Decision for Hampshire Group Southern Ltd (OH2079468)
Written decision of the Traffic Commissioner in the West of England for Hampshire Group Southern Ltd (previously called JCT Group Holdings Ltd)
IN THE WESTERN TRAFFIC AREA
IN THE MATTER OF:
HAMPSHIRE GROUP SOUTHERN LTD – OH2079468 (PREVIOUSLY CALLED JCT GROUP HOLDINGS LTD)
BEFORE THE TRAFFIC COMMISSIONER MR M DORRINGTON
PUBLIC INQUIRY ON 03 JUNE 2026 AT THE OFFICE OF THE TRAFFIC COMMISSIONER IN BRISTOL
WRITTEN DECISIONS
SUMMARY OF DECISIONS MADE
The restricted goods vehicle operator’s licence authorising two vehicles and zero trailers is revoked under sections 26(1)(f) and 26(1)(h) [operator is no longer fit] of the Act. Revocation will take effect at 2345 hours on 02 August 2026.
I propose to disqualify the sole director, Mrs Vicky Steere, from holding or obtaining any type of operator’s licence in any capacity and in any traffic area for a period of two years effective from 2345 hours on 02 August 2026 under sections 28(1), 28(3) and 28(4) of the Act. If Mrs Steere wants to request a hearing so that she can seek to persuade me that such a disqualification order should not be made, or only made in a modified form, then she must formally write to the Office of the Traffic Commissioner in Bristol to request such a hearing. If such a hearing is requested then she will be expected to attend in person and no virtual attendance will be permitted. If such a written request is not received at the Office of the Traffic Commissioner in Bristol by 1400 hours on Monday 13 July 2026 then this order of disqualification will come into force at 2345 hours on 02 August 2026.
I propose to disqualify Hampshire Group Southern Ltd from holding or obtaining any type of operator’s licence in any capacity and in any traffic area for a period of two years effective from 2345 hours on 02 August 2026 under sections 28(1), (3) and (4) of the Act. If Mrs V Steere (today still the sole director at Companies House) wants to request a hearing so that she can seek to persuade me that such a disqualification order should not be made, or only made in a modified form, then she must formally write to the Office of the Traffic Commissioner in Bristol to request such a hearing. If such a hearing is requested then she, as the sole director, will be expected to attend in person and no virtual attendance will be permitted. If such a written request is not received at the Office of the Traffic Commissioner in Bristol by 1400 hours on Monday 13 July 2026 then this order of disqualification will come into force at 2345 hours on 02 August 2026.
BACKGROUND
Hampshire Group Southern Ltd (previously called JCT Group Holdings Ltd before 13 April 2026) were granted a restricted goods vehicle operator licence authorising two vehicles and zero trailers at a public inquiry on 02 July 2025 before Deputy Traffic Commissioner Seculer.
The licence was granted subject to the following specific undertaking (a formal and binding promise) that was agreed to by the operator in the public inquiry:
“By 13/08/2025, a director will attend, in person, a one-day operator licence management course, run by either:
- a trade association (e.g. Logistics UK/ RHA/ BAR/ CPT);
- a professional body (e.g. IoTA/ CILT/ SOE/ IRTE);
- an approved examination centre offering the relevant transport manager CPC qualification for the type of licence held; or
- a firm of solicitors (or their associated training organisation) with significant experience with road transport regulatory and compliance issues (defined as having represented road transport operators and/or transport managers in at least 20 public inquiries over the past two years).
A copy of the certificate of attendance will be uploaded to the licence record via the Vehicle Operator Licensing self-service account within seven days of the course taking place. If the attendee does not have a self-service account, the certificate will be emailed to westernhc@otc.gov.uk within seven days of the course taking place.”
Due to this specific undertaking being breached a decision was made to call the operator to a public inquiry by letter dated 21 April 2026.
PUBLIC INQUIRY ON 03 JUNE 2026 AT 1400 HOURS
The sole director, Vicky Steere, did not attend the inquiry. Her husband, Mr Shaun Steere, attended. He had not brought a laptop with him so he was provided with one to use in the hearing. I adjourned for 15 minutes to allow him time to obtain a letter of consent from the sole director to be able to speak on behalf of the company and to bind the company. That letter was forthcoming and I then heard from Mr Steere in evidence including about the effect upon the business of regulatory action being taken against the licence.
