Decision for Black Cat Travel Ltd (PF1146276)

Written decision of the Traffic Commissioner for the East of England for Black Cat Travel Ltd and Transport Manager, John Christopher James Edwards

From:: Traffic Commissioners for Great Britain
Published: 24 February 2026

Subject:: PSV operator and Transport manager
Region:: Eastern
Case type:: Regulatory
Regulatory decision:: Conditions imposed on licence, Licence curtailed or authorisation reduced and Loss of repute
Published:: 16 February 2026

IN THE EASTERN TRAFFIC AREA

BLACK CAT TRAVEL LTD – PF1146276

AND JOHN CHRISTOPHER JAMES EDWARDS – TRANSPORT MANAGER

TRAFFIC COMMISSIONER’S WRITTEN DECISION

On a finding that John Christopher James Edwards has failed to exercise effective and continuous management, he is prevented from relying on his Certificate of Professional Competence as Transport Manager for an indeterminate period pursuant to Schedule 3 of the Public Passenger Vehicles Act 1981. Accordingly, I record a loss of repute under section 17(1)(b).

As a result of that finding, I record a material change under sections 17(3)(e) and 17(1)(a) against the operator, Black Cat Travel Ltd. I have allowed a Period of Grace of 4 weeks to pursue the nomination of Iona Arlette Edwards nee Shore to fulfil that role and thereby meet the requirement of section 14ZA(2)(d) (see paragraph 84, below)

Following adverse findings under the following sections of the Public Passenger Vehicles Act 1981: 17(3)(a) – failure to meet statements relating to inspection intervals, that the nominated Transport Manager would exercise effective and continuous management, and to comply with conditions on the licence, 17(3)(b) – condition to notify relevant changes in the ability to hold the licence most notably in respect of financial standing and the ability of the Transport Manager to meet the statutory duty, 17(3)(aa) – undertakings (vehicles to be kept fit and serviceable, effective driver defect reporting, complete maintenance records, drivers’ hours and tachographs), 17(3)(c) – Prohibition Notices, and on findings that there has been a material change under 17(3)(e), so that financial standing was not met for the current authority, I impose a condition restricting operations to a total of 3 vehicles from 23:45 on 21 February 2026.

Background

Black Cat Travel Ltd held a Standard National Public Service Vehicle Operator’s Licence authorising 15 vehicles (reduced to 10 vehicles on 19 December 2025). The Director is John Christopher James Edwards, who was also named as the Transport Manager at grant. The up-to-date printout from Companies House showed no change, despite the earlier suggestion that Mrs Edwards might be added as a Director. Immediately before the reconvened hearing, I was alerted to the fact that Iona Arlette Shore (Mrs Edwards) had been added to that record. There had been no prior notification via the VOL record. In the period allowed for written representations, I received notification that she had received sufficient shareholding to be registered as a Person of Significant Control. This is not currently reflected on the Companies House register.

There is one Operating Centre at Beeching House, Station Yard, Station Road, Harmston, Lincoln, LN5 9SU. Preventative Maintenance Inspections are said to be carried out in-house by Mr Edwards and Ady Rae (referred to as Roe in written representations) at 8-weekly intervals. There is evidence that whilst they are IRTEC qualified, they also drive. Additional contractors have been proposed (see below).

The licence was issued subject to restrictions on the operation of small vehicles, accepted at the time of application.

This licence was granted from 12 August 2016 and initially authorised 10 vehicles. A variation application requesting to increase the licence authorisation from 10 vehicles to 15 vehicles was granted on 25 June 2019, subject to undertakings for financial evidence and Mr Edwards to attend at a 2-day CPC refresher course. A subsequent application to increase the licence authorisation from 15 vehicles to 20 vehicles was granted on 29 June 2020.

The record indicated that the operator was required to attend a Preliminary Hearing on 28 February 2023 before Deputy Traffic Commissioner, Nick Denton, following a DVSA desk-based assessment, a follow-up maintenance investigation, and a statement from a DVSA Bus Operator Account Management (BOAM) Officer:

“I am broadly satisfied that the operator is now compliant with maintenance and roadworthiness requirements and that there is therefore no need for a public inquiry at present. The operator should ensure that the recent improvements are sustained and maintained for the rest of the life of the licence.

We discussed the issue of missing mileage of which there is a large amount. I was satisfied that this was largely accounted for by the fact that vehicles do work under both EU and GB domestic rules. The operator is retrofitting vehicles with digital tachographs so that all drivers can insert tachograph cards and record when driving is out of scope. This should largely eliminate the problem.

We also discussed the conclusions of the BOAM relating to the percentage of services running outside the 1 minute early to 5 minutes late window. I noted that there was a reasonable excuse for some of the non-compliant services and that, as the local services were predominantly new, I would allow more time for them to bed down. But I would expect any future BOAM report to find a significant improvement in the compliance rate.

The following undertaking has been added to the licence:

i) By 31 October 2023, the operator will submit evidence of financial standing (sufficient to support the number of vehicles on its licence) over the period 1 April to 30 September 2023.

I noted that the operator intends to reduce its authority from 20 to 15 vehicles before the end of April.”

The licence authorisation was reduced on 23 November 2023 to 15 vehicles (from 20). Correspondence was issued by my office in March 2024 regarding alcohol on football coaches. A no further action letter was issued in May 2024.

Hearing

The Public Inquiry was listed initially for 11 December 2025, in Tribunal Room 1 of the Office of the Traffic Commissioner in Cambridge. The operator was present in the form of Mr Edwards, Director and Transport Manager, accompanied by Ms Shore/Edwards, proposed Transport Manager, and represented by Eliot Willis, of NA Legal solicitors. Vehicle Examiner Alice Huckfiekd, and Traffic Examiner Leo McLaughlin, attended at the request of the operator to give evidence. However, Mr Edwards found himself unable to enter the tribunal room, demonstrating a violent anxiety reaction towards himself and members of tribunal. For the reasons set out below, I was anxious to ensure the safety of operations, underpinned by available finance. It took considerable time before I could open the Public Inquiry and even then, the operator and Transport Manager were only present through their advocate. Mr Edwards declined to attend in open session and only appeared for the preliminary determination of finance.

On 13 November 2025, the operator requested an adjournment citing insufficient time to instruct legal representation and for that legal representative to prepare for the hearing. However, the Public Inquiry call up letters were issued on 30 October 2025 by email and post. The link to the brief was also issued on 30 October 2025, providing the operator and Transport Manager with 6 weeks advance notice of the hearing. The operator first accessed the bundle on 31 October 2025. Whilst the Transport Manager’s letter was returned by Royal Mail marked “RTS not at this address,” the operator had requested the hearing (see below) and was therefore alive to the issues. In refusing that application, my colleague Mr Denton noted that the DVSA Examiners had raised serious concerns and that the operator and Transport Manager were fully on notice.

Following consideration of the financial position, in private session, I adjourned to 13 January 2026. The hearing reconvened in Court 4 of Cambridge Magistrates’ Court. I am grateful to the staff of HM Courts and Tribunal staff for facilitating that appropriate accommodation. Further to correspondence from Mr Willis acknowledging the pressures placed on the tribunal on the first occasion.

Simon Newman of NA Legal solicitors appeared to represent the operator at the substantive hearing. On Mr Newman’s application, I delayed making my decision by 7 days in order for Mr Newman to specifically investigate the allegation made by Mr Edwards during his evidence that Mr Willis had advised him not to fully comply with the Case Management Directions (see below). Representations were received at 2 minutes before the deadline on 20 January 2026. They failed to address the point raised by the solicitor. My office replied immediately and allowed Mr Newman until 10am on 21 January 2026 to confirm why his client did not comply with the Case Management Directions. I extended the Period of Grace, accordingly (see below). An email at 9:40 am asked me to extend that to 12 noon, which I allowed. To be clear, as per the Upper Tribunal in 2021/018 Egertons Recovery Group Ltd, the granting of a Period of Grace does not amount to a decision “not to revoke” but allows the operator additional time.

Issues

The public inquiry was called at the request of the operators and following notice (1 October 2025) that I was considering grounds to intervene in respect of this licence and specifically by reference to the following sections of the Public Passenger Vehicles Act 1981:

17(3)(a) – statements relating to inspection intervals, that the nominated Transport Manager would exercise effective and continuous management, and to comply with conditions on the licence.
17(3)(b) – condition to notify relevant changes by implication above.
17(3)(aa) – undertakings (vehicles to be kept fit and serviceable, effective driver defect reporting, complete maintenance records, drivers’ hours, and tachographs)
17(3)(c) – Prohibition Notices.
17(3)(e) – material change:
17(1)(a) – repute, financial standing, professional competence.
28 – Disqualification.

Mr Edwards was also called to consider whether he had exercised effective and continuous management and therefore whether I should make a finding under section 17(1)(b) preventing him from relying on his Certificate of Professional Competence.

On 22 July 2025, an application was submitted nominating Iona Edwards as an additional internal TM. She proposes to work 4 hours per day Monday to Friday. Her Certificate of Professional Competence was seen at page 311.

The operator was directed to lodge evidence in support with maintenance and other compliance documentation to be with DVSA for analysis by 20 November 2025 and the remaining financial and other representations to be with my office by 27 November 2025.

Following the attempt to vacate the hearing date, an email dated 9 December 2025 (2 days before the hearing) confirmed that the operator had received the update reports based on the material it had supplied to DVSA. It indicated that its advocate had only gained access to the bundle on the “last evening.” That email referred to the Traffic Examiner’s report and the suggestion that evidence had not been supplied and attempted to argue that Mr Mclaughlin acknowledgement of receipt was equivalent to acceptance. It was not. Mr Willis was advised that the submission of evidence beyond the deadline would need to be addressed during the hearing.

