Decision for Odyssey Journeys Ltd (PC2058042)
Written decision of the Traffic Commissioner for the North West for Odyssey Journeys Ltd and transport manager, Mohammad Lambat.
IN THE NORTH WEST TRAFFIC AREA
ODYSSEY JOURNEYS LTD - PC2058042
WRITTEN DECISION OF THE TRAFFIC COMMISSIONER
PUBLIC INQUIRY HELD IN GOLBORNE ON 11 NOVEMBER 2025
DECISION:
Under provision of Section 17(1)(a) and 17(3)(e) of the Public Passenger Vehicles Act 1981 (“the 1981 Act”), Operator’s licence PC2058042, held in the name Odyssey Journeys, is revoked with immediate effect.
Under provision of Section 28(1) of the Transport Act 1985, Odyssey Journeys Ltd, and Director Mr. Mohammad Lambat are each disqualified from holding or obtaining an Operator’s licence for an indefinite period of time.
I make a finding that Mr. Mohammad Lambat has lost his good repute as transport manager. Mr. Lambat is disqualified from acting in such capacity for any road transport undertaking for an indefinite period under provision of Schedule 3 (7B)(1) & (2), of the 1981 Act.
Odyssey Journeys Ltd holds a Standard International PSV Operator’s licence, authorising six vehicles. The Directors are Mr. Mohammad Lambat and Mr. Abdul Suleman Malji. Mr. Lambat is also the nominated Transport Manager. It is noted that Mr. Malji is recently appointed as a Director (May 2025) and has not yet been added to the VOL record. The licence was granted on 20 August 2022 and, until the issues below were uncovered, there is no known previous compliance history for the Operator.
Background
Odyssey Journeys Ltd came to the attention of the Office of the Traffic Commissioner (OTC) following receipt of an email from Lancashire County Council following a compliance check they had conducted at a school on 30 October 2024. The notification raised significant concerns regarding the driver, Mr Omar El Aidi, and the state of the vehicle. The driver was unable to produce his driver licence or Driver CPC to the Council at that time. It is alleged that the Operator subsequently provided the Council with records for a different driver, and when the Council followed this up, the records for Mr. Aidi showed that he did not have the required licence entitlement for the vehicle he was driving.
Due to the above the DVSA were requested to undertake a full investigation of the Operator’s maintenance, drivers’ hours, and their systems to ensure the Operator was complying with the laws relating to the driving and operation of vehicles. The OTC were then advised that the DVSA investigation could not be conducted as the Operator had stated that it stopped operating in February 2025 due to poor business. That statement suggests that there has been a material change - in that the licence is no longer being used - and that there has been a change in the financial position of the company - as business has been poor to the point that operations have ceased. Both these changes are required to be notified to the Traffic Commissioner as per the Conditions of the Operator licence. No such notice has been received.
The issues raised by the Council, and the inability of the DVSA to conclude otherwise, are such that it raises concerns as to whether the undertakings of the licence are being complied with - namely the requirement to have proper arrangements so that (i) the laws relating to the driving and operation of vehicles used under the licence are observed and (ii) vehicles, including hired vehicles, are kept in a fit and serviceable condition and (iii) records are kept (for 15 months) of all safety inspections, routine maintenance and repairs to vehicles, and made available on request.
The combination of these issues is such that it further brings into question whether the Operator can be considered to be of the required good repute, and whether the Transport Manager, Mr. Lambat, is of the required good repute. Any adverse finding against Mr. Lambat as Transport Manager would subsequently impact the Operator’s ability to satisfy the professional competence requirement.
It has also been noted that no vehicles have been specified on the licence, and the Operator claims not to be operating, therefore there is reasonable cause to believe that the licence holder no longer satisfies the establishment criteria to have access to a proportionate number of vehicles.
Letters were issued to the Operator on 08 August 2025 proposing to revoke the Operator’s licence and company Director, Mr. Lambat, responded to state that they were seeking investment. Finances were also provided which showed that the licence holding entity does not have sufficient funds to meet the financial standing criteria. This change in financial position was not previously notified to the OTC as required under the conditions of the licence. Whilst the letter did not specifically request a Public Inquiry it did ask that consideration be given to the licence being allowed to continue. Accordingly, I directed that matters be considered at a Public Inquiry.
Pre-Public Inquiry
Separate notices calling the Operator and Transport Manager to the Inquiry were issued on 30 September 2025, by both post and email, to the given addresses. Those letters set out the date, time and location of the Hearing and included case management directions to be complied with ahead of the Inquiry.
The Public Inquiry call-up letter also confirmed that the Hearing would give consideration to the variation application received 15 July 2025 to add Mr Abdul Suleman Malji to the licence as Director. Consideration was also to be given to the variation application received 08 August 2025 to add Hamza Mohammed Ayaz as an additional Transport Manager.