EVIDENCE
The evidence in this case is that which is contained in the electronic case bundle on Case Center and the oral evidence I heard in the public inquiry.
ISSUES TO BE DETERMINED
The calling in letter (which also refers back to the propose to revoke letter) details (see page 7 of the bundle) the main issues:
- Whether the operator had failed to fulfill a licence undertaking
- Whether, since the licence was issued, there had been a material change in the circumstances of its holder, namely, failure to respond to correspondence and fitness of the operator to hold a licence.
Those are the issues that I will determine in this written decision.
BURDEN AND STANDARD OF PROOF
The burden of proof is upon Office of the Traffic Commissioner (“OTC”) to prove any allegations that have been made in the calling in letter and/or case summary. The standard of proof is the civil law test; the balance of probabilities. In other words what is more likely than not to have occurred.
FINDINGS OF FACT AND REASONS
I have made the following findings of fact after applying the correct burden and standard of proof to the evidence that is before me. For the avoidance of any doubt all of my findings of fact can be taken to start with the words “It is more likely than not that…”
The calling in letter, dated 21 April 2026, was sent to the last email and last postal correspondence address held on VOL. I am satisfied that it was delivered to the addresses to which it was sent because the operator submitted financial evidence in advance of the public inquiry. Without receiving and reading the calling in letter and accompanying Case Management Directions that evidence would not have been submitted. I am also satisfied, in accordance with the Upper Tribunal appeal cases of Philip Drake UKUT 2023 98 AAC and Ocean King UKUT 2024 592, that the operator was served with the calling in letter.
The calling in letter was sent to the operator 43 days before the public inquiry. The legislation only requires, for a restricted licence holder, 21 days notice to be given for a public inquiry. This operator has therefore had more than twice the minimum statutory notice period.
The chronology in this case is as follows:
04/09/25 VOL message sent to the operator requesting an update on the director completing the OLAT course
05/09/25 Operator stated that Shaun Steere had attended the course and that he would be added as a director. The Traffic Commissioner made it clear that the undertaking would be fulfilled if Shaun Steere was added as a director by 30 November 2025
03/12/25 Operator informed the Office of the Traffic Commissioner that Shaun Steere will not be added as a director and that Vicky Steere had been booked onto an OLAT course for 20/11/25
27/11/25 The Office of the Traffic Commissioner sent a VOL message asking for an update. No response was received.
29/12/25 Office of the Traffic Commissioner sends a letter and email to the operator stating that if nothing is received by 06/01/26 then the case will be referred to the Traffic Commissioner
13/01/26 Operator messaged to say another course was booked for 29/01/26 but no explanation was offered regarding the course previously booked for 20/11/25 and no extension was requested
20/01/26 The Office of the Traffic Commissioner sent a request explanation letter (“REL”) with three specific questions within it asking for a response within 21 days i.e. by 10/02/26 at the latest. That letter also stated within it “It is fundamental to the trust required to hold an Operator Licence that all correspondence from the Traffic Commissioner is responded to fully and promptly.”
13/02/26 A VOL message was received including a OLAT certificate for Vicky Steere dated 29 January 2026. The message did not respond to any of the three questions asked in the REL. To date those three questions have not been answered in correspondence.
23/02/26 A propose to revoke letter was sent to the operator
11/03/26 The operator emailed to request a public inquiry.
21/4/26 Calling in letter sent to all correspondence addresses held on VOL
02/06/26 As at the day before the public inquiry no maintenance and no traffic evidence had been received
03/06/26 Public inquiry at 1400 hours.
I heard from Mr Steere about what had happened regarding the above specific undertaking. He apologised on behalf of the company and said he had hoped to be a director sooner but becoming one was an ongoing issue with Companies House. As at today he is still not a director of this company.