I made clear to Mr Willis that any procedural arguments should be raised during the hearing. The call up letter dated 30 October 2025 states:

“Additional participants, such as legal representatives and transport consultants may be provided with access to the bundle on receipt of a written request from the party called to the hearing. The request must include the full name, email address, and role of the additional participant.”

Accordingly, Mr Willis was reminded that, whilst formal notification of his involvement was dated 28 November 2025, for some reason it was not lodged with my office until 8 December 2025. This appeared to be at odds with the earlier concern that he might not have sufficient preparation time. That was acknowledged in Mr Willis’s email of 10 December 2025. For some reason, it was thought appropriate to repeat that claim in documents submitted out of tribunal hours the night before the first hearing. The tribunal office advised that any further evidence would need to be paginated and with a paper copy. The operator again chose to ignore those Directions.

Further assistance was provided to the operator under cover of an email dated 4 December 2025 in which my office drew attention to the assessment of the financial evidence submitted, suggesting that the average did not meet the prescribed sum. The operator was specifically directed to the published guidance. Representations of 14 November 2025 had appeared to accept that financial standing could not be met.

The initial evidence of available finance: [REDACTED] was not sufficient to meet the prescribed sum.

I am legally required to have regard to the Senior Traffic Commissioner’s Statutory Guidance on Finance, and paragraph 18 summarises the legal position by reference to appellate decisions in 2011/036 LWB Ltd and the stay decision in 2014/065 Trevor Kevin Dibnah (which also explains the important purpose of the mandatory and continuing requirement):

“Financial resources must be at the disposal of or within the reach of the operator so if the operator must first ask someone else to transfer the money, then it is not available. The Upper Tribunal has drawn a distinction between funds that are actually available to ensure the establishment and proper administration of the business to those financial resources that are technically available. Examples of actually available money, where the only decision the operator has to take is whether or not to spend the money, include: a credit balance in a bank account, the unused portion of an overdraft or the unused credit limit on a credit card. The Upper Tribunal contrasted this to a lump sum payable from a pension which whilst technically available, in that once the required age was reached at which the operator could require the pension provider to pay it, it was not actually available because it could only be spent once the operator had taken the decision to require the pension provider to pay it.”

In 2012/017 NCF Leicester Ltd, the Upper Tribunal referred to the legal purpose for the mandatory requirement and by reference to the Recitals of Regulation (EC) 1071/2009 now retained. Faced with the absence of even tangible evidence to support a Period of Grace, Mr Willis encouraged me to use the approach described in 2012/005 AND Haulage. I deemed that necessary to provide a measure of protection to the public in cases where it appears, on paper, “that there are real concerns as to road safety”. I recorded that material change under section 17(3)(e). Taking account of the contractual obligations, I proposed to suspend the licence from 23:45 on 20 December 2025 until tangible evidence was produced to support a Period Of Grace (to an authority of 1 or more vehicles) of the reconvened hearing on 13 January 2026, whichever is sooner. The operator was able to refer to a closing balance before any suspension would come into effect.

A variation application was lodged on 27 December 2025 requesting to reduce authority to 8 vehicles. The updated financial calculation showed an average which would meet the prescribed sum for 3 vehicles only. I referred again to the Upper Tribunal in NCF Leicester and noted that the onus was now on the operator. At the reconvened hearing on 13 January 2025, some 10+ weeks from the call up on 30 October 2025, the average was only sufficient to meet the prescribed sum for 3 vehicles.

Summary of Evidence

“DVSA investigation – Maintenance”

An unannounced visit was made to the operator on 4 June 2025; the operator was unable to provide any maintenance records or driver defect reports but assured the Examiner that they would be sent electronically before 6 June 2025. However, only 1 record was provided as of 9 June 2025. On 10 June 2025, the Examiner returned to conduct her visit, which was marked as ‘unsatisfactory’. The main areas of concern were as follows:

The operator was apparently reluctant to provide any maintenance records, suggesting to the Examiner that they were not in order. The Examiner apparently informed the operator that she was willing to put the documents in order herself, but Mr Edwards still refused to supply the records. The Examiner noted a file labelled ‘PMI 2024’ and requested to see them. Mr Edwards handed her each sheet separately and completed parts of the sheet in front of her, which included the signing of the roadworthiness declaration. No records were produced for 2025.
Those records seen showed items missing from the inspection including an absence of recorded brake tests (44%), no tyre pressures recorded, missing defect rectification details and frequent omission of the declaration of roadworthiness. Of the 27 records produced, 6 showed extended inspection intervals where other inspections were only 1-2 weeks, suggesting an ineffective planning system.
Mr Edwards suggested to the Examiner that he often recorded inspection details as notes on his phone and then transferred the information to the paper record. He gave this as the reason for needing time to get the records in order.
The forward planning system did not include maintenance inspections. There was no VOR records kept with the Preventative Maintenance Inspection record or on a separate log. Mr Edwards suggested that VOR vehicles were recorded on the forward planning system. However, at the time of the visit, there were 6 vehicles with VOR signs which were not recorded on the forward planner. Vehicle B19 BCT was said to be under repair from 10 to 27 March 2025 but the driver defect records show it being used at least 3 times during this period, covering 1090 km.
The operator informed the examiner that he uses a recall check system every 6 months but there is no documented evidence.
The operator was aware of the PSV incident reporting system as he had used it previously for a wheel loss.
No driver defect reports were produced for 2025, when asked. Driver reports were produced electronically after the visit. The Examiner noted that drivers appeared to be reporting defects, but there were several occasions of vehicles being used with repeated defects, e.g. J111 BCT had an inoperative rear destination board, it was reported multiple times over 14 months, before it was repaired.
There was an emissions tester on site, but it was not in use. Mr Edwards suggested that emissions tests were carried out externally, but no evidence was produced other than those at annual test. Mr Edwards claimed that Adblue percentages were monitored on driver defect reports, but this was not reflected on any of the records produced.
Drivers visually check wheel nuts and pointer caps. If wheels are removed, red tags are left on the nuts until they have been re-torqued. The Examiner found that, where wheel torques were documented, there were no dates or mileage readings recorded and noted multiple job cards showing where wheels had been removed with no re-torque recorded. The operator did not record tyre ages.
The majority of the PSVAR training records were blank.
An ‘S’ marked prohibition was issued on 3 June 2025 for braking system air build up excessively slow and anti-lock brake warning light indicating a fault. The driver stated that the operator was aware of the defect but had allowed the vehicle on the road. The driver defect reports for this vehicle showed that ABS warning light and brake failure were reported 17 times over 12 months. A prohibition was issued to vehicle GO03 BCT on 9 August 2024 for exterior body panel damaged - bodywork damage was reported 13 times by drivers from 2 March 2024 onwards.

The Examiner was aware that a Desk-based assessment had been conducted by DVSA in 2022 where compliance was marked as unsatisfactory. Advice was given with regard to ensuring tyre details are complete on maintenance records, that a measured brake performance test should be conducted at each inspection, and the operator told the examiner that VOR sheets were placed in the vehicle inspection file. Those remained as issues at the current maintenance investigation. The Transport Manager was also the Director and a driver. Although he was reported as being friendly, he refused to provide maintenance documents for 2025. The documents that were provided were incomplete and disorganised. The first iteration of the visit report was emailed to the operator on 18 August 2025. No reply was received so DVSA sent a chaser on 3 September 2025, to which the operator did reply. He explained that he had been on holiday since 8 August 2025 and had only returned that day. He indicated that he would look at the report and reply once he had worked through his backlog but did not consider 7 days to be long enough and commented that 12 weeks had passed since the inspection. As of 11 September 2025, there had been no reply.

“DVSA investigation - Drivers’ Hours management”

The Traffic Examiner visit was originally due on 4 June 2025. A proposed visit on 20 June 2025 was cancelled due to sickness amongst the operator’s driving staff (also see below). The visit was conducted on 27 June 2025 and again, compliance was marked as unsatisfactory. The main areas of concern were:
- Mr Edwards suggested that driving licence checks were only conducted every 6 months but at the visit on 27 June 2025, the June checks had not been completed. - There did not appear to be routine checks of records and downloaded data. Mrs Edwards informed the examiner that 2 office staff had left in 2024, and she was working through the records for the previous months records to get up to date. As a result, driver infringements had not been produced with a reasonable time frame. - Tachomaster was used to record Working Time. Again, infringements were not raised within a reasonable timeframe.

The Examiner concluded that Mr Edwards was kept very busy running the business, splitting his time between the office, the workshop and driving tasks. This resulted in him being unable to fully focus his attention effectively on his Transport Manager duties. Whilst basic systems were said to be present, they were not regularly monitored.

The operator did respond to the Traffic Examiner, suggesting that licence checks would now be carried out at 3-monthly intervals, downloading of vehicles was carried out on a regular basis and that driver cards were downloaded weekly but by the office staff. The backlog of analysis and infringements letters had now cleared and that there would be no recurrence. Mr Edwards was booked to attend a two-day Transport Manager refresher course, starting on 27 October 2025. A part-time member of staff was being trained on tachograph analysis and infringements and a new Transport Manager, Mrs Iona Edwards, would be added to the licence.

Notice dated 1 October 2025 was sent expressing concern on my behalf and putting the operator on notice of the potential consequences for this licence and the Transport Manager and requesting a response by 15 October 2025 and 19 October 2025, respectively. I refer to the financial information supplied, above.

