Neutral Citation Number: [2010] UKUT 297 (AAC)

 

Appeal No. T/2010/034

IN THE UPPER TRIBUNAL

ADMINISTRATIVE APPEALS CHAMBER

TRAFFIC COMMISSIONER APPEALS

 

ON APPEAL from the DECISION of MARY KANE DEPUTY TRAFFIC COMMISSIONER for the South East and Metropolitan Traffic Area

Dated 7 April 2010

 

 

 

Before:

His Hon. Michael Brodrick, Judge of the Upper Tribunal

Patricia Steel Member of the Upper Tribunal

David Yeomans Member of the Upper Tribunal

 

 

Appellant:

W P COMMERCIALS LIMITED

 

 

 

Attendances:

For the Appellant: Stephen Thomas, of Stephen Thomas Law

Other parties: Mr & Mrs Earnshaw, Mr & Mrs Silvester and Mr Oliver all attended the hearing as Representors who had become parties to the appeal.

 

Heard at: Victory House

Date of hearing: 23 July 2010

Date of decision: 12 August 2010

 

 

 

 

DECISION OF THE UPPER TRIBUNAL

IT IS HEREBY ORDERED that this appeal be ALLOWED to the extent that the condition relating to the movement of authorised vehicles is varied by the addition of the following after the word ‘Sunday’: “Save that occasional movements into the operating centre are permitted outside these hours provided that each results from matters outside the control of the Appellant. The date of each such movement and the reason for it must be reported to the Traffic Commissioner within 7 days of the day on which the movement took place”. The other conditions remain in force without alteration.

 

 

 

 

SUBJECT MATTER:- Operating Centre, environmental issues, conditions

 

 

CASES REFERRED TO:- None

 

 

 

REASONS FOR DECISION

 

 

1.           This is an appeal from the decision of the Deputy Traffic Commissioner for the South East and Metropolitan Traffic Area to impose conditions on the Restricted Goods Vehicle Operator’s licence held by the Appellant following the grant of the Appellant’s application to vary the number of vehicles authorised from 2 to 4.

2.           The factual background to this appeal appears from the documents and the Traffic Commissioner’s decision and is as follows:-

(i)                   The Appellant is the holder of a Restricted Goods Vehicle Operator’s licence. When the licence was issued in April 2008 it authorised 2 vehicles at an operating centre at Fre-Mel Farm, Offham, West Malling in Kent. At that stage there was one condition attached to the licence, namely that authorised vehicles should enter the operating centre using the route which passed ‘Alexander House’ and that they should exit the operating centre using the route which passed ‘The Bungalow’.

(ii)                 In June 2009 the Appellant submitted an application to increase the number of authorised vehicles to 4. That application attracted 5 representations, which were sent to the Traffic Commissioner but most were not copied to the Appellant, at the request of the authors. Nevertheless 3 out of the 5 representations were ruled to be valid while the remaining two were ruled to be invalid because they were received far too late. However one of the invalid representations, coming from Offham Parish Council, was copied to the Appellant.

(iii)                The main grounds advanced by the Representors were (a) noise and pollution resulting from operating 7 days per week, (b) erosion of the entrance track, (c) danger to pedestrians, horse riders and others using the entrance track due to its narrowness, (d) the increase in the speed and volume of traffic on the entrance track since the grant of the licence and (e) the suggestion that the route passing ‘The Bungalow’ should be used as the entrance and the exit to the operating centre.

(iv)                No objection was received from the Local Authority, Tonbridge and Malling Borough Council.

(v)                 On 29 June 2009 the site was visited by Mr. Zinzan, a Vehicle Examiner. He was satisfied that the operating centre, itself, was large enough to take 4 vehicles and that they would be able to enter and leave in forward gear. However he expressed concern about the suitability of the access via ‘Alexander House’ and the problems at its junction with Comp Lane, a public highway. In his view those problems could be overcome by a condition requiring all movements into and out of the operating centre to use the junction with Comp Lane at ‘The Bungalow’.

(vi)                Following receipt of the Vehicle Examiner’s report the Traffic Commissioner put forward three proposed conditions namely that (a) all authorised vehicles should enter and exit the operating centre via the access passing The Bungalow, (b) authorised vehicles should be rigid in type and (c) that there should be no operation, movement, loading or unloading of authorised vehicles before 0800 and after 1730, Mondays to Saturdays, and before 0800 and after 1300 on Sundays.

