Thanks for the advice. One of the two grounds, I remember (please bear in mind that this information is erased after you submit the appeal form) was that the officer "failed to exercise their discretion" to waive the penalty. I suppose they can use this discretion if there is no facility to buy a ticket at the boarding station. The other ground was equally narrow - that the passenger was not liable to pay for some reason or other, perhaps. The penalty appeal system reminds me of schools appeals. In principle, it's purely administrative, you just fill in the form, and getting a lawyer involved gives you no advantage. In practice, a lawyer hardly ever loses a school appeal, whereas the unassisted parent loses 50% of the time. I take your point that if the rail appeal form is defective, this can become grounds for further appeal. There was no reference at all, on the form, to the relevant legislation or to any supplementary guidance.