In summary, Mr Edwards disagreed with the prohibitions issued by the Vehicle Examiner at the visit and alleged that the Examiner was confrontational, ‘almost to a point of shouting’ when requesting the documents on her return visit. He indicated that he was left physically shaken by the experience. He referred to a meeting with DVSA line management where it was apparently agreed that the report was written in a negative tone (and the good aspects should also be recorded), that one of the prohibitions should not have been issued and that they would look into the other prohibition. There was some suggestion that the Examiner had not asked the correct questions and that she has chosen to misconstrue the responses.

The letter suggested that Mr Edwards and his wife had been considering the downsizing of the company for some time with a plan to reduce the vehicle authorisation to 10, when it could be achieved. The operator had already given notice to Lincolnshire County Council to terminate six school contracts and therefore plan to reduce the vehicle authorisation to 7-10 discs by January 2026. It was said that the reduction would help to achieve financial standing. The goods licence (OF2037713) had already been surrendered and the current fleet on this licence had started to be reduced.

Mr Edwards referred to Preventative Maintenance Inspection paperwork now being up to date, with a new garage administrator being appointed. Vehicle defect reports were no longer kept in the workshop, and new Preventative Maintenance Inspection job cards had been introduced. He was still working on a new Preventative Maintenance Inspection pro-forma. His wife had started an application to become the Transport Manager, which would allow a fresh set of eyes and Mr Edwards to dedicate more of his time to the workshop and vehicle maintenance. A full review of the company handbook has commenced. He acknowledged that more time was required to address the shortcomings.

“Mrs Edwards’s proposals”

I was directed to a booking form for the Lloyd Morgan Group to conduct an audit on 17 and 18 February 2026 and 3-Day Vehicle Inspection Course (Optional IRTEC) 16 to 19 February 2026 but described as a Vehicle Inspection Course Candidate Booking for 17 and 18 February 2026, in the index. I saw various documents relating to how Mrs Edwards will be engaged and how she proposes to carry out those duties. That is supported by a new Company Handbook. I noted its presence rather than the content as much relies on the position of the Transport Manager.

As part of the application to add Mrs Edwards (Shore), she confirmed she would devote 20 hours per week to those duties, with no other employment declared. She qualified in January 2024. She is not currently specified on any other licence and there appeared to be no previous history recorded against her. Mr Edwards confirmed that the nomination was intended to allow a fresh set of eyes which would allow him to dedicate his time to the workshop and vehicle maintenance.

Plans were further developed in the representations of Mrs Edwards at pages 312 to 316 where she described how she might exercise effective and continuous management of the transport operation. This is the more challenging as drivers do not have set work patterns (24/7 operation) meaning that any driver can be on site at one time. She referred to the change in staff, following which she took a Tachomaster course for downloading charts, units, and digital tachos, to allow her to start processing. She then decided it would be beneficial to expand her knowledge and took her CPC Transport Manager Course in November 2023. She compared the operations with those of larger operators. It is planned for Mr Edwards to move to the garage full-time, as his primary job. They already have a weekly meeting to go through the maintenance records, as well as plans for the coming week. The operator is planning to reduce the number of older vehicles, which then will reduce cost and pressures on sourcing parts. She also referred to new pro-forma and monitoring including whole-year planning. Colour coding will be used to monitor VOR and when annual tests are due. Mr Edwards’s presence will provide two qualified fitters and two apprentices, for a minimum of seven vehicles.

I have attempted to summarise the improvements adopted by the operator and described by Mrs Edwards in her approach to the position of Transport Manager:

the vehicle recall spreadsheet has been modified to allow full transparency with what is being needed to be sent to different garages or dealerships, as well as planning properly by the garage side.
Daily walkarounds Checks - the operator will use the private hire booking system (PHCloud-provided by Roeville), as a driver reporting app from 1 January 2026 (with training over the Christmas period), to generate reports to Mrs Edwards and Mr Edwards in his new role as the engineer manager.
Additional maintenance providers: Volvo (Crossroads) - tacho centre/maintenance; TSUK Ltd – warranty providers; Alexander Dennis -warranty and full part providers via AD24 system; AB Automotive (local garage) - 16 seats and smaller 6; S and P Garages (local Mercedes dealer) - tacho centre.
Vehicle Emissions procedure is currently outsourced, but there are plans for in-house testing in 2026, and subject to newer vehicle.
Wheel removal and retorque policy now relies on a job card system which records the fitter who did the original work and who went back to it, as well as the mileage. The operator has adopted a set of red tags for the whole wheel, so that the drivers can also make a full visual check with the wheel nuts, if they are between torques.
Driver Licence checks are now undertaken every three months. Mrs Edwards is looking into Checkmaster (by Roadtech) to automatically link up with Tachomaster.
Roller Brake Testing on site, at every Preventative Maintenance Inspection (aiming to reduce to every 6 weeks) with local sites, which offer voluntary brake testing i.e. Roe Hire and Pedersens Contracting Services Ltd.
Site Security has been improved. There are further improvements being made to the surrounding property.
There is currently a mix of digital and analogue recording units and buses with no units in service. Digital units are being fitted with immediate effect. Digital downloads will be done once a week, primarily on a Monday morning. Mrs Edwards has investigated the DOT system, commencing January, which is also linked in with Roadtech and new service vehicles. There will be a period of transition.
Drivers’ records are downloaded once a week, primarily on a Monday, to match Vehicle Units. Charts are also handed in on a Monday. These are scanned and analysed immediately. Several drivers are on domestic hours only with the rest of the drivers on mixed duties (private hire and domestic). The reduction in fleet size will allow the operator to streamline onto either domestic or retained EU tachograph rules. Tachomaster also tracks the hours.
Mrs Edwards acknowledged the difficulty in producing infringements reports from analogue charts provided by the drivers after the 28 days but before the 42-day period, i.e. October infringements are not reported until December. Two of the service buses are scheduled to be fitted with digital tachograph units from 22 December 2025. Those will be operated in full service, resulting in a full fleet. This part of an ongoing process and will be supported by training.

The case was further complicated by Mr Edwards’s apparent departure from some of those proposals. The picture changed yet again, when Mrs Edwards was confirmed as a Director, immediately before the reconvened hearing. I therefore asked Mr Newman to confirm the position, in written submissions (see below)

“Response to Case Management Directions”

The operator only supplied the following: 4 x licence checks, dated 7 July 2025, for Mr Rowbottom, Mr Redfern, Mr Ireland & Mr Davis; 4 x licence checks dated 7 October 2025, for Mr Rowbottom, Mr Redfern, Mr Ireland, Mr Davis. 11 other drivers were identified from Vehicle Unit data, but not supplied: Mr John Edwards, Ms Iona Edwards, Ms Jasmine Bavin, Mr Marc Caffrey, Mr Adam Clayton, Mr Ryan-James Green, Mr Gary Johnson, Mr Jason Midgley, Mr Joshua Midgley, Mr Adrian Rae, Mr Christopher Sutcliffe.

The Traffic Examiner credited Mrs Edwards’s involvement with the disciplinary process: Joshua Midgley received a formal written warning notice dated 15 October 2025, for:
- Pulling your digital card out of the vehicle unit during his shift. - Not filling in defect cards for each vehicle you have been presented with to drive for each shift. - Incomplete or absent analogue charts, either not returned to the office or completed at all. - General conduct of completing paperwork, whether this is for the DVSA or the company, not being the standard that is required.

Mr Edwards issued a formal warning to Joshua Midgley dated 3 October 2025, for:

Passing a Red traffic light in Retford, whilst driving in service with passengers as reported by Nottinghamshire police. This followed with correction advice.
Speeding on Long Leas Road on 13 September 2025 in W111 BCT whilst in service, reported by Community Speed Watch.
Speeding in Bassingham on 23 September 2025 in GO23 BCT, reported by Community Speed Watch.

However, tachograph files, driver licence checks and driver infringement reports were not produced for Joshua Midgley.

I took account of the driver infringement reports for Robert Rowbottom. None of the infringement reports were complete as they either required to be signed and dated by driver or manager or both. The same applied to the reports for James Redfern, Simon Ireland, and Richard Davis. In summary - Driver licence checks appear to be conducted quarterly now, rather than annually / 6 monthly, from the limited number produced. Driver infringement reports are still not being actioned or signed promptly and completed correctly. Minimal improvement from June 2025 TEVR.

I accepted that WN73 CUG, GO23 BCT, GO03 BCT, Y666 BCT and J111 BCT are not fitted with tachographs, but I was entitled to expect that the equivalent records of domestic hours would be produced, particularly given the operator’s approach to the DVSA investigation. The operator was directed to supply all driver infringement reports for the last 3 months, but it only supplied infringement reports for Mr Rowbottom, Mr Redfern, Mr Ireland, Mr Davis. The operator was directed to supply all Vehicle Unit downloads/missing mileage reports for the last 6 months. It only supplied 4 x reports, for period 17 June to 18 November 2025.

“Updated DVSA evidence”

Mr Edwards’s response to the Examiners was sent to the tribunal the night before the first hearing. In it he again attempted to claim that everything requested had been supplied. Given the late service of representations and subsequent adjournment due to a lack of time, I requested DVSA Examiners to provide responses to the suggestions made on behalf of the operator.