(vii)              The Appellant indicated “after much consideration” that it was unable to agree to any of the proposed conditions. On the other hand the Representors, in the main, responded that they would welcome the proposed conditions. As a result of these replies the Traffic Commissioner directed that the matter should be determined at a Public Inquiry.

(viii)             The call-up letter is dated 4 November 2009. Amongst the papers enclosed with this letter was a document headed ‘Case Summary’. That document set out the grounds advanced by the Representors in similar terms to paragraph 2(iii) above. Under the heading ‘Previous History’ reference was made to the fact that the land being used for the operating centre had the benefit of a ‘Certificate of Lawful Use’ [“CLU”] issued in 1994. The relevant terms of the CLU are:-

“(b) Hours of opening to the public 0800-1730 Monday to Saturday and 0800-1300 Sunday.

(c) General hours of use by employees as above (b) but with occasional cars and lorries to and from the site at other times”

(ix)                The Public Inquiry was held on 1 December 2009. The two directors of the Appellant, Mr. & Mrs Paternoster, appeared on behalf of the Appellant. The Vehicle Examiner, Mr. Zinzan attended and gave evidence. Mr. & Mrs Earnshaw, Mr. & Mrs Silvester and Mr. Oliver, whose representations had been accepted, all attended as did Mr. Balfour, a Borough Councillor, who represented Mr. Oliver and Mrs Innes, who appeared on behalf of the Parish Council. She was permitted to speak for the Parish Council on the basis that she did so as a witness.

(x)                 The evidence at the Public Inquiry focussed on each of the proposed conditions, two of which are not subject to appeal.

(xi)                In relation to the suggestion that all movements should be routed via the junction at The Bungalow Mr. Paternoster told the Deputy Traffic Commissioner that he did not think that his rigid 18 tonne vehicle could turn either left or right from Comp Lane into the route passing The Bungalow. When questioned by Mr. Paternoster Mr. Zinzan said that he had been told by Mr. Paternoster that the Appellant only wanted to use a rigid vehicle of up to 30 tonnes, that it would not be using trailers and that it could work with vehicles of less than 30 tonnes. In answer to Mrs Innes Mr. Zinzan said that he considered that visibility in both directions at The Bungalow exit would be satisfactory. However he accepted that part of the land over which vehicles would turn actually belonged to the bungalow and might be damaged by vehicles turning. He said that he would recommend a limit on the weight and size of authorised vehicles.

(xii)               Mr. & Mrs Paternoster gave evidence that the Appellant company’s business was to repair and maintain vehicles and that at the time of the Public Inquiry the Appellant had a 7.5 tonne vehicle, for picking up spares and an 18 tonne vehicle for large movements. According to the Traffic Commissioner’s written decision Mr. & Mrs Paternoster went on to say that they wanted a further 7.5 tonne vehicle and a further 18 tonne vehicle to be used as part of the breakers yard side of the business but that he did not want to be restricted by conditions along those lines. Mr. Paternoster repeated his opposition to conditions relating to the use of rigid vehicles only and to the operating hours suggested. He added that if the Appellant did not get authority for another two vehicles it would have to use ‘free lance’ vehicles over which it would have no control. He said that he would be happy to abide by the hours set out in the CLU.

(xiii)             The evidence from the Representors concentrated on demonstrating that the access passing by Alexander House was unsuitable. But in addition it raised questions about the suitability of the access passing by The Bungalow for use by articulated vehicles or trailers.

(xiv)             In a written decision, which was sent to the Appellant and to all the Representors on 13 January 2010 the Deputy Traffic Commissioner reached the conclusion that the access passing Alexander House was not suitable as an entrance to the operating centre. She also concluded that the grant of the application to increase the number of authorised vehicles would have an adverse effect on the environment unless conditions were imposed. She proposed four conditions or undertakings, namely: (a) authorised vehicles should enter and exit from Comp Lane via The Bungalow entrance, (b) authorised vehicles should be rigid in type, (c) no authorised vehicle greater than 18 tonnes plated weight shall be used on the licence at the operating centre and (d) that the hours of operation should be as set out in the condition proposed by the Traffic Commissioner, see paragraph 2(vi) above. In accordance with s. 23 of the Goods Vehicles (Licensing of Operators) Act 1995, ["the 1995 Act"] the Deputy Traffic Commissioner invited representations in respect of the proposed conditions.

