Internecine PCN warfare

 

Some motorists have a pessimistic attitude, that councils and TfL have it in for them. They shouldn't feel individually persecuted, councils have it in for everyone, including other local authorities (and possibly their contractors). Every motorist is a possible rich revenue source.

Here is a tribunal case in which Islington Council try to avoid giving Haringey Council £160 and fail.

 

 

An adjudicator decides the case based upon the evidence put in front of them. The argument put forward was 

Had there been an official diversion in place one would expect there to be diversion signs. The cctv at this location is within Frobisher Road so looks at the backs of the signs (they can be proven by library images). If Islington Council had proof of signage diverting them into Frobisher Road that would have been an exemption to the pedestrian and cycle zone. However, Frobisher Road is part of the 'Haringey ladder' and I would therefore expect any diversion to have been through a different 'rung' one without a school within it. it is easy to lose a case by not proving it. If the explanation was true it was not adequately evidenced.

Islington Council lost £160 (unless they make the employee pay) and Haringey Council lost a c.£30 tribunal fee. Both sides lost bundles of time.

The alternative is that councils let each other off but that isn't satisfactory either, as council employees piously tell us we should look out for signs, so what is sauce for the goose....

The end. 

Barnet Council - your number's up

 

Older readers will get the reference to 'come in number x'

This was an odd case although Mr Mustard has now seen a second instance of it in a different borough.

For starters the PCN was for the wrong contravention, it was for code 01 but should have been for code 02 as loading was also banned.

The motorist, Mr D, sent Mr Mustard a copy of the PCN placed on his car windscreen which ended with the numbers 6618. That could not be found on the council computer and so Mr Mustard just kept an eye out to see what would happen next.

A month later Mr D received a Notice to Owner bearing a number ending 6607 for the same set of facts (date, vehicle, location etc).

What you need to know now is that PCNs are issued in sequential series by individual traffic wardens and that the last digit of a PCN is a check digit so the PCNs in this case were 660-7 and 661-8 and thus they had been consecutively issued at the same time.

What had therefore happened was that the traffic warden had decided something was wrong with 660-7 and issued a fresh PCN 661-8 intended to cancel 660-7 but accidentally cancelled 661-8 (or the computer took over and did it).

It was therefore an easy win as 661-8 was never served and Mr Mustard had proof that 660-7 was served.

Mr Mustard made out three arguments in his formal representations to the council.

1    Finchley Road as a description of the location is too vague (the keeper and driver may be different).

2    Loading is banned so the alleged contravention is incorrect.

3    The PCN was not served.

The Notice of Rejection didn't tackle points 1 and 2 and said that the PCN was either placed on the windscreen or given to the driver. It also waffled on about CPZ entry signage which was irrelevant as there was a local sign.

Thus it was an easy decision to start an Appeal at London Tribunals at which time a fourth Ground of Appeal was added which was the Notice of Rejection dated 14 August offered a 50% discount for 14 days from service and 2 days earlier it had already been removed. A council must be as good as their word.

There was no need for a hearing. Faced with an opponent with 4 straight arrows in his quiver the council cancelled the PCN.

The end. 

Newham Council - in another world - one you don't want to be in.

 

Mr Goodson (not his real name) received a PCN and thought that it would be quickly cancelled so he made his own representations. He was wrong and so Mr Mustard took over at the Notice to Owner stage. Mr Mustard re-used his grounds as well as adding his own.

1    The PCN was for the wrong contravention. Newham Council did not create a restricted street, they suspended the use of a bay. Councils often get this wrong.

2    The Notice to Owner did not contain a postal address to which to write so was non-complaint 

3    The informal challenge made by Mr Goodson was as follows:

On Sunday 13 April 2025, at 3.25 pm, I had to urgently take my 77-year-old father to the hospital following a sudden episode of rectal bleeding. He suffers from a neurological condition resembling dementia, making it impossible for him to manage hospital interactions independently. I am his primary carer and was the only person available to accompany and remain with him.

Due to this emergency, I was not able to return home before the bay suspension came into effect. At the time of leaving, there was no plan to stay overnight and the decision to stay overnight was only taken due to medical necessity and hospital advice.

The car was parked lawfully in a permit holder space on 13 April. The suspension began on 14 April. When the emergency occurred, I had no reasonable opportunity to relocate the vehicle, and no one else was available at the household to move it.