The Vehicle Examiner, Ms Huckfield, set out her background, expertise, and the advice resource available to her, which she relied upon in certain respects during this investigation. The Vehicle Examiner answered Mr Edwards’s attempts to question the circumstances of 3 June 2025. Mr Edwards arrived at the check site after the Prohibition was issued. The ABS lamp was illuminated, indicating a fault. The Examiner asked the driver if he had carried out a walkaround check that day, he confirmed he had and that the ABS lamp was illuminated during his check, but “he” had told him to take the vehicle out anyway. The driver did not request to move the vehicle. Mr Edwards did not ask to move the vehicle. He stated that the issue was with one of the ABS wheel sensors that had a poor connection in the hub. This suggested that Mr Edwards was aware of the ABS fault and aware that moving the vehicle forwards would not cause the warning lamp to extinguish. The Examiner attended on 10 June 2025, to remove the prohibition. She carried out the air build-up checks, and the ABS lamp was not illuminated even whilst the air was depleted. The vehicle was not moved forward. Photographs taken at this time show the ABS lamp was not illuminated. Although discovered after the date of the prohibition, the ABS warning lamp was reported on driver defect reports and maintenance inspection reports 16 times, suggesting this was an ongoing issue. The ABS defect was mostly reported by one driver, who would be familiar with the vehicle and aware that the vehicle does not need to be moved to extinguish the ABS warning lamp.

Note 4 from the Categorisation of Defects, to which Mr Edwards averred, refers to the operation of the ABS warning system, where the vehicle may need to be moved in order to carry out the self-check a second time. The ABS warning lamp is a delayed prohibition defect. Having consulted with her line manager, discretion was exercised so as to issue an Inspection Notice as the ABS lamp may have been linked to the air build up defect. It was only realised after this reduction that the ABS lamp does not illuminate when the air is depleted. The Categorisation of Defects IM38 Note 2 states that for vehicles fitted with electronic braking systems (EBS) the modulators need to cycle at least once to signal correct ABS operation. The Examiner recalled asking a colleague to check for the sounds of the cycle and would not normally have issued the prohibition if they had cycled but fairly acknowledged that she could not recall doing so. Her line manager agreed that the immediate prohibition was correctly issued.

“Regarding the immediate prohibition for air build up, the Categorisation of Defects IM34 states” “Excessively slow, If the warning device fails to cease operating or gauge does not reach 3.1kg/sq. cm (45psi/3bar/310kPa) within 9 minutes for vehicle/trailer/semi trailer combinations (6 minutes for rigid vehicles and uncoupled tractor units) or 25cm to 30cm vacuum in 2 minutes (see notes 1, 2 and 3).” It does not stipulate which tank this applies to, only that the warning device must cease operating. The Vehicle Examiner waited 9 minutes after starting the engine and raised the revs of the engine for the last 3 minutes of this. Both the audible warning and the triangle ‘!STOP’ lamp did not cease operating. The dash showed a stop sign with a ‘!’ warning sign underneath, accompanied by the number 3. When switching to the gauge display, tank 3 showed the air level as less than halfway to the marker point for 5.5bar, meaning the air level was at less than 2.75. The photographs were taken during the second attempt to build the air. She confirmed that she carried out the air tank depletion and build up test a second time to ensure complete fairness.
The driver was aware that the stop warning sign was illuminated and said that he had been told by the operator to switch off the retarder to stop the audible warning. However, the stop sign, and tank 3 warning remained on the dash. The driver said he had been told by the operator that it was safe to drive the vehicle. The driver was aware of this defect, evidenced by the driver defect report dated 3 April 2025 and signed by the same driver as on the date of the prohibition. The driver report states, “Brake system failure came on dash” and “Air tank 3 low pressure coming up on dash intermittently”.

Mr Edwards suggested that “The prohibition itself is strongly contested and denied by myself and the technicians at Volvo Truck and Bus…”. Mr Edwards had 14 days to submit an appeal after the prohibition and details of appeal were provided on the rear of the prohibition paperwork. He failed to do and thereby accepted the Notice. Further, the Examiner visited Crossroads Truck and Bus who confirmed a number 3 tank gauge fault and pressure switch replacement on tank 3.

In the face of unfounded allegations against the professionalism of the Examiner and her employer, she found it necessary to explain how the encounter history is generated. As stated, an initial encounter report is taken from the previous 3 years before the operator visit. The second encounter report is taken from after the operator visit until the deadline for the pre-Public Inquiry documents. Power Bi reports include any DVSA encounters where the operator licence number is recorded and reports cannot be manipulated. Traffic encounters are included in the report from the Traffic Examiner and are separate from mechanical encounters. Even including traffic encounters, Power Bi showed 4 encounters, not 6. Only relevant encounters are included in the Power Bi reports, encounters to remove or vary prohibitions would not be included in the prohibition percentages. Annual test reports were provided with the same date ranges as encounter reports. Power Bi takes data from the HGV testing service for any vehicles specified on the operator licence. These reports cannot be manipulated. The late inspections percentage is calculated by the Excel proforma SIPCAT (Safety Inspection Period Calculator & Analysis Tool). This percentage is from the date of the first maintenance inspection report until the most recent maintenance inspection report provided by the operator. It was only having taken advice from Mr Newman at the second hearing, that Mr Edwards, via his solicitor, indicated that those allegations were not to be pursued. He also indicated that the Prohibition Notices were not appealed, meaning that the findings had been accepted. On that basis, Mr Newman suggested that the Examiners did not need to be called.

The inspection schedule example provided in the operator’s response differs from the forward planning example provided with the “Black Cat Travel Bundle”. This is shown on the next page. From the documents provided by the operator on 20 November 2025, the only evidence of VOR is on the recall check sheet. This sheet shows VOR for a certain month but does not specify how long within that month. For example, the vehicle may have been VOR for one week in July, but not the entire month. The Examiner gave advice during her visit to include reason for the VOR, date, and odometer readings when off and on the road and that the vehicle has been signed off as roadworthy.

Again, her evidence was based on the evidence provided by the operator. She referred to pages 3-4 of the Guide to Maintaining Roadworthiness, section 5.2: “A robust tyre management system is essential for any vehicle operator and should ensure:… that tyre age is recorded and monitored for the entire fleet on the tyre management system…” As observed on 3 June 2025, one of the tyres on B19 BCT was stamped 2016 and required to be monitored. As DOT codes are not stamped on both sidewalls of tyres, inspections can sometimes be the only time the DOT codes are visible. It was further explained that if wheel nut markers have moved, they should be reported immediately. If a wheel nut marker is missing it is not possible to determine movement. The operator did not provide any evidence of regular torque checks for wheel fixings.

Regarding the inspection 25 June 2025, the Examiner referred to no evidence of brake test as no roller brake test record was provided, and the braking assessment section of the inspection form was blank. She referred to the best practice set out in the Guide to Maintaining Roadworthiness. The seat belt, anti-roll bar bracket and driver’s seat defects were all marked as unserviceable by the inspector. For the anti-roll bar bracket the words “snapped” and “broken” are recorded by the inspector. This was recorded on two consecutive inspection records, which Mr Edwards signed off. During the visit, Mr Edwards was asked to explain the VOR system he had in place and that was relayed in MIVR question 4e). The Examiner was directed to the wall planner in the Operating Centre office, which was photographed. Despite being asked, no other evidence was produced. The only evidence of VOR for GO06 BCT was on the Preventative Maintenance Inspection record where 21 September 2025 was crossed out and annotated: “Return to service 6/11/25 after MOT”. ‘Possible’ use was offered as an explanation in the Pre-PI report. A Work order apparently showed date in as 22 September 2025 and the date out as 6 October 2025. The question at the bottom of the work order about return to service is circled ‘No.’ The Examiner noted a driver defect report dated 29 September 2025, within the period that the Preventative Maintenance Inspection and work order show the vehicle should not have been returned to service. Although the odometer reading is the same for start and finish, there appears to have been an attempt to put the vehicle into service and the odometer reading did not correlate with the Preventative Maintenance Inspection record. A tachograph mileage issue had been recorded by the driver.

The Guide to Maintaining Roadworthiness advises on roller brake testing up to 14-days before the safety inspection date. The brake test for GO13 BCT was carried out 11 days after the vehicle had been signed off as roadworthy. GO06 BCT records a roller brake test 32 days after the inspection. The Preventative Maintenance Inspection dated 17 June 2025, completed by J. Edwards, does indeed show ADV and “shields detached” however the Preventative Maintenance Inspection dated 9 August 2025, completed by A. Rae, shows a defect marked as unserviceable “both R/R shocker tops broken corroded.” The Examiner found the rectification details to be illegible at the time but accepted now that it stays “works planned.” The fuel access panel, wheel arch and drag link ball joint defects were all marked as unserviceable by the inspector. Mr Edwards suggested that “DDR from 22/7/25 will have the same ODO as the PMI/RTC from 26/8/25 as per the VOR record the vehicle was VOR through the summer holidays. It was noted on the PMI schedule as VOR…” but the vehicle was not marked as VOR on the forward planner in the bundle provided. The Examiner also accepted that there was a note against a driver report for GO13 BCT. B19 BCT Preventative Maintenance Inspection record for 6 October 2025 suggested a “road test” and “ok” in the temperature section. The previous Preventative Maintenance Inspection dated 24 June 2025 was blank with no roller brake test report, as with the inspection before that. The most recent evidenced, acceptable brake test was on 4 March 2025, 7 months after the last roller brake test for the vehicle.

The Examiner referred to the Case Management Directions and what should have been produced. Data was taken from Microsoft Power BI, but she was unable to comment on the driver defect reporting system, as she had not received any previous responses from the operator. The operator was aware that some vehicle inspections were longer than 8 weeks. The need to provide evidence of VOR to cover the overdue inspections should have been obvious. Evidence of VOR on the forward planning system that was provided in the operator’s response to the pre-PI report was not the same as the forward planning system evidence that was provided in “Black Cat Travel Bundle” upon which the SIPCAT and pre-PI report were based.