(xv)              The Appellant replied by accepting the first two conditions. But the Appellant went on to submit that the changes imposed by these two conditions meant that the remaining conditions were unnecessary. In particular it was submitted that no weight limits applied in relation to the other users of the access passing The Bungalow, that the maximum weight for a rigid vehicle was 32 tonnes and that the refuse vehicles which operated in Comp Lane exceeded 18 tonnes. In relation to operating times it was submitted that they should be aligned with the times in the CLU and that they should permit occasional movements outside the specified hours to allow vehicles held up by traffic or bad weather, for example, to return to the operating centre rather than having to find another place to park.

(xvi)             The Representors agreed with the proposed conditions.

(xvii)            The Deputy Traffic Commissioner did not agree with the Appellant’s views. She referred to the evidence given by Mr. Paternoster, namely that the largest vehicle which he intended to use on the licence was an 18 tonne vehicle. She also referred to his evidence that the access at The Bungalow junction caused some difficulties for larger vehicles. In relation to permitted hours the Deputy Traffic Commissioner pointed out that the question of occasional use outside the hours proposed by the Traffic Commissioner had not been raised at the Public Inquiry. She took the view that extending the hours could put the operator in breach of the terms of the CLU, which entitled the Appellant to carry out its business on the site.

(xviii)          For these reasons the Deputy Traffic Commissioner imposed all four of the conditions which she had originally proposed. Her decision was sent to the parties on 7 April 2010.

(xix)             The Appellant appealed against that decision by a Notice of Appeal dated 29 April 2010. In relation to the permitted hours for the movement of authorised vehicles it was submitted that the condition should be varied to permit occasional movements out of hours, thereby bringing the condition into line with the terms of the CLU. In relation to the condition limiting vehicles to a maximum of 18 tonnes gross plated weight it was submitted that the condition that only rigid vehicles could be used was sufficient because vehicles would be limited to the maximum weight permitted for a rigid vehicle.

3.           At the hearing of the appeal the Appellant was represented by Stephen Thomas, who had not appeared at the Public Inquiry. In advance of the hearing he provided us with a helpful skeleton argument for which we are grateful.

4.           In relation to the first point raised in the grounds of appeal, namely the question of permitted hours, Mr. Thomas stressed that the Appellant was not seeking to extend the hours permitted by the CLU. Instead it was seeking to vary the condition so that it matched the terms of the CLU by permitting occasional out of hours movements in order, for example, to cope with the problems caused by heavy traffic or bad weather. The best estimate which could be given in the course of the hearing was that this might happen about 36 times per year.

5.           In seems to us that there was some confusion in the mind of the Deputy Traffic Commissioner as to whether the Appellant was just seeking a condition which permitted occasional out of hours movements or whether the Appellant was seeking a condition containing wider hours than those set out in the CLU. In our view the Deputy Traffic Commissioner was plainly right to reject any extension of the specified hours permitted by the CLU. While we accept that there was no detailed discussion of the implications of a condition which precisely matched the terms of the CLU it was made plain from the outset that the Appellant wished to be able to operate on the basis set out in the CLU, in other words during the hours specified and with the ability to make occasional out of hours movements. In our view it is unfortunate that the Deputy Traffic Commissioner did not clarify exactly what the Appellant was seeking in this respect, though it has to be said that the overall approach adopted by the Appellant probably did not assist this process. To that extent we consider that this part of the decision has to be regarded as plainly wrong.

6.           We believe that it will benefit all concerned if occasional out of hours movements are permitted, under strict conditions. If the present condition is maintained and the relationship between Mr.& Mrs Paternoster, on the one hand, and those living in the locality, on the other, does not improve the chances are that each time it is thought that an authorised vehicle has returned late there will be a complaint to the Traffic Commissioner that the condition has been breached. Assuming that the Appellant was then able to show that the movement was caused by matters outside its control it seems to us that it is unlikely that the Traffic Commissioner would take action, save, perhaps, to vary the condition, in the way in which we propose to vary it, in order to avoid the problems caused by repeated complaints, especially if they lack a firm evidential foundation.

