[2025] UKUT 146 (AAC)

The grounds of appeal are at page 55 of the bundle and are as follows:-

“Ground 1

In all the circumstances it was wrong and an error of law not to provide the Appellant with an opportunity to have the potential revocation of its licence considered at a public inquiry, with such an obligation stemming from the principles of natural justice as explained in Atbus Ltd [2019] UKUT 0032 (AAC).

The Appellant is a long-established, exemplary operator and it had taken prompt steps to appoint a replacement transport manager following Mr Walton’s departure. The letter of 15 October 2024 does not record any ground for revocation of licence PM0000103 (“the Licence”) other than the lack of a transport manager and the Appellant would contend that none exist.

To revoke the Licence without giving the Appellant the opportunity to present its case, including the steps taken by Mr Fyvie to comply with the request for information made by the Office of the Traffic Commissioner, at a public inquiry, represents a clear breach of the principle of natural justice as per Atbus.”

“Ground 2

In all the circumstances the decision to revoke the Licence by the application of the new operating instructions was disproportionate and an unreasonable interference with the Appellant’s rights under Article 1 of the First Protocol (as part II, schedule 1 of the Human Rights Act, 1998).”

In addition to the grounds of appeal, Mr Davies helpfully provided a written skeleton argument for which we are grateful.