The updated annual test history for November and December 2025 – PRS 18 December 2025 for a defective speed limiter.

Traffic Examiner McLaughlin quite properly referred to the onus on the operator to supply the requested evidence and company with Case Management Directions. The late provision of that evidence did not assist or support the operator’s contentions (see below). Accordingly, Mr McLaughlin analysed the data which was produced. Mr Edwards supplied raw tachograph data files for vehicles GO13 BCT, B19 BCT, GO06 BCT & GO14 BCT but not for all the drivers of these vehicles; only Drivers Rowbottom, Redfern, Ireland, and Davis. Mr McLaughlin identified from the Vehicle unit for B19 BCT, that Mr Edwards drove for 42 minutes on Thursday 6 November 2025, with 4 minutes of other work, between card insertion at 15:16 hours to card withdrawal at 16:02 hours. Mr Edwards’s digital driver card raw data was not provided.

Like the tribunal, he was not able to identify in advance which vehicles are fitted with tachographs, but a record of missing mileage reports should have been kept for all vehicles on the operator’s licence. He expected to receive missing mileage reports or nil returns for all 13 specified vehicles. Only 4 x missing mileage reports were produced for vehicles GO13 BCT (71 km), B19 BCT (0 km), GO06 BCT (88 km) & GO14 BCT (81 km). Licence checks were only submitted for drivers Mr Rowbottom, Mr Redfern, Mr Ireland & Mr Davis dated July 2025 and October 2025.

He confirmed that his pre-hearing report identified that not a single infringement report was completed correctly, with each one either requiring to be signed and dated by driver or manager or both. Mr Edwards confirms in his response that: “Robert Rowbottom had one unsigned infringement.” That is correct as Mr Rowbottom’s particular infringement report was not completed correctly but, not a single other infringement report was completed correctly either. Drivers must carry 29 days of records (current day & previous 28 calendar days) but infringement reports evidence that there were long periods between the infringement date and acknowledgement of the infringements by driver and manager, resulting in delays to corrective or disciplinary action. Infringements can be actioned, more frequently whilst drivers still retain their charts for the 28-42 days he mentions. The Examiner’s report was restricted to the period required in the Case Management Directions. Reports for June and July fell outside that period. In addition, the Traffic Examiner was not supplied with all driver infringement reports for August to October. Mr Edwards’s representations suggested that October 2025 infringement reports had now been generated but failed to mention the schedule or give a reason for not producing October’s infringements. Mr Edwards may carry out digital downloads each week, but infringements are not actioned promptly. Analogue charts are not scanned at the same time but left for 28 to 42 days.

“Mr Edwards’s approach to the investigation and Public Inquiry”

The Examiners were requested to attend the Public Inquiry, based on Mr Edwards’s challenge to the DVSA evidence. He had made a series of serious allegations against the Examiners. Following advice from Mr Newman, he chose not to pursue those claims, and I was told that it was not necessary to call the Examiners.

Mr Edwards was then called to give evidence by Mr Newman. He contradicted some of the early suggestions made by Mrs Edwards and indicated his intention to remain as a Director. He acknowledged that his multiple roles had proved challenging, being spread across engineering, Transport Manager, planner, cleaner, “you name it.” He suggested that he would resign if Mrs Edwards were allowed to be appointed as the Transport Manager, so that he could concentrate on the maintenance side of the business but then went on to limit Mrs Edwards to overseeing drivers and paperwork, whilst he would retain responsibility for the garage and planning. He described how he had now been moved out the general office to one located in the workshop. He and Mrs Edwards had allocated time on a Monday to discuss any issues and the paperwork. This started only after the initial hearing and there had been teething issues regarding the flow of paperwork. Whilst the operations had been “slimmed down,” he had still driven for one works contract and one school run during the last week. Mrs Edwards had driven one school run in the last month. Mr Rae undertakes afternoon school runs.

Mr Edwards was asked to explain the contradictory correspondence received in December 2025 indicating that he was considering shutting the business. He had planned to sell the vehicles; some were sold already. He referred to the decision in September 2025 to serve notice on Lincolnshire County Council and to reduce its contracts. He had changed his mind and sought to reduce authority from 20 vehicles to 8, to allow the operator to provide registered local services and to meet the remaining Council contracts. He acknowledged that the operations had grown to meet the opportunities presented during the pandemic. The operator had recruited staff quickly, especially in the maintenance department, rising to a total of 12. It was suggested that the loss of key staff in 2024 might have contributed, but Mr Edwards then told me that people he had put in place the spread the load, had let him down. It did not occur to him that he might have been a cause of the issues. He indicated that the maintenance manager had departed in Christmas 2024 and that paperwork was in a terrible state, which he started to put right in January 2025. The current position leaves the operator with 1 fitter, Mr Rae, and Mr Edwards, after an apprentice was let go 2 weeks before. There remain a full-time cleaner and an office administrator who was responsible for tachographs and maintenance paperwork, with Mrs Edwards. With fewer other jobs, Mr Edwards would divert more time to the maintenance.

Mr Edwards referred to the workshop containing column lifts for single deck vehicles (not the new double-decker), a beam tester, and I saw photographs (4) of this and the roller brake test set in the ground outside, replacing previous mobile units and representing an investment by the operator. Preventative Maintenance Inspections are carried out in-house (as per the notification) but newer vehicles are under warranty. They had attended the 4-day IRTEC training referred to above, in addition to Advanced IRTEC training. Mr Edwards attended a 2-day CPC refresher course. In respect of the annual test failure rate, Mr Edwards again blamed someone else, in that case the test centre. I was told that the introduction of the new brake and beam testers had improved the chance of passing annual test. However, issues arose because of the cherished plates and tests had to be carried out by reference to the previous vehicle registration. The Examiners helpfully confirmed that this can be an issue. The operator needs to resolve this and was directed to the DVSA Director of Vehicle Services.

The Vehicle Examiner raised the absence of tyre pressure and tyre age from the records. The lack of pressures was attributed to having no fitter. There was no explanation for the lack of tyre age, it just did not happen, despite the well-publicised requirements of the Road Vehicles (instruction and Use)(amendment) Regulations 2020. Defects appeared to be conflated to fit on one job card and then closed. He acknowledged that this was a failure, potentially confusing and should have been put on separate cards. It was suggested that the driver defect reports had not operated in the same way. Mrs Edwards had investigated a new app, which will ensure that there is no longer a delay in reporting defects. Adblue has been ‘renamed’ on the defect record. There is no gauge on the tank. It was suggested that vehicles are given to external contractors in advance and emissions are addressed “if” there is any issue with smoking.

Tachograph data is downloaded every 1-2 weeks. The analogue charts are scanned in weekly but there are less of them There are two remaining analogue vehicles: 1 VOR and the other is the oldest vehicle, which the operator hopes to replace (finance permitting). I understood infringement reporting to therefore be limited to 2-month intervals. I was confused as to why Mr Edwards could not see the purpose of driver’s signing to acknowledge infringement reports. Whilst training records have now been updated and driver licence checks completed quarterly (by Mrs Edwards), the failure to implement those basic checks appears to illustrate the root cause of the operator’s problems. As with some many of the issues identified, Mr Edwards was aware of the DVSA guidance or had been previously advised but chose not to change the systems. He described it as complacency, but on my assessment, this appears to be a characteristic of Mr Edwards’s approach to compliance and to regulation. In essence, his approach was ‘I know I’s done it, so I didn’t need to write it down.’

Mr Edwards was asked to explain the attitude he had taken to the DVSA Examiners, best evidenced through his refusal to supply document, choosing instead to hand then one page at a time and after he had amended or altered them. He sought to give the impression that he valued the knowledge and advice of previous Examiners and that he appreciated the need for regulation and a level playing field. He described a change of Examiners as offering a fresh pair of eyes, but that was not reflected in his approach to this investigation. He accepted that Preventative Maintenance Inspection intervals had been exceeded. He also accepted that a VOR record was absent. That is now included on a spreadsheet to record relevant dates. He said that he had taken on board the Vehicle Examiner’s comments, but there were still no odometer readings.

He sought to explain away his behaviour towards Ms Huckfield, suggesting that he was a “literal person”, as if that might offer some explanation as to why he failed to provide the documents requested but frustrated her inquiries and then supplied some documents page by page. The real reason appeared to be that the records had not been completed. Preventative Maintenance Inspections had been conducted outside the covered workshop. Mr Edwards referred to his concerns about completing a piece of paper attached to a board so, with two inspectors, one person would make notes on an app. As was picked up in representations, he suggested this was an “OCD issue,” not wanting fingerprints and other damage to “his PMI records.” It did not occur to him that there was a better way and that has remained the case. The Preventative Maintenance Inspection or rectification record should have been completed from those notes. He acknowledged that the operator needed to change and to continue to monitor systems, so it did not end up in the same position, but he was unable to provide me with a satisfactory explanation as to why he had allowed it in the first place.

Despite indications to the contrary, I was presented with new evidence under cover of a letter from Mr Newman, dated 20 January 2026, in response to the suggestion of the Examiner that no vehicle records for documents were provided for 2025 and his refusal to supply the same. Mr Newman refers to a miscommunication or misunderstanding. I reject that suggestion. The Examiner was present and available to give evidence. She was not called following an indication from the operator, via Mr Newman, that this was not required. What I was provided with were copies of emails dated 10, 14, 16, 20, 21 June 2025 addressed to Ms Huckfield referring to job cards: GO03, W111, P111, GO14 BCT, P111 BCT, GO03 BCT, W111 BCT. The final email of 21 June 2025 at 18:07 states: “This I believe is the final information you requested. Sorry again about the delay, this week has Been a disaster for us with a quarter of our drivers being sick on the busiest week of the year.” It was suggested that I might put these emails to Ms Huckfield, but the face of the emails appeared to be sufficient and none of the attachments were included. I reminded myself that the Examiner attended on 4 June 2025 and of the approach adopted by Mr Edwards during that visit. I was also mindful of the failure to comply with Directions.