7.           Two of the dictionary definitions of ‘occasionally’ are particularly significant in the present context. An event occurs occasionally if it happens ‘infrequently’ and/or ‘irregularly’. In other words the variation of the condition to permit occasional out of hours movements will not allow the Appellant to make a habit of returning late. If, for example, it becomes clear that traffic conditions are always bad at a particular time or on a particular day they cannot then provide justification for out of hours movements because such movements will cease to be infrequent or irregular.

8.           The problem identified by the Appellant is the occasional need to return late because of matters beyond its control. The variation will therefore be limited to take this into account. Given the poor state of the relationship between the parties we consider that all out of hours movements must be notified to the Traffic Commissioner within 7 days of the movement taking place. The notification must also explain why the out of hours movement was necessary. Notification will enable the Traffic Commissioner to monitor this condition to ensure that the out of hours movements are occasional and for reasons outside the control of the Appellant. It will also mean that if there are concerns in the future that the condition is being abused that those concerns can be considered in the light of contemporaneous evidence. Finally the Appellant should be aware that serious consequences might follow should it be proved that unreported out of hours movements had taken place. It will need to take care to ensure that all out of hours movements are fully reported to the Traffic Commissioner.

9.           For these reasons the condition in relation to the timing of movements will be varied. The following will be added after the word ‘Sunday’: “Save that occasional movements into the operating centre are permitted outside these hours provided that each results from matters outside the control of the Appellant. The date of each such movement and the reason for it must be reported to the Traffic Commissioner within 7 days of the day on which the movement took place”.

10.        Turning to the condition restricting the weight of authorised vehicles to 18 tonnes Mr. Thomas made the following points: (a) that the Deputy Traffic Commissioner appeared to be unaware that in 2006 another operator, using a different part of the same site, had been authorised to operate 6 vehicles with no weight restriction, but had since ceased to trade, (b) that she failed to take into account that there were two other operators using the site again without any weight restriction on their licences, (c) that the absence of any recording of the Public Inquiry and the consequent lack of a transcript has resulted in inaccuracy in relation to significant parts of the notes of the evidence, (d) that Mr. Paternoster made it clear that the Appellant needed vehicles of at least 18 tonnes, rather than 18 tonnes precisely, (e) that the Deputy Traffic Commissioner should have known and had regard to the fact that the dimensions of a 26 tonne or 32 tonne rigid vehicle can be the same as those of an 18 tonne vehicle, (f) that a restriction to 18 tonne vehicles would mean a greater number of vehicle movements than a condition limiting the Appellant to the use of rigid vehicles.

11.        In our view the Deputy Traffic Commissioner cannot be criticised for paying little attention to the fact that other operators may have been granted operator’s licences without any condition as to the weight of the authorised vehicles. The reason is that there was no evidence before her as to the circumstances in which those licences were granted. The Deputy Traffic Commissioner had to decide this case on the material which was put before her, which concentrated on the position in relation to this Appellant.

12.        We have been told by the Office of the Traffic Commissioner that the recording equipment was faulty, hence the absence of a transcript. In it’s place we have copies of the notes taken by the Deputy Traffic Commissioner and by someone else, (we assume that it must have been her clerk). Mr. Thomas submitted that there were two significant points which could have been conclusively resolved had there been a transcript. The first was the comment, attributed by Mr. Zinzan to Mr. Paternoster, that the Appellant wanted to use a 30 tonne vehicle. Mr. Thomas submitted that the weight given by Mr. Paternoster was, in fact, 32 tonnes. The notes suggest that what was heard was 30 tonnes but, in our view, this point does not assist the Appellant, however it is resolved, because of the strength of the evidence in relation to the other aspect of Mr. Thomas’s submission.

13.        The second was that Mr. Thomas submitted that the marks which appear after the figures 18 in both versions of the notes of Mr. Paternoster’s evidence tend to support the view that he was saying that the Appellant needed vehicles of at least 18 tonnes. We accept that there are occasions when it is arguable that the mark is more consistent with a plus sign, indicating 18 tonnes plus, than it is with the letter ‘t’, which would signify 18 tonnes exactly. However on other occasions we are left in no doubt at all that the mark is a ‘t’ and not a plus sign. We are quite satisfied that both the people taking notes are referring to the same thing each time a mark is made after the figures 7.5 or 18, in other words the differences cannot be explained on the basis that the witness is talking about more than two different kinds of vehicle. Having reached that conclusion it is, in our view, appropriate to take an overall view of the evidence in order to assess whether the Deputy Traffic Commissioner has come to the correct conclusion or whether the Appellant may be right.

