them, it's in your interests to make it really easy for them. And if you can generate a print of the itinerary which does what you want, I think it makes sense to enclose a copy: from the comments in this thread this does not seem to be an easy itinerary to create, and you wouldn't want SWR's response to amount to 'I can't get that itinerary, so I don't believe you could either': neither is it impossible that now this loophole has been uncovered it will be closed very promptly so that by the time your appeal is looked at, the itinerary is no longer available.

 

[walkingsophie]

Getting these printed and adding them to the mail should be sufficient, right?

 

[AlterEgo]

Getting these printed and adding them to the mail should be sufficient, right?

In, theory, yes.

Did you purchase the ticket against an itinerary?

 

[walkingsophie]

In, theory, yes.

Did you purchase the ticket against an itinerary?

No, I purchased the tickets from a ticket machine.

 

[furlong]

You need to frame this as an appeal!

State that you are appealing under 16(3)(a) of the regulations as you produced a valid ticket as required under 4(1) so 5(1) was never engaged.

See https://www.legislation.gov.uk/uksi/2018/366

 

[walkingsophie]

[Penalty Fare Case Number]

Dear Penalty Services,

I am writing to appeal under 16(3)(a) of the regulations against the above penalty fare as I produced a ticket that was valid for the journey I was making under 4(1), so 5(1) was never engaged

I was travelling from Upper Halliford to London Waterloo on the 09/02/2025 1444 service with an Upper Halliford to Hinchley Wood Any Permitted Evening Out Return Ticket. I was charged a penalty fare for Incorrect Route at the gatelines at London Waterloo.
On the national rail planner, if you search for return tickets from Upper Halliford to Hinchley Wood departing at 14:30 and travelling via London Waterloo at an appropriate date in the future (for example 23/02/2026), it will show an itinerary using the Upper Halliford to London Waterloo train I was on. I have enclosed a print of this itinerary. According to NRCoT (13.1.2), The tickets are valid as shown on an itinerary presented by the journey planner on www.nationalrail.co.uk, thus the tickets I produced were valid for my whole journey from Upper Halliford to London Waterloo

I would be grateful for your prompt confirmation that the penalty fare has been cancelled

Yours Faithfully,
[My name]


Does this look good?

Edit: For the benefit of people reading this in the future, when submitting the actual penalty fare appeal I have replaced the first paragraph with the following:

"I am writing to appeal against the above penalty fare as my ticket was valid for the journey I was making"


== Doublepost prevention - post automatically merged: 10 Feb 2026 ==

Also is there a significant difference between appealing via https://www.penaltyservices.co.uk/make-an-appeal/ and via post? I'd prefer to appeal online if possible.

 

[z444z]

Might it be more effective in this case to simply argue that the ticket was valid, rather than arguing that 5(1) was never engaged because of xyz? I would expect the appeals service to know to cancel a penalty fare if the ticket was in fact valid, all the additional legislative stuff may just confuse things and could always be added to the final stage appeal anyway if required.

 

[AlterEgo]

Might it be more effective in this case to simply argue that the ticket was valid, rather than arguing that 5(1) was never engaged because of xyz? I would expect the appeals service to know to cancel a penalty fare if the ticket was in fact valid, all the additional legislative stuff may just confuse things and could always be added to the final stage appeal anyway if required.

Yes, this. Just state and demonstrate the ticket was valid, that is all that is required.

 

[furlong]

(My words were only a brief summary of what needs to be explained. It's up to the OP how to phrase it.)

 

[walkingsophie]

I have now made an online appeal, will provide an update when they respond to it.

 

[z444z]

(My words were only a brief summary of what needs to be explained. It's up to the OP how to phrase it.)

Wasn’t a dig at your perfectly reasonable suggestion btw, just an alternative suggestion

 

[walkingsophie]

I've just realised I have typoed the date as 2025 instead of 2026 in my appeal. Hopefully that will not be a problem

 

[Fawkes Cat]

I've just realised I have typoed the date as 2025 instead of 2026 in my appeal. Hopefully that will not be a problem

The consensus round here is that while there are three rounds for an appeal, the first two tend to be a bit of a waste of time (although you have to go through them to get to the third appeal). So if this typo does cause a rejection, you can still put things right for the third appeal.

 

[walkingsophie]

Surprisingly enough, the first appeal was successful. I guess the new NRCoT does work.

 

[z444z]

Surprisingly enough, the first appeal was successful. I guess the new NRCoT does work.

That’s great! Would you be willing to share the response to your appeal? Would be helpful for us. Remember to redact personal details though.

 

[walkingsophie]

 

[z444z]

Thanks for sharing that, a fairly decent response but you’d hope so with something so simple.

Might it be more effective in this case to simply argue that the ticket was valid, rather than arguing that 5(1) was never engaged because of xyz? I would expect the appeals service to know to cancel a penalty fare if the ticket was in fact valid, all the additional legislative stuff may just confuse things and could always be added to the final stage appeal anyway if required.

Looks like this was indeed the way to go though.

 

[bb21]

Thanks for sharing that, a fairly decent response but you’d hope so with something so simple.