When I had asked why Mr Edwards had failed to fully comply with the Case Management Directions (so that I could have an up-to-date picture of compliance), he suggested that this was on the basis of legal advice. I cautioned Mr Edwards and explained that enjoyed legal professional privilege and suggested that he speak to Mr Newman. I was aware of an argument raised by Mr Willis previously regarding the supply of documents to a Traffic Examiner based on what might be commensurate to the number of records to be supplied to the Vehicle Examiner. That proved to be wholly unsustainable, in the face of the relevant Direction at page 15 of the bundle:

“At least 21 days prior to the hearing, the party must send to Leo McLaughlin of the Driver and Vehicle Standards Agency at (leo.mclaughlin@dvsa.gov.uk) the following documents required for the hearing. As an operator you are expected to have the following documents to evidence your compliance with the operator’s licence requirements: evidence of your systems for managing drivers to include at least the following for the last 5 months:

raw tachograph (ddd files) for vehicles GO13BCT, B19BCT, GO06BCT & GO14BCT and any relevant drivers of those vehicles for the same period;

driver licence checks carried out over the last six months;
driver infringement reports for the last three months;
vehicle unit download reports (sometimes called missing mileage reports or unknown event reports) for the last six months;
evidence of continuous professional development of relevant managers/planners/supervisors;
evidence of disciplinary action received by drivers and managers.”

On the conclusion of evidence, Mr Newman asked for additional time to clarify the position with Mr Willis and his client. I considered it only fair to the operator and Mr Edwards to allow that opportunity. That had to be extended again to midday on 21 January 2026, when I received the following, sent at 11:58 am

“I am setting out below comments from Mr Willis in relation to the response to the case management directions which may assist on this point :

It would not be appropriate to comment on the specific advice provided, as this is privileged. However, we believe it is still possible to address the issue respectfully in general terms.

It appears to us that the calling‑in letter limited the scope of evidence required. This is reflected in the fact that the evidence requested for the Vehicle Examiner was expressly restricted to four vehicles. Likewise, the case direction concerning evidence for the Traffic Examiner referred only to four vehicles. We note that the TE, in his Pre‑PI report, has stated that he intended this to mean all vehicles, but we respectfully observe that this is not what the calling‑in letter actually states.

Evidence was therefore submitted for the four vehicles identified. No request was made for evidence relating to all vehicles or all drivers. Our understanding is that, where an operator has a large fleet, it is standard practice for the calling‑in letter to specify a limited sample. In that spirit, the requested information was provided to DVSA.

In the covering email to the TE, we expressly invited him to raise any questions or request any further material, so that this could be supplied promptly. The relevant extract is below:

“From: Eliot Willis

Sent: 20 November 2025 19:08

To: REDACTED

Subject: Black Cat Travel Ltd: PI 11 December 2025

Hello Mr Mclaughlin,

We write to inform you that we represent Black Cat Travel Ltd.

Per the TCs case directions, please find attached a bundle of evidence/index; and .ddd files for VU and driver cards.

If you have questions about the evidence or require anything further please do not hesitate to ask. (underlining ours)

I would be grateful if you could kindly acknowledge receipt.”

Determination

This case was challenging to manage, not least in securing the attendance of the operator and Transport Manager and even more in establishing what was being pursued on the operator’s behalf. Based on the evidence summarised above and by reference to the required burden and level of proof, I am satisfied that I should make adverse findings under the following sections of the Act: 17(3)(a) – failure to meet statements relating to inspection intervals, that the nominated Transport Manager would exercise effective and continuous management, and to comply with conditions on the licence, 17(3)(b) – condition to notify relevant changes in the ability to hold the licence most notably in respect of financial standing and the ability of the Transport Manager to meet the statutory duty, 17(3)(aa) – undertakings (vehicles to be kept fit and serviceable, effective driver defect reporting, complete maintenance records, drivers’ hours and tachographs), 17(3)(c) – Prohibition Notices.

“Financial standing”

I refer to the establishment of a transport operation below, in respect of financial standing. The requirements of a licence are accepted at the point of application. Those who think it is incumbent on Traffic Commissioners to repeatedly remind individual operators of those responsibilities and the consequences if they fail, do not understand the regulatory regime, the relevant transport industry, or the nature of risk management (where other statutory duties apply).

The operator was on notice of the importance of financial standing from the previous Public Inquiry on 28 February 2023. There was no basis for a Period of Grace. The Upper Tribunal set out the relevant test in 2014/008 Duncan McKee “In our view, when considering whether or not to grant a period of grace, Traffic Commissioners will need some tangible evidence, beyond mere hope and aspiration, that granting a period of grace will be worthwhile, and that there are reasonable prospects for a good outcome. Some sort of analysis along these lines will be necessary because, amongst other reasons, Traffic Commissioners have to decide how long to grant. Moreover, as with a stay, there is no point in granting a period of grace if the likely effect is just to put off the evil day when regulatory action will have to be taken.” It must also have considered the position in advance of the Preliminary Hearing.

Representations suggested that the operator had now ring-fenced a sum [REDACTED] apparently received via a member of the family. There was no explanation as to why this was not made available before. I have previously referred to the Upper Tribunal in the leading case of 2012/017 NCF Leicester Ltd, which explains how vital financial standing is to the proper establishment of a compliant operator, which applies to all standard operators. Mr Newman invited me to extend my discretion by extending the Period of Grace to at least 21 March 2026 to show financial standing for 8 vehicles, even though the average showed financial standing for only 3. The test for grant of a Period of Grace was explained by the Upper Tribunal in 2014/008 Duncan McKee: “In our view, when considering whether or not to grant a period of grace, Traffic Commissioners will need some tangible evidence, beyond mere hope and aspiration, that granting a period of grace will be worthwhile, and that there are reasonable prospects for a good outcome. Some sort of analysis along these lines will be necessary because, amongst other reasons, Traffic Commissioners have to decide how long to grant. Moreover, as with a stay, there is no point in granting a period of grace if the likely effect is just to put off the evil day when regulatory action will have to be taken.” The closing balance was pointed to as providing tangible evidence, the remaining question, given all the circumstances of this case was whether there was any good outcome and whether I should grant this operator a further commercial advantage.

I picked up on the earlier references to staff being let go. It may be that the pressures on this business resulted in this position and the stresses demonstrated by Mr Edwards. It did not amount to effective oversight or continuous and effective management. At the very heart of the interaction lies the undertaking, a formal legal promise, that maintenance records would be properly completed, retained, and made available upon request. That underpins the promise to ensure that vehicles engaged in this type of work are kept fit and serviceable, for the safety of passengers and other road users. The 2025 records may have been in an embarrassing state, but that does not abdicate the responsibility to produce them.

Mrs Edwards suggested that regulatory intervention might wait to the end of December so that the operator might then reduce the fleet. I noted the attempt to delay the hearing of this case. Representations suggested the intention “to take back control and rebuild when things are more controlled.” That recognises that compliance and management had got away from the operator, and particularly Mr Edwards, since Mr Denton saw the operator at a Preliminary Hearing. She talked about streamlining the operation and using software and equipment to reduce labour time. The problems appear to have arisen because this is a small team and there has been a reluctance to tackle the weaknesses in the systems. From my assessment of the evidence and having had the benefit of seeing Mr Edwards given evidence, this is mainly attributable to him. It is laudable that Mrs Edwards was concerned for staff (‘hearts and minds’) but basic competence and accountability were lacking. Whilst Mrs Edwards appeared ready to grasp that and referred to a statement to staff about the new roles, the financial position was not such that I could satisfy myself about compliance going forward and Mr Edwards and final representations appeared to contradict the plan of action she offered.

For the sake of completeness, I have considered what, if any, impact the decision in Edinburgh Coach Lines [2025] UKUT 146 (AAC) might have. With respect to the Bench hearing that case, whilst the decision cites Atbus Ltd. [2019]UKUT 0032 (AAC). Bradley Fold Travel Ltd & Peter Wright –v- Secretary of State for Transport [2010] EWCA Civ 695. Bryan Haulage No 2 (2002/217). Crompton t/a David Crompton Haulage v Department of Transport North Western Traffic Area [2003] RTR 34. Ladd v. Marshall [1954] 1WLR 1489, it was not addressed in respect of the following case law, which goes beyond reference to the Recitals to explain the mandatory requirements. In 2021/018 Egertons Recovery Group Ltd the Upper Tribunal reminded operators “that in order to successfully apply for a standard operator’s licence, the operator shall satisfy the four requirements set out in Article 3(1) of the 2009 Regulation and s.13(A)(2) of the 1995 Act and a licence will not be granted unless the Traffic Commissioner is so satisfied. Section 27 provides that, if at any time it appears to a traffic commissioner that a licence holder no longer satisfies the requirements of s.13A(2) [in that case] the traffic commissioner “shall direct that a standard licence be revoked””. That is the proper application of the mandatory requirements described in section 14ZA of the 1981 Act. That was further explored in 2012/017 NCF Leicester Ltd, which explains how real assets might be considered. No evidence of ownership, independent valuation or how quickly them might be realised was produced.