Please exercise your discretion. A hospital document is attached.

Please cancel the PCN for any of the three reasons advanced above.

Now Mr Mustard rather thought that any reasonable human being would cancel the PCN due to the medical reason being an unavoidable emergency but he was wrong. 

The Notice of Rejection contained the following:

Mr Mustard was outraged by the response but getting mad doesn't help. He had already lined up his arguments to pick apart the obvious flaws in the council's logic (or failure to understand reality) but decided to keep his powder dry and obliterate Newham Council once they had produced the evidence pack and the full glory of their unreasonable position was there to shoot at, so the Grounds of Appeal were short, but carefully targeted:

The tribunal appeal had been made on 1 August 2025 and because of a temporary adjudicator shortage was listed for hearing on 12 November. On 7 November Newham Council suddenly decided they didn't want to fight Mr Mustard at the tribunal and filed a 'Do Not Contest' form and cancelled the PCN because:

Therefore there was no traffic management order when Newham Council rejected the informal challenge. 

There was also no traffic management order when they rejected the formal representations made by Mr Mustard. 

This probably does count as a PCN which Mr Mustard could have written up in the Newham Council are Cheats series but it is in a special category all of its own.

Councils don't think of PCNs as having been issued to a human being, they are just a number PN12345678 etc, just a job to be done and when this one is finished there will be another, another and another.

Mr Mustard has to spend some of his time dealing with the physchological fallout reassuring a motorist that everything will turn out all right (and Mr Mustard is fortunately right 85% of the time).

Mr Mustard was confident, provided he didn't get a green adjudicator who might not yet fully grasp the law, that he would win the day on his wrong contravention argument alone. However, Mr Mustard is the veteran of 2,000 PCN fight in the last 7 years so has all his ducks in a row but the motorist may only have had one or two in that time so doesn't know how strong his case is and motorists are inclined to think that councils must be honest, they may be in other areas but often not in PCNs.

Here is a short exchange of emails:

Motorists should not be put under this much strain by councils who reject what turn out to be perfect challenges. The trouble is there isn't a body charged with oversight of their day to day actions. It is assumed that a council will act fairly as Lord Mustill stated in a House of Lords decision:

Where an Act of Parliament confers an administrative power there is a presumption that it will be exercised in a manner which is fair in all the circumstances.

It is high time a supervisory body was formed to make sure this is the case.

The end. 

Hounslow Council find the end of the road

 

Car drivers are in the habit of finding every possible extra parking space. This location is one that ended up at the tribunal where the PCN was cancelled for the simple reason that the alleged contravention had not occurred. The mistake the traffic warden (CEO) made is a common one or it isn't a mistake, they are just taking a flyer.

This wasn't one of Mr Mustard's cases so he doesn't have any photos for you but we can surmise that a car was parked in the middle of the carriageway fairly close to the brick wall which terminates the carriageway. Mr Mustard expects the car was within the white rectangle.

The neighbours probably have an arrangement to block each other in and move when required. An arrangement with a traffic warden is a dangerous one as they come and go and their boss might intervene.

If you are so parked both sides of your car are more than 50cm from the edge of the carriageway and if the car was reversed in then the front of the car is also more than 50cm from the edge of the carriageway. However, providing the car is backed up to within 50cm of the wall, as it must have been in this case, it is not in contravention.

Not only should the traffic warden not have issued the PCN, the council should not have rejected the representations and nor should they have resisted the Appeal but £130 was at stake and that causes errors of judgments within councils, not just Hounslow..

Redbridge Council - not so fast

On 4 June Mr Mustard lost a tribunal appeal which related to Redbridge Council. He advised his client to pay the £110 within the 28 days allowed, which was done. The motorist also very generously made a donation to the North London Hospice.

On 9 June Mr Mustard filed a Review request at the tribunal. The Chief Adjudicator considered it and listed it for a Review hearing on 2 July. At the Review hearing the original decision was over-turned and Redbridge Council were ordered to make a refund of the £110 'without delay'.

Mr Mustard thinks that allowing 28 days is reasonable for any refund, that being the same timetable as the public gets to pay up in.

On 30 July the motorist chased Redbridge for his refund. Silence ensued, a refund didn't arrive.

He kept on chasing to no avail and then asked Mr Mustard for his advice.

