Question Author
Thanks, New Judge.
The problem is that these are decriminalised offences, so courts do not get involved - you address your appeal to DVLA (or the issuing council for parking fines) and they decide whether to accept it or not.
In fact, there doesn't appear to be any way of challenging their decisions, in court or otherwise, so they are allowed to be the judge of reasonableness. As they openly state in their fine notices that you cannot rely on the postal service to fulfil your obligation to notify them of the change, I don't think they would be receptive to an appeal on that basis, whatever its legal merits!
As I said before, it's not affecting anything current as these are past cases - it just annoys me that they are allowed to act in this way. It seems to bypass due process by not allowing independent review of individual cases, not to mention the fact that it pretty much says: "we don't care if you are actually responsible for the offence or not, we just want the money", and the real culprit gets away scott-free! It just doesn't send the right message out.
Anyway, I'm ranting, but thanks again for taking the time to reply!