Contravention code 94 · Off-street

PCN Code 94: Parked in a pay & display car park without clearly displaying two valid pay and display tickets when required

This is the official national contravention code printed on your notice. Here's what it means, and whether there's a common ground worth checking.

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Not a law firm. General information about the code itself, not legal advice about your case — upload your own notice for facts that actually apply to you.

What this code means

“Parked in a pay & display car park without clearly displaying two valid pay and display tickets when required”

Code 94 is an off-street car park contravention from London Councils' national PATROL contravention code list, the standard list used on council and TfL penalty notices across England and Wales, not just London.

Note: Off-street car parks.

Councils set two penalty bands, higher and lower, and this contravention is usually charged at the lower band — the exact amount still varies by authority, so check the figure printed on your own notice.

Is there a common way to challenge this?

Often argued as: The contravention did not occur

The alleged contravention simply didn't happen, either because you were legally entitled to be there, or because the signage/road markings were so inadequate that no valid restriction was actually communicated. Adjudicators treat inadequate signing as meaning no contravention arose at all, not as a separate, weaker ground, it stands or falls with this one.

This is a statutory ground (reg 5(4)(a), Civil Enforcement of Road Traffic Contraventions (Representations and Appeals) (England) Regulations 2022) — one of six specific grounds an independent adjudicator can allow an appeal on, not just something a council might choose to accept. Whether it actually applies to you depends on your own facts and evidence, not the code alone.

Check your notice and pick your ground

Other off-street codes

Code 95

Parked in a parking place for a purpose other than that designated

Code 96

Parked with engine running where prohibited

Code 70

Parked in a loading place or bay during restricted hours without loading

Code 71

Parked in an electric vehicles' charging place during restricted hours without charging

Not sure which code applies to you? See the full list.

Official source for this code

London Councils' national PCN Contravention Code List (PATROL), the standard reference used on penalty notices across England and Wales.

Last reviewed: 30 August 2026

GOV.UK PATROL

OverturnFine is an independent document-preparation service. It is not a law firm and does not provide legal advice, and it is not affiliated with any council, TfL, or UK government body.

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