Mr Mustard gave him the direct email of a manager who he had previously dealt with. That was on 17 September. A reply wasn't received but a refund was.

Perhaps the apology is 'in the post'.

Councils should put as much effort into a refund as motorists have to do into paying them promptly. If the boot had been on the other foot the council could have increased the penalty to £165. There will be no compensation for the delay by the council.

Councils should also have good manners. They would be better regarded if they did. 

Newham Council are Cheats - #17

 

The adjudicator may well be correct in that the CEO (Civil Enforcement Officer or 'traffic warden') was present at the moment when the signs were changed or it could just have been unlucky timing but there are only 26 minutes to play with.

When signs are replaced the registration numbers of already parked vehicles should be taken so that if they are given a PCN it can be cancelled by the back office.

The morning briefing for traffic wardens should also notify them of signs which are being changed that day so that they can steer clear for the day.

The back office carried on with their apparently ignorance based cheating. 

Newham Council are Cheats - #16

 

Yet another case in which the CEO (Civil Enforcement Officer or 'traffic warden') cheated by taking photographs of irrelevant signs in order to try and support a penalty charge. The resident's local knowledge was useful, the bogus sign photographed was always likely to be nearby.

It led to another unlawful vehicle removal.

Newham Council are cheats.

Newham Council are Cheats - #10

 

PCNs are used these days as a blunt instrument of revenue raising to fill holes in council budgets. Humanity, service to residents and fairness seem to be alien concepts in council parking departments these days (Mr Mustard does get to see them when he approaches senior management but those cases are the exception, he can't deal with the 5m+ PCN issued a year in London). 

Mr Umar is a good man helping his elderly and disabled grandmother into a wheelchair and to transfer to the car. He has been abused by Newham Council. Luckily he has a backbone and a sense of right and wrong.

He was cheated out of a Notice of Acceptance.

He was cheated out of hours of his time:

- in starting an Appeal to the tribunal which he shouldn't have had to fight

- spent in considering the voluminous evidence pack, probably 100 pages

- spent in preparing his case and appearing on line and explaining his case, clearly in quite a lot of detail, to the adjudicator

- spent worrying that surely a council must surely be right and he would end up having to pay £130 as the discount was long gone.

Councils need to reflect upon the results of their actions and 99.9% of what they write should be accurate, not the usual sleight of hand responses which Mr Mustard gives a good kicking to because of his profound knowledge.

Barking Council - wide of the mark

 

Barking & Dagenham Council got the law absolutely wrong in this case. 

They had already rejected a good challenge by the motorist at the PCN stage.

Mr Mustard stepped in at the Notice to Owner stage. He used the council's online system which asks standard irrelevant questions. Whoever sent the rejection did not know what they were doing. Loading/unloading and boarding/alighting are completely different concepts.

The kerb marks would probably have been found to be inadequate as they are not bright and there should be one every 3 metres or so, so that there is always one adjacent to the vehicle. 

Mr Mustard started an Appeal to the independent adjudicators at London Tribunals. Just before the case was due to be heard Barking threw in the towel and cancelled the PCN.

Mr Mustard is concerned that most motorists would believe what a council writes no matter how wrong.

Sadly there is no remedy within legislation which obliged a council which contravenes the Regulations to pay a penalty. There should be in order to improve the quality of processing of representations.

The end. 

Harrow break the 56 day law

 

This blog relates to Harrow Council. They have made the same mistake as Barnet made back in 2016, here.

The above image displays the grounds on which Mr Mustard started an Appeal to the independent adjudicators at London Tribunals.

Councils get given 56 days to consider and respond to formal representations against a parking Notice to Owner whereas motorists only ever get 28 days to make them and a council really ought to be able to cope, if not they should issue less PCNs.

In addition, given the law sets a deadline to which councils must adhere and of which the average motorist will be ignorant all councils should programme their software in order to stay within the law. Sadly, there is no penalty if a council breaks the law.

In this case within a fortnight of hearing of the Appeal being started Harrow Council threw in the towel. 

The end. 

Horrible Havering

 

The PCN from the above is an extract was a pretty standard document. What wasn't standard was the state of the yellow box at the point at which the allegedly contravening car entered it.

It is impossible to commit a yellow box contravention (entering and stopping die to a stationary vehicle) if there isn't another vehicle in sight! That didn't stop Havering, they must have hoped the motorist would be a mug, far from it, he knows Mr Mustard.