The operator breached the specific undertaking given to the Deputy Traffic Commissioner. That was because the original deadline of 13 August 2025 was extended to 30 November 2025 but by that time and date no director had completed an OLAT course and (a) no request to extend that deadline had been made by the operator and (b) the Traffic Commissioner had not extended that deadline on his own volition. No cogent and persuasive reason for that breach has been provided before or at the public inquiry.
This breach of the specific undertaking given in a public inquiry is very serious misconduct. The Deputy Traffic Commissioner had clearly regarded the need for a director to complete the OLAT course as being vital in order to grant this operator’s licence so that a director had the required knowledge and understanding of operator licensing and as a result he expected a director to do that course. The breach of this specific undertaking also cuts to the very heart of the operator licensing system; trust. In the Transport Tribunal (as it was before the Upper Tribunal) appeal case of 2006/27 Fenlon it was held that:
‘trust is one of the foundation stones of operator licensing. Traffic, commissioners must be able to trust operators to comply with all the relevant laws, rules and regulations because it would be a physical and financial impossibility to police every aspect of the licensing system all day and every day. In addition, operators must be able to trust other operators to observe the relevant laws, rules and regulations. If trust between operators breaks down and some operators believe that others are obtaining an unfair commercial advantage by ignoring laws, rules or regulations then standards will inevitably slip and the public will suffer.”
The operator failed to co-operate with the Traffic Commissioner by (a) failing to fulfill the specific undertaking given in the public inquiry and also because (b) it failed to answer important correspondence sent from the Office of the Traffic Commissioner including the REL dated 20 January 2026.
The calling in letter requested, in the Case Management Directions, specific maintenance and specific traffic evidence to be sent to the Office of the Traffic Commissioner not less than 14 days before the hearing.
As at 02 June 2026 (the day before the public inquiry) none of that evidence had been received despite the operator being sent the calling in letter 43 days before the public inquiry. In other words to comply with the case management directions, that requested specific evidence to be provided 14 days before the public inquiry, the operator actually had 43-14 days = 29 days to comply but still failed to do so.
Before 7am on the day of the public inquiry an email was received by the caseworker from Vicky Steere to ask if she could upload that evidence to Case Center. That request was refused and she was told to attend the hearing and to bring the evidence with her.
She did not attend. In her place was her husband. He brought a small green file with him with documents in it. Those documents were passed to me. I read them and asked the Caseworker to upload them onto Case Center into a folder titled “Operator Evidence Submitted on the day of PI.”
Mr Steere had not brought any written authority with him to be able to speak on behalf of the company. In the inquiry I read out what it says on page 2 of the calling in letter:
“Who should attend
It is important that a board-level director of the company attends the public inquiry. If, exceptionally and with the prior written approval of the traffic commissioner, someone of below director level attends on behalf of the company, that person must bring written authority, signed by a director on company headed paper, stating that he/she has a right to speak and make binding decisions (including decisions which involve cost) on the company’s behalf.”
I adjourned for 15 minutes to allow time for Mr Steere to obtain the necessary written authority which was forthcoming.
I went through the documents I had received and those I had not by going through the Case Management Directions that attached to the calling in letter with Mr Steere. I have marked the evidence that had not been brought to the public inquiry next to the relevant part of the Case Management Direction quoted below:
“i. the original maintenance records for all vehicles for the last 3 months to
include at least:
• preventative maintenance inspection records including detailed brake
Test reports – Only one PMI for each vehicle was produced both dated 21 April. Only one roller road brake test was produced.
