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Revitalising Justice - Proposals To Modernise And Improve The Criminal Justice System

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07: MODERNISING OUR LICENSING LAW

We propose to take forward a number of changes to the law on licensing and these are detailed below.

SETTING OUT OUR STRATEGIC APPROACH TO TACKLING ALCOHOL MISUSE

Subject to the outcome of our alcohol strategy discussion paper, which outlines a comprehensive package of measures aimed at reducing alcohol-harm in Scotland, we may opt to include proposals in the Criminal Justice and Licensing Bill.

Relevant weblinks

Scottish Government's "Setting out our Strategic Approach to Tackling Alcohol Misuse" consultation paper - June 2008

http://www.scotland.gov.uk/Publications/2008/06/16084348/0

BENEFIT OF MAKING THE PROPOSED CHANGE

Will support our plans to tackle alcohol misuse in Scotland.

"FIT AND PROPER PERSON" TEST - LICENSING (SCOTLAND) ACT 2005

The Licensing (Scotland) Act 2005 (the "2005 Act") will replace the Licensing (Scotland) Act 1976 in its entirety. The 2005 Act and the new licences under it come fully into force on 1 September 2009 at the end of a transition period that began in February 2008. It replaces the 1976 Act's system of separate licences for pubs, restaurants &c with a single all-purpose premises licence and a personal licence.

An issue of concern that has been raised with the way the 2005 Act will work is the restricted ability of the police to comment on applications for premises and personal licences.

Under the 1976 Act, various "competent objectors", including the chief constable, may object to the grant, renewal or transfer of a licence. Objections must be relevant to the grounds, as set out in section 17, on which the Board may refuse to grant a licence. These grounds include that the applicant (or connected persons) are not a "fit and proper person" to be the holder of a licence. Section 16A also permits the chief constable to submit "observations", again relevant to the grounds in section 17.

The 2005 Act takes a different approach. Section 22 allows any person to object to an application for a premises licence, but subsection (2) limits the chief constable so that he can only object on the ground that he has reason to believe that the applicant is involved in serious organised crime and that refusal of the application is necessary for the purpose of the crime prevention objective (in section 4(2)). The chief constable also has a role, under section 21, of providing antisocial behaviour reports and a notice relating to convictions for relevant or foreign offences.

We propose to amend the 2005 Act to enhance the police role. We do not propose to reintroduce a "fit and proper person" test as such, but rather to work within the existing framework of the 2005 Act to ensure that the police have appropriate powers and suitable provisions will be included in the Criminal Justice and Licensing Bill.

BENEFIT OF MAKING THE PROPOSED CHANGE

Will ensure the police are able to bring a wider range of information to the attention of the Licensing Board at the time of application.

IMPROVEMENTS TO LICENSING LAWS - CIVIC GOVERNMENT (SCOTLAND) ACT 1982

A Task Group was set up by the previous administration to review the licensing provisions contained in the Civic Government (Scotland) Act 1982 (the "1982 Act"). The Group reported in December 2004 and made a number of recommendations for reform.

The then Scottish Executive responded to the report in August 2005 agreeing with the broad thrust of the recommendations, but indicated that those requiring primary legislation would be for a new administration to introduce following the 2007 elections, in light of competing priorities. We will take forward the relevant recommendations within the Criminal Justice and Licensing Bill.

The Task Group report's recommendations cover the general licensing provisions of the 1982 Act, and include specific provisions on metal dealers, market operators, public entertainment and late hours catering, taxis and private hire cars. The amendments to the 1982 Act will be largely of a technical nature affecting procedural aspects of the current licensing regime though some of the amendments contain deregulatory measures. We will take forward the relevant recommendations made in the Task Group report by making the following changes.

Standard conditions attached to deemed grants

Where the authority has failed to reach a final decision on a grant application before the expiry of the statutory period under the 1982 Act, the licence is statutorily deemed to have been granted unconditionally on the date of expiry and remains in force for one year. We intend to take forward the recommendation that the existing "deemed grant" provisions should be retained, but the Act should be amended to permit the application of standard conditions to any such licence.