Three seconds later, this was the scene 

Still not another car in sight, still not a contravention, the car is clearly stopped so that the words on the yellow sign can be digested.

Mr Mustard made the formal representations which said this.

When the situation is patently absurd no point in writing lots of words as surely the most inept council officer will realise an error has been made?

Apparently not! 

Mr Mustard didn't hesitate, he started an Appeal at London Tribunals. 

That was on 11 April.

The hearing was listed for 25 June.

On 12 June Havering Council realised they were in for a bruising and cancelled the PCN.

Their ability to decide whether a PCN has occurred is inadequate unless of course it was their computer which decided in which case it needs reprogramming.

The decision to reject the representation was made by a complete nincompoop.

The only goods news to come out of this is that the North London Hospice will get £65 which is the sum Mr Mustard bet the motorist that the Appeal would be won.

If Mr Mustard wins the motorist pays the £65 to the Hospice not to Mr Mustard.

If Mr Mustard loses he pays £65 to the motorist make up for the lost discount.

Mr Mustard rarely pay outs as he rarely loses when he offers this deal, at his own discretion.

The end 

How the penalty unfolded

 

This is a case which Mr Mustard took to Appeal at London Tribunals. When the motorist parked the water was deeper and the driver didn't notice the dropped kerb as it was under water and as there isn't any dimpled paving.

This location leads nowhere, with the road being made into a cul-de-sac by bollards set in the carriageway to stop all but cyclists and motorcyclists from going through.

It is 6 roads to the east of Fore St and is very quiet. The point of giving a PCN to a car having made an innocent error was lost on Mr Mustard and the car could easily have been relocated instead of being towed but that would leave Enfield Council £200 down.

As it happens Mr Mustard knows the location because he helps a company on the Eley Estate and sometimes he cycles there from High Barnet and the grey path showing in the greenery is part of his route.

In this case the CEO who issued the PCN was the one who spends his day as a passenger in the tow truck. The PCN was timed at 09:19 and the car was towed at 09:24

Mr Mustard made representations to the council on four grounds

1. The drop was unclear due to standing water.

2. The PCN was not served.

3. There was no traffic management purpose.

4. The council quoted the wrong Regulations, 2007 instead of 2022.

The council rejected the representations, they didn't go into great detail about the particular facts, just spouted the usual stuff about rules. Mr Mustard had no hesitation in starting an Appeal as in a removal case the PCN has been settled in full and final at 50% and the £200 removal fee has already been paid so the worst result, of losing, doesn't cost the motorist anything extra.

The grounds of Appeal follow:

The exact wording of the not served argument was follows:

The reason that Mr Mustard included that argument was because the plastic wallet was so flat that it seemed unlikely that it contained anything.

 

Enfield Council's evidence was

At the in person hearing of the Appeal Mr Mustard handed up to the Adjudicator the original PCN which his client had posted to him under the clear instructions to use a large envelope and not fold the PCN. The benefit of keeping all PCN paperwork in an unadulterated condition will become clear to you in a moment. The adjudicator agreed (having already decided to cancel the PCN on another ground of less interest) that a piece of paper which has to be folded twice to be placed within a small plastic envelope would show signs of creasing:

Mr Mustard knew to look for this as he had noticed it in another borough and from memory it may have been when he actually saw a car being towed.

Should you be unlucky enough to have your car removed please keep all of the paperwork exactly as it is given to you at the car pound, places which are a bit incompetent, and which may save you £265.

This motorist who turned up on the day to the tribunal as she was free was delighted to get her £265 back and spent c.£3 of it on a pint of Greene King IPA for Mr Mustard in the local 'spoons' where they repaired after the hearing along with another representative who had his own cases that day.

The end.

Discounts - not offered - a new trend

In 2024 Mr Mustard and other experts noted a number of rejections in which enforcement authorities in London stopped offering the discount when issuing official Notices of Rejection which open the door to the independent tribunal.

Motorists often complain that the penalty has doubled and he pedantically points out that is not tree, it simply hasn't halved, it was always £130, £110, £80 or whatever the case may be.

Let us start with a PCN placed on your vehicle.