The case management directions included the requirement to notify this office of the list of attendees, to provide updated financial evidence in support of the financial standing criteria, to provide evidence of systems for complying with undertakings by way of original maintenance records, and to provide any other evidence the Operator wished to rely upon. These materials were to be received at my office not later than 14 days before the Hearing. Those case management directions were not complied with.
Mr. Lambat was also been called to this Public Inquiry in his capacity as Transport Manager, to establish whether they have ensured compliance with the conditions and undertakings of the licence and whether they have continuously and effectively managed transport operations.
Public Inquiry
The applicant failed to attend the Public Inquiry. I first gave consideration as to whether the Hearing should proceed. I took account of the guidance issued by the Senior Traffic Commissioner at paragraph 27 of Statutory Document 9, which states
“The Traffic Commissioner is entitled to expect that the party called to a Hearing will submit any application for an adjournment.”
I am advised that the calling-in letters were posted to the given correspondence addresses and emailed to the given address for electronic communications. It is a well-established principle that an Operator is required to provide the Traffic Commissioner with an address at which communications can be received and dealt with. Evidence from the Post Office confirms that both calling-in letters (Operator and Transport Manager) were delivered on 01 October 2025 and each were signed for by “Lambat”. I conclude, therefore, that good service of the calling-in letters has been made.
I give consideration as to whether there would be merit in adjourning the Hearing and offering an alternative date to the applicant. I am mindful, however, of the expense and efforts already afforded in setting up this Inquiry, the fact that another Operator has been unable to use this slot – for example, to consider an alternative application – and that my Hearing Room is currently booked up until late January 2026 therefore any adjournment would not be brief.
I conclude that good service has been made, that it is not in the best interests of the public or the regulated industry to adjourn, and therefore I proceed with the Hearing and make a decision based upon the best available evidence before me.
Consideration
“Section 14ZA(2)(b) – Good Repute”
The allegations from the Council (set out above) are provided alongside two witness statements. The issues raised are of grave concern and go to the very heart of road safety and fair competition. The Operator then failed to engage with the DVSA investigation and, in its response to the letter proposing to revoke the licence, failed to address the concerns raised.
The failure to attend this Public Inquiry is a further failure to allow those serious concerns to be addressed. I conclude that the reason the Operator and Transport Manager are refusing to address the issues is because the allegations were accurate. I am extremely concerned by the allegation that the Operator provided records for a different driver when first requested.
I am also mindful that the discovery that this Operator was no longer trading and no longer satisfied financial standing requirements came about from OTC inquiries. It is a condition of an Operator’s licence that these matters are notified to this office within 28 days of their occurrence. The Operator failed to comply with the conditions of its licence in this regard.
A further significant issue is the failure to have proper systems to receive and respond to important communication from this office, such as the calling-in letter. Finally, I have regard to the failure to attend this Public Inquiry. Trust is a fundamental requirement of the licensing regime, and this Operator’s shortcomings, and failure to attend this Inquiry and be held accountable for those shortcomings, has created a significant absence of trust.
“Section 14ZA(2)(c) – Financial Standing”
The Propose to Revoke letter set out that I was concerned that the requirement to have appropriate financial standing was no longer complied with. The Operator responded to state that sufficient finances were held, and provided bank statements from 01 January 2025 to 31 July 2025 in support. A calculation was completed in line with the guidance set out by the Senior Traffic Commissioner in Statutory Document 2 – using the most recent three months statements. The result was that this Operator fell significantly short of the financial standing requirement. In fact, there was insufficient evidence to support a single vehicle authority.
The calling-in letter invited the Operator to provide more recent or further evidence to support financial standing. In failing to provide the requested evidence ahead of the Inquiry, the applicant has failed to demonstrate that this mandatory and continuous requirement is met or can be met.
“Schedule 3(7b)(1) & (2) and Section 14ZA(3)(a) and Section 14ZA(2)(d) – Transport Manager’s Good Repute and Professional Competence”
The calling-in letter directed that Mr. Lambat as Transport Manager, was to attend this Hearing. The reason for doing so was in order to understand his role in the shortcomings identified. I wished to understand how a person could be in charge of a vehicle for which they did not have entitlement to drive. I am further concerned as to why the details for an incorrect driver would be provided in response to the investigation.
The Transport Manager is responsible, in law, for the continuous and effective management of transport services. It appears that Mr. Lambat has failed in that duty.
As a CPC Qualified Transport Manager Mr. Lambat is also expected to be aware of, and to comply with, all undertakings and conditions of the Operator’s licence. He failed to ensure the notification of material changes to this office.