Right of entry and inspection for police civilian staff

We intend to take forward the recommendation that the rights of entry and inspection in relation to constables under the 1982 Act for specified purposes (such as checking compliance with the terms of the licence), should be extended to include civilian staff employed by the police under the provisions of section 9 of the Police (Scotland) Act 1967.

Display of licences

We intend to take forward the recommendation, in the interests of public safety, to amend the Act to make it a mandatory condition of a licence that the licence (or a copy) be displayed on premises, vehicles (or a plate) and vessels, and where this is not practical for the licence to be carried at all times by the day-to-day manager. In the case of other activities (such as window cleaners) it was further recommended that individuals should be required to carry the licence (or a copy) on their person unless the licensing authority, under its discretionary powers, has made it a condition of licence that an identification badge be displayed or shown on demand.

Representations, hearings and renewed applications

We intend to take forward the recommendation to make a number of amendments to Schedules to the 1982 Act, which include, extending the time allowed for making representations on any application for the grant or renewal of a licence from 21 days to 28 days, increasing the period of notice which licensing authorities must give for attendance at a hearing from 7 days to 14 days, and allow licensing authorities to consider licence renewal applications received after the expiry date as renewals rather than applications for a new licence for up to 28 days after the expiry of the previous licence.

Metal Dealers

We intend to take forward the recommendation that, given the decrease in metal dealing activity over the last 20 years, the current mandatory licensing scheme for metal dealers should be replaced with an optional licensing scheme, i.e. it would be open to local licensing authorities to determine whether or not a licence is required in its area.

Public Entertainment

We propose to implement the recommendation that the 1982 Act be amended to remove the existing exemption for free events. This recognised that it is unsatisfactory that authorities are not able to control large scale public entertainments that are free to enter. It noted that authorities may not wish to license certain types of free event, such as gala days and school fetes, but considered that the decision on whether to license these events should rest with the authority.

Late Hours Catering

We will take forward the recommendation that the part of the 1982 Act covering late hours catering should be extended to ensure that licensing authorities have the power to license any premises selling food or drink at late hours. The report states that "the principal justification for licensing such premises related to the potential for large numbers of people leaving pubs, night clubs etc. late at night to cause a disturbance, and that this potential exists regardless of whether the food or drink being sold has been cooked or pre-prepared in any way". As such, we consider that licensing authorities should have the option of licensing all such premises if they consider it necessary to do so.

Taxi fares - notification of decision on taxi fare scales or review

Section 17(3) of the 1982 Act states:

"Before fixing any scales or carrying out any review under this section the licensing authority shall-

(a) consult with persons or organisations appearing to them to be, or be representative of, the operators of taxis operating within their area; and

(b) give notice of their intention by advertisement in a newspaper circulating in their area stating-

(i) the general effect of the proposals and the date when they propose that their decision will take effect; and

(ii) that any person may lodge representations in writing with respect to the proposals within a period of one month after the date of first publication of the notice; and

(c) consider any such representations duly lodged with them".

The intention of the 1982 Act was that a licensing authority should before (1) fixing any scales or (2) carrying out any review of scales consult with those persons or organisations referred to at section 17(3)(a) and give notice of their intention to fix scales or undertake a review in the manner prescribed at 17(3)(b). We are aware that some authorities are unclear about the provisions with regard to the need for consultation and we propose to bring forward provisions to clarify that consultation should be undertaken both when fixing any taxi scales or when undertaking a review of taxi scales.

Section 17(4) of the 1982 Act provides that where a licensing authority fix any scale or carry out any review they shall forthwith give notice in writing of their decision to such persons and organisations as were consulted under terms of subsection 17(3)(a) of the 1982 Act and informing them of the general effect of section 18(1) which advises of right to appeal.

It has been noted during consideration of the Task Group report that the wording of section 17(4) in providing for only notification to those persons and organisations consulted by an authority in terms of section 17(3)(a) results in a number of people with a legitimate interest being uninformed of a council's decision and thus their right of appeal under section 18(1).