14.        It is clear from the terms of her decision that the Deputy Traffic Commissioner believed that Mr. Paternoster was saying that the purpose of the variation was to obtain authority for one more 7.5 tonne vehicle and one more 18 tonne vehicle. The question is whether it is possible, in the absence of a transcript, to come to a conclusion as to whether this view was well founded or whether she may have misunderstood what Mr. Paternoster was saying. We know from the list of vehicles specified on the licence, (page 11 of the appeal bundle), that there was one 7.5 tonne vehicle and one 18 tonne. In the course of his evidence Mr. Paternoster was asked about the Appellant’s existing vehicles. The note made by the Deputy Traffic Commissioner, (page 152 of the appeal bundle), records: “7.5 tonnes – picks up spares, 18 tonnes – for large movements”. Since the word ‘tonnes’ is spelt out in full on this occasion there can be no doubt at all that she is referring to the existing vehicles by weight. The other note, (page 163 of the appeal bundle), refers to the two vehicles currently authorised on the licence and the uses to which they were put, as recorded by the Deputy Traffic Commissioner. On the other hand there is a mark after 7.5 and 18 which in one case looks more like a ‘t’ and the other more like a ‘plus’ sign. In our view the ambiguity is resolved beyond doubt when the two notes are taken together and when one takes into account the weights of the existing vehicles. We are satisfied that the mark which appears against the existing vehicles in this note is an abbreviation for ‘tonnes’. Moving on to the point where Mr. Paternoster was asked about the variation the note made by the Deputy Traffic Commissioner, (page 152 of the appeal bundle), records that he said that the appellant wanted: “1 more 18 and 1 more 7.5”. In each case there is a mark after the figure which could be a ‘t’ or could be a ‘plus’ sign. The other note of the same passage, (page 163 of the appeal bundle), is in these terms: “need two extra vehicles to collect vehicles that have broken down, vehicles will be 18t and 7.5t”. In our view there can be no ambiguity over the nature of the mark in this instance, it is, unequivocally a ‘t’, which we take to be an abbreviation for tonnes. This is entirely consistent with the Deputy Traffic Commissioner’s note because we take the view that in her case she used the word ‘tonnes’ in full on the first occasion and then an abbreviation to signify tonnes thereafter. Finally, at page 166 of the appeal bundle there is a passage attributed to the Paternosters, which is not replicated in the Deputy Traffic Commissioner’s notes, which reads: “want 2, 18t + 2, 7.5ts but don’t want to be restricted by conditions along these lines”. In our view the addition of the ‘s’ after 7.5t demonstrates that the mark is used as an abbreviation for tonnes. For these reason we are quite satisfied that there has been no misunderstanding on the part of the Deputy Traffic Commissioner and that she was right to proceed on the basis that Mr. Paternoster was asking for authority, on behalf of the Appellant, to add one 7.5 tonne vehicle and one 18 tonne vehicle to the licence.

15.        The remaining points made by Mr. Thomas were that the Deputy Traffic Commissioner should have known and had regard to the fact that the dimensions of a 26 tonne or 32 tonne rigid vehicle can be the same as those of an 18 tonne vehicle and that a restriction to vehicles of 18 tonnes would mean a greater number of vehicle movements than a condition limiting the Appellant to the use of rigid vehicles. It seems to us that Mr. Thomas was inviting us to say that the Deputy Traffic Commissioner was plainly wrong not to use her personal knowledge of these matters even though these issues were never raised at the Public Inquiry, with the result that the Representors never had an opportunity to deal with them. They emerged for the first time in the document submitted by the Appellant when given an opportunity to comment on the proposed conditions. This was not a document which was seen by the Representors. We asked Mr. Thomas to assume, contrary to the present position, that Representors have a right to appeal and we asked him to consider whether, if the Deputy Traffic Commissioner had taken the course he suggested, the Represetors would not have had unanswerable grounds of appeal, in relation to breach of natural justice and taking into account something which ought not to have been taken into account. Mr. Thomas had to accept that that would probably have been the case. Given the basis on which this Public Inquiry was conducted, namely that the larger of the two extra vehicles requested was to be 18 tonnes, we are quite satisfied that, in this case, the Deputy Traffic Commissioner was right not to take personal knowledge into account in reaching her decision in circumstances where none of those present at the Public Inquiry would have had an opportunity to comment on or correct her views, if necessary.