Findings & Reasons
“Section 14ZA(2)(b) – Good Repute”
I consider the question posed by the Upper Tribunal in 2009/225 Priority Freight namely: “how likely is it that this operator will, in future, operate in compliance with the operator’s licensing regime?”. In this case I answer in the negative. I find, on the balance of probability, that the allegations of the Council are, more likely than not, accurate. This failure was extremely serious and created a direct risk to both road safety and fair competition. Accordingly, I make adverse findings in respect of Section 14ZA(2)(b) for that alone. I make separate adverse findings in consideration of the applicant’s failure to engage with the DVSA investigation and failure to attend the Public Inquiry. Those failures are sufficient to allow me to find that I cannot trust this Operator whether taken individually or combined with the Council’s allegations.
I go on to consider the question posed by the Upper Tribunal in “2002/217 Bryan Haulage” namely, is the conduct such that the Operator ought to be put out of business? I answer this in the positive. The negative features of this case are well laid out above and I have little or no positive features against which to balance.
In conclusion I find that the Operator has lost its good repute. I further find that there is little to no distinction to be made between the licence holding company, and Mr. Lambat who was the Sole Director until May of this year. It is he that was in control when the Council raised its concerns, it was he that was in control when the DVSA were unable to investigate, and he remains in control (as a joint Director) on the day of the Inquiry. I find Mr. Lambat has forfeited his good repute. I make no such finding against Mr. Malji.
“Section 14ZA(2)(c) – Financial Standing”
In respect of Section 14ZA(2)(c) I make adverse findings as the applicant has provided me with evidence that it does not satisfy financial standing for even a single vehicle, and has since failed to provide me with any further evidence.
“Schedule 3(7B)(1) & (2) – Transport Manager Good Repute”
I find Mr. Lambat has failed in his duty to ensure continuous and effective management of transport services. This lead to a very distinct and credible risk to road safety and, in particular, the safety of school children entrusted to the care of this Operator. As transport manager he has also failed to ensure that the Operator continued, at all times, to comply with the conditions and undertakings of its Operator’s licence. I also consider the fact that he has failed to attend this Public Inquiry. I have considered whether a finding that he is no longer of good repute would be disproportionate and I conclude that it would not. There have been serious shortcomings as set out above and I conclude that the Transport Manager’s failures have created a very real road safety risk, has undermined fair competition, and has sought to avoid the scrutiny of both DVSA and the Traffic Commissioner. I find good repute is lost, and I apply an indefinite period of disqualification.
“Section 14ZA(2)(d) & 14ZA(3)(a) – Professional Competence & Transport Manager”
With Mr. Lambat no longer meeting the requirement to be of good repute, and being disqualified, it follows that this licence holder no longer meets the requirements to be professionally competent and/or to have designated a transport manager who is of good repute. Accordingly I make adverse findings under Sections 14ZA(2)(d) and 14ZA(3)(a) of the 1981 Act.
Decision
As stated above, this Operator has been put on notice of my concerns. Whilst a Public Inquiry was not expressly requested I was asked to consider allowing the operation to continue – that request failed to address the concerns. The Operator, in failing to attend this Hearing, has denied itself the opportunity to provide additional information which might have allayed my concerns.
For the reasons above, I direct that this Standard National PSV Operator’s licence is revoked under provision of Section 17(1)(a) and/or 17(1)(2), in that the licence holder no longer satisfies the following requirements of Section 14ZA(2) and 14ZA(3):
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Section 14ZA(2)(b) – The Traffic Commissioner must be satisfied that the Operator is of good repute;
- Section 14ZA(2)(c) – The Traffic Commissioner must be satisfied that the Operator has appropriate financial standing;
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Section 14ZA(2)(d) – The Traffic Commissioner must be satisfied that the Operator is professionally competent;
- Section 14ZA(3)(a) – The Traffic Commissioner must be satisfied that the Operator has designated a transport manager who is of good repute.
Additionally, under provision of Schedule 3, (7b)(1) & (2), that the Transport Manager no longer satisfies the requirement to be of good repute and that their disqualification is for an indefinite period is justified and proportionate.
I consider immediate revocation to be proportionate as the most recent information I have from the Operator is that they are not trading and I note that, as of today, it remains that there are no vehicles specified on the licence.
“Post Script”
“a. For the sake of completeness and the avoidance of doubt, the variation applications to add Director Mr Abdul Suleman Malji, and additional Transport Manager Hamza Mohammed Ayaz are refused because the licence is revoked. I make no adverse findings against any of these individuals.”
“b. I note that Mr. Lambat is specified as a Transport Manager on a number of other licences and I will direct the OTC to inform those licence holders and allow a period of time for professional competence to be rectified.”
David Mullan
Traffic Commissioner for the North West of England
11 November 2025