• driver daily defect reports; Only nil defect sheets were produced and they did not cover three months for each vehicle
• wheel removal/retorque records; Not produced
ii. the original maintenance contract(s); Not produced
iii. the Forward Planner (or photographic evidence thereof if large); Not produced
iv. evidence of your systems for managing drivers to include at least the following
for all drivers for the last 3 months:
• driver licence checks; Not produced
• driver infringement reports; Not produced
• vehicle unit download reports (sometimes called missing mileage
reports or unknown event reports); Not produced
• evidence of continuous professional development of relevant
managers/planners/supervisors; Not produced
• evidence of disciplinary action received by drivers and managers. Not produced
Mr Steere stated that he had had to scramble around to get what documents he could on the morning of the public inquiry in order to bring them to the public inquiry. I dismiss that explanation as to why only partial maintenance records were made available and why no traffic evidence was produced because (a) if Vicky Steere was asserting in her email to the caseworker on the morning of the public inquiry that she wanted to upload the evidence to Case Center then it is more likely than not that she had all of that evidence at hand to upload it (and therefore it should have all been available to Mr Steere) and (b) I dismiss this explanation from Mr Steere per se because the operator has had 43 days to prepare for the public inquiry and get the requested evidence to the Office of the Traffic Commissioner or, as an absolute last resort, bring it to the public inquiry.
In relation to the production of traffic evidence, when requested, the general undertaking recorded on this operator’s licence (and indeed on every operator’s licence) states:
“The rules on drivers hours and tachographs are observed, proper records are kept and that these are made available on request” [emphasis added].
The request for that evidence was made in the Case Management Directions that attached to the calling in letter (quoted above). The operator was, as at the date of the public inquiry, in clear breach of this undertaking as absolutely no traffic evidence had been produced as at the date of the public inquiry.
In relation to the production of maintenance evidence the general undertaking recorded on this operator’s licence (and indeed on every operator’s licence) states:
“Records are kept (for at least 15 months) of all driver reports that record defects, and all safety inspection, routine maintenance and vehicle repair reports, and that these are made available on request” [emphasis added]
The request for that evidence was made in the Case Management Directions that attached to the calling in letter. The operator was, as at the date of the public inquiry, in clear breach of this undertaking as (a) no maintenance related evidence was received at least 14 days before the public inquiry and (b) only partial maintenance records were brought to the public inquiry.
I was unable to look at maintenance or traffic compliance in the public inquiry given the lack of evidence before me. I therefore decided, whilst I was in the hearing, to not make any determination on maintenance/traffic compliance and to limit the issues to be determined to those set out in paragraph 9 above. That is why I told Mr Steere, at the very end of the public inquiry, not to send in any further evidence after the public inquiry had finished.
Pulling everything together the operator breached a specific undertaking given to the Deputy Traffic Commissioner in a formal public inquiry, the operator failed to answer important correspondence from the Office of the Traffic Commissioner (the REL) and then failed to comply with the calling in letter and Case Management Directions that attached to that calling in letter and the operator breached the two general undertakings quoted in paragraphs 28 and 30 above.
The operator has, I find, failed to co-operate with the Office of the Traffic Commissioner and also with the (Deputy) Traffic Commissioner.
The operator cannot plead ignorance to what is required, notwithstanding it being obvious that it should co-operate with the Traffic Commissioner at all times. So held the Upper Tribunal in the appeal cases of MGM Haulage and Recycling Ltd 2012/030 and LA & Z Leonida TA ETS 2014/024.
In the appeal case of MGM Haulage and Recycling Ltd 2012/030 the Upper Tribunal held that all operators are deemed to know the advice and guidance that is in the public domain. Here that would include the Statutory Documents issued by the Senior Traffic Commissioner which have been in the public domain for over 15 years and are available on the Gov.UK website.
In the appeal case of LA & Z Leonida TA ETS 2014/024 the Upper Tribunal said:
“It does not matter whether an operator’s licence is held by an owner operator, a partnership or a limited company because in each case the person or persons responsible for managing the business bear the ultimate responsibility for ensuring that the road transport aspect of the business operates in compliance with the regulatory regime. That means they cannot plead ignorance or put the blame on the transport manager because they are required to have sufficient knowledge of the regulatory regime to ensure compliance in general and the proper performance of the transport manager’s duties in particular.”
That doctrine applies here; that when any type of operator’s licence is granted the operator is expected to have the required basic knowledge from the day of grant to ensure compliance with the regulatory regime. That is why all applicants for an operator’s licence sign a formal declaration on the GV79 application form to confirm that there will be compliance with all of the undertakings and conditions on the licence and that the laws relating to the driving and operation of vehicles used under the licence will be observed.
