Discussion
27.The Tribunal has detailed much of the history of this case so that any reader of this decision could be no doubt that this was a very serious case which justified the TC’s conclusion that R&J and Mr Singh had lost their good repute and that they could not be trusted to operate compliantly in the future. A finding that R&J deserved to be put out of business was plainly right. Moreover, in view of the many compliance failings and Mr Singh’s conduct as found by DTC Davies during the currency of the interim licence, it is surprising to say the least, that a full licence was granted at all in October 2020. It was clear and obvious that at that stage, Mr Singh and it follows, R&J, could not be trusted. Mr Singh had been given his first chance to demonstrate compliance and trustworthiness in March 2019 and had then been given a second chance when a full licence was granted in October 2020 with regulatory actions taken. He chose not to take advantage of the opportunities he was given to operate compliantly.28.As accepted by Mr Davies (and Mr Mason before the TC) there were few positive features which could have been weighed into the balance when considering good repute and revocation. All of the TC’s findings with regard to Mr Singh as an operator and an individual were well supported by the evidence. This was an overwhelming case justifying loss of repute, revocation and disqualification. We do not accept that the TC’s decision to step back from a finding of “fronting” amounted to a positive feature. Her decision simply meant that there was one less seriously aggravating feature to take into account. Those aggravating features that were considered, clearly justified a finding that a disqualification period of seven years was a proportionate order to make in the circumstances.