You can describe the 50% discount as a sweetener, an incentive or a bribe as you like. If you are bang to rights then the discount is worth taking advantage of. It speeds up the process, saves administration costs and time and puts the PCN behind you. The statutory guidance of the Secretary of State requires if a PCN is placed on your car on the 1st of the month and your informal challenge, as it is known, reached the council by the 14th of the month (that is day 14 as the 1st is counted as day 1, a common error is to add 14 not 13) then if that challenge is rejected the 50% discount must be offered again for 14 days. The PCN will also state this.

What has usually happened, as it was easier, is that all informal challenges for at least the first 28 days (and longer if the Notice to Owner was not issued promptly), were met with a templated rejection that offered the discount again for 14 days from receipt of the letter (sometimes the date of the letter) in an attempt to 'get rid' of a PCN. It was a system that worked as most motorists don't have Mr Mustard's staying power.

When the Notice to Owner is issued discounts are officially no longer available. However, for those tougher motorists who make formal representations, which can be identical to the informal challenge, it doesn't matter if the council have said no once already, most councils still offered the discount again for another 14 days.

The reason is simple. Councils would rather have quick money and an easy life. If the motorist starts an Appeal to the independent adjudicator at London Tribunals, as Mr Mustard does for nearly every PCN he fights, the council in question will have to produce the evidence pack containing all of the documents from both sides about the PCN, the traffic order, photos of signs and a written summary of the case. This will take 2 or 3 hours so is expensive. In addition, there is a fee which they have to pay to fund the tribunal setup of c.£30 for each PCN appeal started whether or not it goes ahead and win or lose. Costs are very rare so can largely be ignored.

In 2024 Mr Mustard, and other experts who swap notes and advice, noticed a trend at the formal representations stage (after the Notice to Owner) that the sum demanded in the Notice of Rejection was the 100% figure. They know that many motorists are a bit afraid of the tribunal although they don't need to be, it is an informal forum and therefore rather than doing something new the tendency in the past was to pay up the 50%. Now that some councils are asking for 100% and going to the tribunal doesn't cost the motorist anything except a little time (and from next month your hearing can be on Microsoft Teams so you don't need to go to Chancery Lane) it appears to the experts that there is no incentive to meekly pay up like a mug provided you have at least a bit of an argument (not a load of silly baloney). It will be interesting to see if more Appeals are made in 2025.

This policy change will make no difference to Mr Mustard. He tries to educate his motorists from the off that he tries to find arguments that could work at the tribunal (he is usually only 91% accurate and at least one other expert is more successful) and sets out his stall from the beginning to fight to the end. Sometimes he realises an existing argument will no longer work but picks up a new one along the way so his trip along the high wire can be a bit exciting.

The other point in favour of motorists is that if councils can't keep up with surges in Appeals they sometimes just let them go and cancel the PCN to save time. This is known as the DNC process (Do not contest). Mr Mustard had 54 DNC cases in 2024 (very few from Barnet) across his 300+ cases.

Looking now at moving traffic PCNs for yellow box junctions, banned turns etc there is only one challenge to the council before the tribunal. Again most councils used to always offer the discount again when rejected you but the law does not require them to offer it at all. Moving traffic legislation is quite blunt. If you pay within 14 days of the date on the PCN you can definitely have the discount, otherwise not. If you challenge on day 10 and get rejected on day 20 a council can insist on 100% being paid (or watch you go to Appeal). Many motorists think of these PCNs the same as parking ones as years ago there were mostly parking PCN and not much else but given the wide implementation of 'school streets' and other 'low traffic neighbourhoods' the numbers of these PCNs has mushroomed.

If we finally consider London bus lane PCNs you get sent a PCN and then if still unpaid an Enforcement Notice. Again if you don't pay the PCN within 14 days the discount could be gone. The Enforcement Notice, just like the Notice to Owner in parking, does not include a discount offer. The informal rejection and the Notice of Rejection may include a discount offer but they don't have to (unless the council documents says otherwise in which case out of fairness the offer must be honoured).

Now, finally, to the trend which has been witnessed.

Mr Mustard had a look through recent Notices of Rejection and found that the following councils did not offer the discount as an incentive to pay up rather than start a tribunal Appeal. Mr Mustard started Appeals for them all as he is confident in his arguments.

Enfield

Islington

Camden

Redbridge

Haringey

Brent

Mr Mustard will add other councils to this list as he notices them. It isn't necessarily the case that these councils won't sometimes offer a discount, it may depend how strong they think the case is, a sort of cost benefit analsysis. What Mr Mustard hasn't done is ask any questions about council policy. He will do so when he finds some time.