Maybe they read this forum

 

[walkingsophie]

Note that for the appeal I just showed the outbound ticket and the route the national rail journey planner showed, which implies that they now do the appeals based on the new NRCoT (13.1.2) rather than the routeing guide, as the ticket I showed would not have been valid for the whole journey with just the routeing guide. This might be helpful in the future when appealing more routeing based penalty fares, and I think is definitely helpful for the people giving advice here.

 

[bb21]

Note that for the appeal I just showed the outbound ticket and the route the national rail journey planner showed, which implies that they now do the appeals based on the new NRCoT (13.1.2) rather than the routeing guide, as the ticket I showed would not have been valid for the whole journey with just the routeing guide. This might be helpful in the future when appealing more routeing based penalty fares, and I think is definitely helpful for the people giving advice here.

Yes keep it simple where possible. Chances are people at the appeals body haven't even heard of the routeing guide so there is no point complicating things unnecessarily.

 

[sot]

An excellent outcome, well done.

I'm glad they said something along the lines that it was allowed routeing rather than the "we have decided to cancel this pf on this single occasion for some unknown reasoning that we are not going to share with you"

 

[jfollows]

Right outcome, but did anyone apologise for the errors which caused a Penalty Fare to be incorrectly issued in the first place? It doesn’t look like it to me.

 

[sot]

It may be worth a speculative post in the correct area, but given this new NRE validity rule I suspect sooner rather than later there will be some form of 'reasonable' adjective applied within the ruling - no London to London via Aberdeen allowed.

They seem to have opened themselves up to routes that were previously not allowed by the Routeing Guide for no reason.

Even more insane is the lack of requirement to even buy with an itinerary now, if NRE is good then all is good it seems.

That is unless this was valid due to some recursive LONDON routeing points or was within the allowed 3 miles.

OP - perhaps if you wish to account for the future usage, travel with a copy of the PF and appeal decision to convince and thwart any further unwarranted PFs. Or don't and demand some great compensation if it occurs again.

 

[walkingsophie]

It may be worth a speculative post in the correct area, but given this new NRE validity rule I suspect sooner rather than later there will be some form of 'reasonable' adjective applied within the ruling - no London to London via Aberdeen allowed.

They seem to have opened themselves up to routes that were previously not allowed by the Routeing Guide for no reason.

Even more insane is the lack of requirement to even buy with an itinerary now, if NRE is good then all is good it seems.

Yes, there's a high potential for exploiting here.

That is unless this was valid due to some recursive LONDON routeing points or was within the allowed 3 miles.

In this case neither of these apply, and in fact the Upper Halliford to Hinchley Wood ticket is not valid between Wimbledon and Clapham Junction according to the routeing guide.

 

[z444z]

Yes, there's a high potential for exploiting here.

Then they should make their website work properly, and if they can’t do that it’s probably a sign the fares system needs simplifying? Am I missing something?

 

[ChilliSauce]

A

Right outcome, but did anyone apologise for the errors which caused a Penalty Fare to be incorrectly issued in the first place? It doesn’t look like it to me.

Personally I am not sure if it is the role of "Penalty Services" to apologise for the failing of the TOC by way of clearly wrongly issuing the PF.

Perhaps the OP should now open a customer complaint with SWR complaining they had to go through the procedure of appealing a PF that basically should never of been issued in the first place, and seek a reasoning from SWT for this failure and an apology for inconvenience caused.

 

[Starmill]

Have you raised a complaint about the inspector with SWR customer services?

They're unlikely to cough up anything much but if I were you I would send them a copy of your appeal being allowed and ask them to confirm if they agree the inspector made a mistake which caused you to waste a significant amount of your time. It will be interesting to see what they say. In theory they could be liable for damages for your wasted time, if they accept that the inspector shouldn't have issued the Penalty Fare, though they are very unlikely indeed to accept that point willingly. This certainly won't amount to much in cash form but say £40 for two hours of work for you filling in the appeal and dealing with the correspondence seems reasonable to me.

== Doublepost prevention - post automatically merged: 17 Feb 2026 ==

Personally I am not sure if is the role of "Penalty Services" to apologise for the failing of the TOC by way of clearly wrongly issuing the PF.

Perhaps the OP should now open a customer complaint with SWR complaining they had to go through the procedure of appealing a PF that basically should never of been issued it the first place, and seek a reasoning from SWT for this failure and an apology for inconvenience caused.

These messages crossed in the posting, but I agree with the suggestion. This can be done without referring to the possibility of a breach of contract or damages for wasted time if preferred, as it's less confrontational.

 

[bakerstreet]

Possibly one for a separate thread, but I’m appalled that we are now in a position where (ignoring anyone on this forum testing validities of routes) passengers essentially risk a penalty fare by taking an invalid route when it should be pretty obvious that somebody who:

- possesses a ticket,
- is travelling from the origin and to the destination on the ticket,
- or is asking to break their journey
- has appropriate supporting documentation for the journey (eg railcard)
- that the journey is taking place on the correct date
- and the ticket is valid for the time the journey is being made,
- is not taking the Michael
- is an adult or child and the ticket matches the passengers status

is most likely to be an honest passenger.

I think this is one of the most egregious changes in recent times to ts and cs on the English railway.

To be required to pay a penalty fair under the circumstances, and be logged as a wrongdoer in the railway system, is very worrying in my opinion