There were very limited positives in this case; the sole director had (late and in breach of the specific undertaking) completed an OLAT course, the operator apologized for that breach, the operator told me it wanted to be compliant going forward.
BALANCING EXERCISE
Negatives I have found in this case:
- Breach of the specific undertaking given to the Deputy Traffic Commissioner in a public inquiry. I attach very significant weight to this.
- Breach of the REL issued by the Office of the Traffic Commissioner on behalf of the Traffic Commissioner. I attach significant weight to this.
- Failure to comply with the maintenance related Case Management Directions. I attach significant weight to this.
- Failure to comply with the traffic Case Management directions. I attach significant weight to this.
- Breach of the maintenance general undertaking quoted in this written decision. I attach significant weight to this.
- Breach of the traffic general undertaking quoted in this written decision. I attach significant weight to this.
Positives I have found in this case:
- That the OLAT was completed by the sole director (albeit late and in breach of the specific undertaking). I attach moderate (meaningful) weight to this; she had agreed to this in a public inquiry and was therefore expected to complete the course.
- The operator’s apology given in the public inquiry. I attach moderate (meaningful) weight to this.
- The operator’s promises to be compliant going forward. I attach little weight to this. Promises are easily given but this operator has a proven history now of breaching its promises on multiple occasions.
Looking at the operator, as it appeared before me in the public inquiry, it is clear that the evidential weight that I have attached to the negative findings in this case significantly outweigh the evidential weight that I have given to the positives in this case and as a result the balance tips firmly in favour of the negative findings. Consideration of regulatory action is therefore required.
DECISIONS
This is an unusual case in that it centres around the operator’s failure to co-operate with the Office of the Traffic Commissioner and the (Deputy) Traffic Commissioner. It is not a typical maintenance or traffic case where I am dealing with evidence from the DVSA.
In reaching my decisions I have considered what the operator told me about the effect on its business were I to take regulatory action against the operator’s licence.
Any failure to co-operate with the Office of the Traffic Commissioner or the (Deputy) Traffic Commissioner is taken very seriously. Here it was not an isolated incident of this operator doing that, there is a clear timeline of proven incidents including the breach of a formal and binding promise made in a public inquiry. I am satisfied that DTC Secular would not have granted this licence if he thought the sole director would not comply with the entirely reasonable request to undertake an OLAT course by 13 August 2025.
I have repeated all of my findings in this case including the credit that I have given to the operator for the positive features that I have found. I have then asked myself the question posed in the Transport Tribunal (as it was then) appeal case of Priority Freight 2009/225; “How likely is it that this operator will, in future, operate in compliance with the operator’s licensing regime?”. From all of my findings in this case I answer that question firmly in the negative. I have absolutely no confidence or trust in this operator being compliant in the future. At repeated touch points with the Office of the Traffic Commissioner, (Deputy) Traffic Commissioner and in relation to this public inquiry this operator has shown its clear, and true, colours; it cannot be trusted.
Having repeated all of my findings and having answered the Priority Freight question in the negative, it is now proportionate for me to determine that this operator is no longer fit to hold this restricted operator’s licence. That is a material change of circumstances from the operator previously being fit to hold this restricted operator’s licence. I therefore revoke this operator’s licence under section 26(1)(h) of the Act.
Having repeated all of my findings, including the credit that I have given to the operator for the positive features in this case, I have determined that it is also proportionate to revoke this operator’s licence for the breaches of the two general undertakings quoted at paragraphs 28 and 30 above. That revocation order is made under section 26(1)(f) of the Act.
All orders of revocation will take effect at 2345 hours on Sunday 02 August 2026. That time and date will not be changed. From that time and date this operator has no lawful authority to use any vehicle over 3,500kg for any commercial purpose on any public road. Were the operator to breach my orders of revocation then the DVSA are lawfully empowered, without any further warning, to impound any vehicle being used in contravention of my decision. The operator now has actual knowledge of that power. For that purpose the area DVSA manager will be sent a copy of this written decision.
CONSIDERATION OF DISQUALIFICATION – OPERATOR AND SOLE DIRECTOR
I repeat all of my findings in this case. This is a bad case on any reading of it.