Regardless, I was told that this operator introduced 3 new vehicles last year and gained the benefit of those new assets. I inevitably made adverse findings under section 17(3)(e) as a material change and section 27(1)(a) as from the evidence, financial standing for even 8 vehicles was not met. It was suggested that I might grant a further Period of Grace, allowing more time for the operator to collect the funds. I have referred to the McKee test above. Financial standing is not only a mandatory but a continuing requirement. I was told that it had a plan to replace the oldest coach in March 2026 and a service bus later in the year. I cannot see how financial standing for 8 vehicles will be maintained and that the ring-fenced funds would have to be used.

“Conduct at the Public Inquiry”

It was left to the tribunal staff to manage the situation before the first hearing and to try and deal with some of the aggression demonstrated by Mr Edwards in respect of other attendees and observers.

The pressures on our public services are well known. To ensure that funds generated through operator licence fees are used to best effect, the tribunal allocates time within busy diaries to allow for the preparation of cases. That requires parties to comply with Directions. The approach is not to treat operators as children but recognises the complicated nature of transport businesses. In giving undertakings, operators accept the basic obligations of an operator’s licence when the application is made. I am entitled to proceed on the basis that a competent operator should be able to supply its own documents, which should already have been monitored by the Transport Manager. There is nothing unfair in that process and, when it comes to this Public Inquiry, notice was given well in advance. The Directions ensure that all the factors contributing to a fair hearing are properly balanced and, in this case, were directed to the operator. It was not for DVSA to provide legal advice to the operator.

For the record I must express my deep concern at the suggested conduct. I have never encountered a suggestion from any member of a regulated legal profession that legal professional privilege belongs to that lawyer. Privilege is an absolute right, which belongs to the client. I gave Mr Edwards the opportunity to consult with Mr Newman before deciding on whether to waive that, but it is for the operator to decide whether it wishes to waive its protections, not for Mr Willis’s own purposes. It is clear that he was closely involved in the supply of those documents. His email to Mr McLaughlin did not relieve him of his professional obligations.

Traffic Commissioners are entitled to infer that a party has received proper legal advice from a legally qualified representative. Mr Newman asked that “no adverse finding is made against Mr Edwards or the Operator in relation to this issue regardless of whether or not this reasoning was correct.” Any conflict of interest may ultimately be a matter for the professional regulatory authority to consider. At no point did Mr Willis alert me to the fact that he had advised his client, Mr Edwards. As the Solicitors’ Regulatory Authority states: “A solicitor is first and foremost an officer of the court. A solicitor’s duty to the court may override other duties or principles, such as the duty (reflected in Principle 7) to act in a client’s best interests. The preamble to the Principles provides that: “Should the Principles come into conflict, those which safeguard the wider public interest (such as the rule of law, and public confidence in a trustworthy solicitors’ profession and a safe and effective market for regulated legal services) take precedence over an individual client’s interests”” I also referred to the Senior Traffic Commissioner’s Statutory Document No. 9, in which: “Advocates are reminded of their professional duties not only to their client but also to the tribunal. It is particularly important for representatives to be alive to any potential conflict of interest. A legal representative of an employer is under a professional obligation to communicate any relevant information. If they were to attempt to also represent an employee there is a risk of a conflict of interest. If a conflict were to arise in that situation it would be difficult to envisage the representatives being able to continue to act for either party.” Whilst it is the individual representative’s responsibility to ensure that they meet the outcomes of their regulating body’s rules and guidance, the reason that they are permitted to appear as of right is because they are regulated to carry out those reserved legal activities. Where they act outside those requirements then Traffic Commissioners may be entitled to employ additional measures to ensure the continued fairness of proceedings.

Whilst the Senior Traffic Commissioner advises that there may be occasions where an operator should not be blamed for acting on legal advice, the Upper Tribunal recently provided useful indication as to the competency which Traffic Commissioners are entitled to expect from advocates in its decision in Pro-Drainage Ltd & Others [2025] UKUT 397(AAC). Whilst the application is limited on appeal, I have felt it necessary to take that into account when reaching my determination, below. The conduct in advance of the substantive hearing should be a matter of professional concern.

Mr Newman accepted that there were grounds to consider action under section 17(2). I was reminded that Mr Edwards obtained his CPC qualification in April 2010 and undertook refresher training in 2019, with a further two-day refresher course in October 2025 (just before the call up letter). It was suggested that the identified positive might also count towards his performance as transport manager. That fails to appreciate that it was his responsibility to exercise effective and continuous management of the transport operation so as to prevent those shortcomings. He was an unimpressive witness. He was unable to explain why he took a different course even when aware of DVSA guidance to the contrary. As per my judicial training and the Equal Treatment Benchbook, judges are expected to be alert to any behavioural indicators which might arise during proceedings. Mr Edwards described himself as “literal”. No representations were raised beyond acknowledging his behaviour at the first hearing. Based on the evidence above and his responses to me at the hearing I am satisfied that Mr Edwards knew that his approach was not acceptable.

“Transport Manager”

This case is fundamentally about trust, which underpins the licensing the regime. Mr Edwards’s attempts to question the honesty of a public official without evidence were yet further evidence of his inability to cope under challenge. It was only on legal advice from Mr Newman that he decided not to pursue these suggestions. In 2014/050 Andrew Harris trading as Harris of Leicester: “Given the importance attached to operators complying with the regulatory regime and given that transport managers must: “effectively and continuously manage the transport activities of an undertaking holding an operator’s licence”, it seems to us that whether or not an individual has the character, personality, ability and leadership qualities to ensure compliant operation as an operator or to effectively and continuously manage the transport activities as a transport manager is a factor which can, properly, be taken into account when assessing good repute.” His actions did not amount to effective management. His approach to when his processes were questioned could be categorised as: ‘he knew best’. That gave me real concern as to his future management. The fact that he continues to drive passengers may be of concern to those relying on this operation. Given the concerns emanating from Mr Edwards’s outbursts at the first hearing, this should be referred via the Driver and Vehicle Licensing Authority to consider whether those medical issues prevent him from driving. A copy of this decision will be publicly available.

The findings are so serious as to justify an adverse finding under section 17(1)(b). ln the end I concluded that Mr Edwards is just temperamentally unsuited to the role of Transport Manager and should therefore be disqualified from relying on his Certificate of Professional Competence. Given the basis of those findings, it is difficult to contemplate a suitable rehabilitative measure to restore his CPC. I have therefore avoided determining the period of disqualification, leaving it open to him to apply after expiry of the minimum period to vary that disqualification, if the presiding Commissioner can be satisfied that he is then capable of meeting the statutory duty.

I proceeded to make an adverse decision against the operator in respect of professional competence under section 17(1)(a). There was an application to add Mrs Edwards but as an additional Transport Manager. That application must now be reconsidered as she will need to satisfy me as to how she intends to exercise effective and continuous management alone and with Mr Edwards as a Director, as suggested would be the case during evidence. The nomination of Mrs Edwards allowed me to grant a Period of Grace of 4 weeks from the date of this decision to satisfy this requirement (or risk the revocation of the licence).

“Balancing Exercise”

I am satisfied that the identified issues cannot simply be attributed to having run out of resource. I noted the previous history. Less than 2.5 years later, Mr Edwards was found to be uncooperative, controlling the provision of records and altering those for 2024 records during the visit. There were no records produced for 2025 at the maintenance visit. Those produced showed inadequate brake testing, exceeding inspection intervals. The lack of planning appeared to contradict the operator’s excuses. I was concerned at the information suggesting B19 BCT was used whilst under repair in March 2025 but have taken account of the responses set out above. There was a similar absence of driver defect reports but even where present they failed to record/ensure rectification. The failure to complete records cannot be blamed on a lack of qualification. An emissions tester was present but not used. There was an absence of wheel security, and a lack of PSVAR training. The Traffic Examiner reported a failure in licence checks, lapses in downloads. WTD management was apparently non-existent.

I was told that the operator had recognised that the size of its operation has been a problem and from return from holiday in September 2025, had sought to reduce the size of the business and fleet, but contracts ran until 31 December 2025. The operator had recognised its inability to also operate goods vehicles. It was suggested that the concentration will make the business more manageable and thereby compliant. In my assessment of those involved, that will largely depend on who is in charge. Mr Edwards had already attended refresher training, so his approach to the Inquiry was all the more concerning. It called into question exactly what Mr Edwards is committed to achieving. I was referred to adjustments to procedures and processes, but a good work ethic does not amount to compliance. I was directed to the facilities and arrangements for maintaining the vehicles. There has been investment in that facility. The operator acknowledged that mistakes had been made and that the situation was unsatisfactory. For the reasons set out above, Mr Edwards was less clear about his part in that.