16.        There was evidence of concern about the ability of larger vehicles to turn into the access road at the junction by The Bungalow. There was also evidence that vehicles might cause damage to land belonging to The Bungalow. When that is coupled with a clear statement on the part of Mr. Paternoster that the larger of the two vehicles for which authorisation is requested is to be 18 tonnes it seems to us that the Deputy Traffic Commissioner was entitled to impose a weight condition in the present case and it is quite impossible to say that she was plainly wrong to do so.

17.        Indeed developments between the main decision, in which conditions were proposed, and the final decision in which they were imposed tend to confirm the wisdom of adding this condition. It appears that in this intervening period the Appellant added a 26 tonne vehicle to those authorised by the licence. We were told that following the final decision and the imposition of a weight condition the vehicle was not used pending the outcome of this appeal. In our view, given the circumstances of this case, if the Appellant wishes to operate heavier vehicles it must apply for a variation of the present condition. That will enable the arguments that a heavier vehicle will not cause more damage and will reduce vehicle movements to be the subject of evidence and argument so that a properly informed decision can be reached on the point.

18.        For these reasons the appeal is allowed in part, (by varying the condition relating to the timing of movements), but the condition restricting authorised vehicles to 18 tonnes is upheld.

19.        Many of the Representors or potential Representors gave reasons as to why their letters had not been sent to the Appellant and those letters were stamped ‘confidential’ by the Traffic Office and not copied to the Appellant. Nevertheless some of these letters were accepted as valid representations and, as we have indicated in paragraph 2(viii) above the substance of the representations was set out in the Call-up letter. The statutory position is that there is a mandatory requirement in s. 12(7) of the 1995 Act for a representation to be made within the prescribed time and in the prescribed manner, both of which are set out in regulations. A representation must be made within 21 days beginning with the date on which the notice of the application was published, see Regulation 12(2) of the Goods Vehicles (Licensing of Operators) Regulations 1995, [“the 1995 Regulations”]. In addition to sending a copy of the representation to the Traffic Commissioner Regulation 11(2) of the 1995 Regulations provides that a copy of the document delivered to the Traffic Commissioner “shall be sent to the applicant on the same day as, or the next working day after, the delivery to the Traffic Commissioner.” Notwithstanding the mandatory form of these provisions s.12(8) of the 1995 Act gives the Traffic Commissioner discretion to treat a representation as “duly made” even though it was out of time or not made in the prescribed manner, “where the Traffic Commissioner considers there to be exceptional circumstances that justify his doing so”. The Traffic Commissioner concluded that there were exceptional circumstances in the present case and concluded that some of the representation were duly made. We do not seek to question that conclusion in the present case but we do wish to draw attention to the problems which are likely to arise if an applicant is not sent a copy of a representation which is considered to have been duly made. It is essential that the applicant is fully informed of the substance of any un-copied representation. Any failure in this respect runs the risk that there will be a breach of natural justice. Representors need to understand that Traffic Commissioners are most unlikely to act on the contents of written representations, particularly those not copied to the operator, unless the contents are either agreed or supported by evidence.

20.        In the present case the letters sent by the Representors were included in the bundle of papers prepared for the Deputy Traffic Commissioner, even though they were still not available to the Appellant. The Representors attended the Public Inquiry and gave evidence so that Mr. & Mrs Paternoster had the opportunity to deal with what they had to say. No point was taken about this procedure in the course of the appeal, (by which time the letters formed part of the appeal bundle available to all), save to say that had the Appellant been aware of certain photographs, included with one of the letters, it would have been possible to prove that the vehicle shown was not one of the authorised vehicles. Since the photographs were of a vehicle on the public highway they were irrelevant to the issues which the Deputy Traffic Commissioner had to resolve. Nevertheless this point does serve to illustrate that, if a breach of natural justice is to be avoided, very great care must be taken to convey the substance of representations, when copies of letters from Representors are not sent to the operator and the representation is nevertheless accepted as valid.

 

 

 

 

 

Michael Brodrick, Judge of the Upper Tribunal,

Principal Judge for Traffic Commissioner Appeals.

12 August 2010