The calling in letter made it clear that section 28 of the Act (the power to disqualify where a revocation decision is made) was available to the presiding Commissioner.
I have considered, again, the Transport Tribunal (as it was before the Upper Tribunal) appeal case of 2006/27 Fenlon where it was held that:
‘trust is one of the foundation stones of operator licensing. Traffic, commissioners must be able to trust operators to comply with all the relevant laws, rules and regulations because it would be a physical and financial impossibility to police every aspect of the licensing system all day and every day. In addition, operators must be able to trust other operators to observe the relevant laws, rules and regulations. If trust between operators breaks down and some operators believe that others are obtaining an unfair commercial advantage by ignoring laws, rules or regulations then standards will inevitably slip and the public will suffer.”
I have also considered the appeal cases on the subject of disqualification including 2018/072 St Mickalos Company Ltd & M Timinis and 2010/29 David Finch Haulage.
There does not have to be a special/unique feature for a Traffic Commissioner to consider using their power of disqualification.
The conduct of this operator, and in particular the failings of its sole director to co-operate with the (Deputy) Traffic Commissioner and the Office of the Traffic Commissioner, have led me to the unequivocal conclusion that I cannot trust either this operator nor its sole director Vicky Steere. The now proven evidence in this case speaks for itself. There is absolutely no place in this heavily regulated industry for an operator/director like this. This is one of those cases where I would fail in my regulatory function were I to step back from making an order of disqualification. Stepping back from making such an order would send out entirely the wrong message to compliant operators and to the public at large and doing so would fail to reflect the gravity of the negative findings in this case.
I therefore propose to make an order of disqualification under sections 28(1), 28(3) and 28(4) of the Act against the sole director Vicky Steere. Such an order would start at 2345 hours on 02 August 2026 and would last for 2 complete years until 2345 hours on 01 August 2028. It would mean that Vicky Steere could not hold or apply for, in any capacity, any type of operator’s licence in any traffic area. It would also mean she could not be director or a majority shareholder in a company that held, or applied for, any type of operator’s licence in any traffic area and it would further mean she could not be a director or majority shareholder in a subsidiary company to a company that held or applied for any type of operator’s licence in any traffic area.
Given that the sole director failed to attend the public inquiry, and out of fairness to her, I will give her the opportunity to make a written request for a formal hearing before myself if she wants to try and dissuade me from making an order of disqualification against her, or to persuade me to only make an order of disqualification in a modified form against her.
If such a written request is not received at the Office of the Traffic Commissioner in Bristol by 1400 hours on Monday 13 July 2026 then this order of disqualification will come into force at 2345 hours on 02 August 2026.
In relation to Hampshire Group Southern Ltd; I propose to make an order of disqualification under sections 28(1), 28(3) and 28(4) of the Act against the company. Such an order would start at 2345 hours on 02 August 2026 and would last for 2 complete years until 2345 hours on 01 August 2028. It would mean that Hampshire Group Southern Ltd could not hold or apply for any type of operator’s licence in any traffic area. It would also mean the company could not be a director or a majority shareholder in a company that held, or applied for, any type of operator’s licence in any traffic area and it would further mean the company could not be a director or majority shareholder in a subsidiary company to a company that held or applied for any type of operator’s licence in any traffic area.
If the sole director Vicky Steere (and she remains the sole director as at today at Companies House) wishes to try to dissuade me from making an order of disqualification, or to persuade me to only make an order of disqualification in modified form, then, as above, she must write to me to request a formal hearing. If such a written request is not received at the Office of the Traffic Commissioner in Bristol by 1400 hours on Monday 13 July 2026 then this order of disqualification will come into force at 2345 hours on 02 August 2026.
If such a hearing is requested then Vicky Steere is expected to attend in person and she will not be permitted to attend virtually.
If such a hearing is requested then I want to make it unequivocally clear, now, that the hearing will only be concerned with the issue of disqualification and will not be, in any way, concerned with my decisions to revoke this operator’s licence.
Traffic Commissioner Mr M Dorrington
25 June 2026.