Previous and written representations attempted to categorise the concerns and remedial action, as follows:

inspections extended because the vehicles were off road for extended periods (e.g. school contract from July to early September). VOR system now includes the reason for a vehicle being off road but has yet to show exact dates and odometer readings. It was the operator’s practice to generally inspect vehicles coming back into service. Mr Edwards now records the reasons referred to an extract.
unsatisfactory annual test and prohibition rates, influenced by issues relating to private vehicle numbers. Mr Edwards recognised that there must be improvement.
Driver defect reporting described as “daily” re-designed following the DVSA investigation. Job cards are made up for remedial work following a defect report. New app now forwards defects to Mrs Edwards in the office.
Following the maintenance investigation, Mr Edwards designed a new form of job card specifically for works done following an inspection. No reason was given as to why there could not be a proper endorsement of the Preventative Maintenance Inspection record.
Wheel torque procedures also use the workshop job card. Tyre pressure and tread depth is now properly recorded on Preventative Maintenance Inspection records.
All Preventative Maintenance Inspection records are now signed off by the relevant inspector, Mr Roe or Mr Edwards, with Mr Edwards as the supervisor.
The Vehicle Examiner commented on the use of a mobile phone to make a record of findings at Preventative Maintenance Inspection and that has not changed, even when challenged about the need to retain records.
The decision to complete Preventative Maintenance Inspection in front of the Examiner was termed “misguided.” They were incomplete. He saw little wrong with that. It was suggested that the substantive parts were complete, but Mr Edwards attempted to dictate the Examiner’s access to the records.
Mr Edwards sought to concentrate on the annual test failure following a recent engine change and deposits in the particulate filter, rather than acknowledge a lack of Adblue management, which only followed DVSA intervention.
The Examiner herself identified the downgrade of the Notice on 3 June 2025. Representations then sought to argue against national averages rather than the requirements of the operator’s licence.
Mr Edwards repeatedly argued that 6-month driver licence checks were acceptable and had to be told otherwise at the Public Inquiry.
The operator termed the failure to issue infringement reports as a backlog, which was addressed by October 2025, but Mr Edwards did not accept or see the need for them to be counter-signed by the driver to acknowledge receipt and to prevent recurrence. It has become necessary for Mrs Edwards to assume those responsibilities.
Drivers had been permitted to hold on to analogue charts for up to 42 days without analysis. This has only now changed pending the removal of all analogue vehicles.

In doing so and for some of the reasons I have observed above, this risked the impression that the operator was seeking to minimise the seriousness of its position.

In 2023/082 Arnold Transport Ltd, the Upper Tribunal explained that operator licensing is based on trust. Since it is impossible to police every operator and every vehicle (at all times), the Traffic Commissioner must feel able to trust operators to comply with all relevant parts of the operator’s licensing regime. In addition, other operators must be able to trust their competitors to comply, otherwise they will no longer compete on a level playing field. So, “grant of an operator’s licence does not mean that an operator can then proceed on the basis that the requirements that must be met in order to obtain a licence can thereafter be disregarded….Unfair competition is against the public interest because it encourages operators to cut corners in order to remain in business”. Where actions doubt on whether they can be trusted to comply with the regulatory regime they are likely to be called to a Public Inquiry at which their fitness to hold an operator’s licence will be called into question. “The attitude of an operator when something goes wrong can be very instructive. Some recognise the problem at once and take immediate and effective steps to put matters right. Others only recognise the problem when it is set out in a call-up letter and begin to put matters right in the period before the Public Inquiry takes place. A third group leave it even later and come to the Public Inquiry with promises of action in the future. A fourth group bury their heads in the sand and wait to be told what to do during the Public Inquiry. It will be for the Head of the TRU to assess the position on the facts of each individual case. However, it seems clear that prompt and effective action is likely to be given greater weight than untested promises to put matters right in the future.”

This operator was slow to react. Even after the Preliminary Hearing, the operator attracted roadworthiness Prohibition Notices with defects including a missing speed limiter plate, braking system air build up excessively slow, illuminated ABS light, fuel leakage, exterior body panel damaged and likely to cause injury and oil leakage dripping on to the road surface. Traffic Examiner roadside encounters recorded failures to keep records of other work, failures to use a tachograph record sheet or driver card, insufficient weekly rest, exceeding 4.5hrs driving and failure to notify a change of address. The initial fail rate at annual test history for the period immediately following the Preliminary Hearing to 27 October 2025 was 23%. This increased to 31.82% for the last 12 months. The operator should have been on notice of the need to act and was given every opportunity to do so following Mr Denton’s consideration. The operator should have been up to the task.

I have recorded the remedial steps which were taken by the time of the second hearing. The changing nature of representations and the failure to act promptly on previous interventions and advice, meant that my trust in the operator has been severely tested. I attribute that in the main to Mr Edwards. After considering the facts of this case, I am unable to understand the basis it was suggested that I approach this case as falling within the ‘Moderate’ bracket. After going through the positive and negative evidence, the facts speak for themselves. An undertaking to produce finance was offered, but the operator also sought a Period of Grace. As above, having given multiple opportunities, I did not find that it particularly likely to succeed or even attractive. It was also suggested that I might allow yet further time to develop compliance procedures and another 6 months to show it was compliant through an audit. If the operator had taken the opportunities already offered it, the Public Inquiry would not have been necessary.

The findings against Mr Edwards clearly went to my determination of the operator’s repute. As stated in Arnold Transport, Director fitness is an essential element. Mr Newman’s written representations indicated that “It was not necessarily envisaged that Mrs Edwards would become the sole director” but that was the impression left by her earlier correspondence. Mr Newman indicated that “if it were necessary to maintain the licence, he would promptly resign as a director but otherwise the Operator would prefer for both Mr and Mrs Edwards to be joint directors.” I proceeded to make my decision on the facts as I found them, with Mr Edwards remaining as a Director (only). I was assured by Mrs Edwards that if she could not work with Mr Edwards, they “would call it quits at work.” They share the same goals but those have been put at risk by that same reluctance to stop and consider compliance, and to involve the regulator. In closing, Mr Edwards acknowledged: “I know that I’ve made mistakes and I considered just stopping but after long days talking with my wife and family, there’s too much blood, sweat and tears gone in to give it up.” Mrs Edwards indicated that she was ready to step up and take responsibility.

I turned to the question posed by the appellate tribunal in 2009/225 Priority Freight namely: how likely is it that the operator will comply in future. Clearly, if presented with a situation where Mr Edwards in sole charge, there would be limited hope for this operator. It was suggested that any curtailment below 8 vehicles would leave the operator unable to fulfil its contractual obligations but that would have no material impact on the plans for future operation. Mr Newman suggested this might be the purposive approach but that ignores appeal cases such as 2014/008 Duncan McKee and Mary McKee and 2006/277 Fenlon, which explain that Traffic Commissioners must be able to trust operators to comply with all the relevant laws, rules, and regulations and the impact on road safety as a whole where that fails. That involves looking at the funds available to support compliance. It is a physical and financial impossibility to police every aspect of the licensing system all day and every day. It was suggested that Mr and Mrs Edwards were hugely embarrassed and disappointed to find themselves at Public Inquiry. I did not share Mr Newman’s optimism as the likelihood of compliance over these matters. However, this is where I felt obliged to take account of apparently poor advice and to explore whether I might draw back from revocation based on the promise of immediate action by Mrs Edwards. I did so only on the basis that she is able to meet the requirements to be appointed as Transport Manager (yet to be determined, as above) and on her indication that she can ensure compliance whilst Mr Edwards remains in the business. The operator should understand how closely it came to loss of this licence. It should consider this its last chance to comply and that its repute hangs by the thinnest of threads.

“Impact of intervention”

Mr Edwards gave evidence as to the impact of potential regulatory evidence: revocation would mean that contracts could not be met and mean that the business would have to cease. I was told that any suspension beyond a month would result in the same outcome due to the cost of covering contractual obligation. No actuarial evidence was produced in support. It was acknowledged that financial standing was only present to the prescribed sum for 3 vehicles. The potential for regulatory action had not proved sufficient deterrence and the reasons for this Public Inquiry proved to be entirely justified.

“Direction”

I was mindful that this would impact on the transport of school pupils, but I am also required to consider the impact on road safety and the jurisdiction as a whole. In Dundee Plant Company Ltd [2013] UKUT 0525 (AAC), the Upper Tribunal stated that, as a matter of law, a suspension (and by implication curtailment etc) is very different from a revocation. As the Upper Tribunal explained, “it provides a glimmer of hope, and a means to return to operation with a known and established authorisation and operating centre - without the need to make a fresh application. It provides a chance for a new leaf to be turned over if the suspension can be survived. And it is, of course, not possible to disqualify an operator or a director if an operator’s licence is merely suspended….we see no difficulty in the traffic commissioner concluding, in principle, that the right thing to do is to draw back from the ultimate sanction and, instead, impose (in that case) a 12-week suspension. In any event, we consider that it would be a very retrograde step to discourage traffic commissioners from taking tough regulatory action (but falling short of revocation) if, after conducting a balancing exercise, it appears right to do so where a very clear marker is needed. We hold this view even if there is a possibility that the consequence will be to put the business in peril. In an appropriate case (which this is) a traffic commissioner is entitled to say: “I hope you survive but if not – so be it. On these particular facts, the public interest in maintaining the integrity of the system demands nothing less than a lengthy suspension.””

For all the reasons explained above, I find this to be one of those cases and accordingly impose a condition, in effect curtailing the licence to 3 vehicles to match the evidence of financial standing. I have taken account of the half-term dates for Lincolnshire and that condition will take effect at 23:45 on 21 February 2026.

R Turfitt

Traffic Commissioner

27 January 2026

Published 24 February 2026

Contents

Decision for Black Cat Travel Ltd (PF1146276)

IN THE EASTERN TRAFFIC AREA

BLACK CAT TRAVEL LTD – PF1146276

AND JOHN CHRISTOPHER JAMES EDWARDS – TRANSPORT MANAGER

TRAFFIC COMMISSIONER’S WRITTEN DECISION

Background

Hearing

Issues

Summary of Evidence

Determination

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Decision for Black Cat Travel Ltd (PF1146276)

IN THE EASTERN TRAFFIC AREA

BLACK CAT TRAVEL LTD – PF1146276

AND JOHN CHRISTOPHER JAMES EDWARDS – TRANSPORT MANAGER

TRAFFIC COMMISSIONER’S WRITTEN DECISION

Background

Hearing

Issues

Summary of Evidence

Determination

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