Mr Mustard's advice is simple. Do all your work at the start and decide if you want to fight or fold. If you want to fight, put all of your energy into it, no half measures.

The end

Redbridge - Cranbrook Road - PHVs not exempt on red route (black cabs are exempt)

 

The vast majority of Appeals by PHV drivers at this location have been accepted. They only occur of course once the motorist has made representations to Redbridge Council and been rejected, even though the council know that the small percentage of people who Appeal to the tribunal are likely to win. The council don't want anything to get in the way of revenue raising, certainly not fairness.

It is quite rare for red routes in London to be under the control of any authority apart from TfL. This has left PHV drivers in a difficult situation, they don't know when the passenger wants to be dropped on a red route whether or not they will receive a PCN for it.

If you are calling a minicab and are adjacent to a red route please help the driver by going 25m down a side road, where the red route has ended and calling from there.

The original Appeal was lost. It shouldn't have been as the Traffic Order was not in evidence and there doesn't need to be a consideration of exemptions until the enforcement authority has proved its case.

More Review requests are turned down than accepted for a hearing and more of the second hearings are lost than allowed but in this the Chief Adjudicator carried out the Review. He picked up the lack of reasoning and thus this request looks like it came under the 'Interests of Justice' ground.

Having asked Redbridge Council to produce the Traffic Order and not been sent it, it is no surprise that the PCN was cancelled accordingly by the Chief Adjudicator.

If you take a mini-cab in Redbridge please ask your driver to spread the word around his driving mates.

The end (although Cranbrook Road is likely to appear again in the blog).

Waltham Forest make the same error as Westminster

Readers with better memories than Mr Mustard will recall he recently wrote about a timing error made by the City of Westminster in their own favour, here.

It is a common error, Mr Mustard expects to write about it at least once again in the future, and today it is Waltham Forest Council in his sights. Let's go back to early May when Bobby (not his real name) received his Notice to Owner which was dated 1 May. Always prompt Bobby sent a copy to Mr Mustard who at that time was up to date so he made the formal representations on 4 May. Representations made by Mr Mustard follow a common layout with the signed authority to act embedded as an image, so it doesn't get forgotten.

Time passed, as it does, and Mr Mustard kept an eye on the balance on line and it was £80 on 10, 17, 23 and 31 May.

An email landed in Mr Mustard's inbox on 31 May with an attached letter. Here is the relevant part.

Mr Mustard decided to play for time, predicting a cock-up. He sent a whatsapp message to Bobby.

Not long later, another emailed letter landed in his inbox.

 Mr Mustard again updated his client.

Following that letter Mr Mustard expected that the Notice of Rejection would shortly arrive. It didn't. The balance did change to £40 on 11 June rather suggesting that the representations had been rejected and the 50% discount offered again, even though it doesn't need to be and many authorities are now playing hardball and not offering it, and it stayed at £40 on 16, 20 and 29 June and on 9 July. 

On 11 July Bobby sent a copy of the Notice of Rejection dated 8 July. Mr Mustard smiled, he knew the Notice was a procedural impropriety as it was unlawful. He started an Appeal to the independent tribunal on 19 July.

The Notice to Owner is defined as the Enforcement Notice. Strictly the PCN was still alive but there were no legal steps which could be taken to enforce it as it was over 6 months old.

Mr Mustard waited for the expected 'DNC' document (Do Not Contest) and on 5 August it reached the tribunal. The council sensibly threw in the towel rather than fight on and risk an application for costs for unreasonable behaviour. It was unreasonable but Mr Mustard had hardly incurred any costs in starting the Appeal and only qualifies as a lay person for £19 per hour when his time is far more valuable.

So this is the second enforcement authority in a month to have broken the law. Many processes within parking are automated with PCNs moving relentlessly forward through a series of steps. The one which should be automated to stop a council from breaking the law isn't automated. This is because most motorists wouldn't know, wouldn't dream even, that a council would break the law. The second is that it is assumed councils will be honest and follow the law, maybe that was the case decades ago when PCNs were decriminalised, not now they are a £multi million enterprise. The third is that there is no sanction from an outside supervisory body for the simple reason that there isn't an all powerful overseer.

Mr Mustard will have to fulfil part of that role.

The end, for now.