Section 18(1) provides a right of appeal to "any person who operates a taxi in an area for which scales have been fixed or in respect of which a review has been carried out under section 17 of this Act". We therefore intend to provide that an authority should notify taxi operators in their area in addition to those representative persons or organisations consulted under section 17(3)(a).

Taxi fares -timescale for local authority review of taxi fares

Section 17(2) of the 1982 Act states:

"It shall be the duty of the licensing authority to fix from time to time scales for the fares and other charges mentioned in subsection (1) above and to review these scales at intervals not exceeding 18 months from the date on which the scales came into effect (whether proceeding upon a review under this section or not)".

The intention of the 1982 Act was that reviews under section 17(2) should be completed within the prescribed 18 month period and this was reflected in guidance issued in Scottish Development Department Circular 25/1986. Some authorities are interpreting the present legislation as providing that a fare scale review need only be commenced within the prescribed 18 month period, rather than commenced and completed within the 18 month period. In order to clarify this issue, we propose to bring forward provisions to make clear that taxi fare scale reviews should be commenced and completed within the 18 month prescribed period.

Taxi fare appeals - right of appeal

Section 18(1) of the Civic Government (Scotland) Act 1982 provides a right of appeal to "any person who operates a taxi in an area for which scales have been fixed or in respect of which a review has been carried out under section 17 of this Act".

The Task Group noted that the Traffic Commissioner for the Scottish Traffic Area had proposed that section 18(1) be amended to provide that "representative bodies" as well as individual taxi operators should have the right to submit an appeal in connection with taxi fare scales set by a licensing authority.

Section 17(3) as drafted provides that an authority consult with representative individuals or organisations before fixing any taxi fare scales or undertaking a review and subsequently notify these bodies under section 17(4) as to their decision and the general effect of section 18(1). In these circumstances it seems appropriate that the general appeal provisions under section 18(1) should apply to representative bodies or individuals. Consultation responses showed broad support for this amendment.

We therefore intend that provisions be brought forward to extend the right of appeal to include bodies or individuals representative of operators of taxis operating in the council area.

Taxi and private hire car driving licences - condition of eligibility

Section 13(3) of the Civic Government (Scotland) Act 1982 states that:

"a licensing authority shall not grant a licence to any person under this section unless that person has held, during any continuous period of 12 months prior to the date of his application, a licence authorising him to drive a motor car."

The Task Group took the view that the provisions as currently worded allowed a driving licence to be provided where an applicant had held a driving licence for any continuous 12 month period prior to submission of their application for a taxi or private hire car driver's licence. The Task Group recommended that provisions be brought forward that require an applicant for a taxi or private hire car driver's licence to have held a driver's licence for the 12 month period immediately prior to their application. Consultation responses on this issue confirmed that there was confusion over interpretation of the present provisions and showed significant support for the amendment proposed. We will bring forward suitable provisions.

Taxi fares -timescale for notification of interested parties

Section 17(5) of the 1982 Act provides for notification of the council's decision on a fare scale or fare scale review to be given to interested parties not later than 5 days after the relevant decision.

During its review of this section the Task Group considered that the prescribed timetable for undertaking this procedure was unnecessarily tight, particularly if broken by a weekend and/or public holiday and suggested that the prescribed notification period be extended to 7 days. The Task Group's proposal received almost unanimous support in consultee responses and we propose to bring forward suitable provisions.

Relevant weblinks

A Report by the Task Group Set Up to Review the Licensing Provisions Contained in the Civic Government (Scotland) Act 1982 - December 2004

http://www.scotland.gov.uk/Publications/2004/12/20391/48542

Scottish Executive response to Task Group Report - August 2005

http://www.scotland.gov.uk/News/Releases/2005/08/02134157

BENEFIT OF MAKING THE PROPOSED CHANGE

Will help tidy up the law.

"CLOSURE ORDERS" - LICENSING (SCOTLAND) ACT 2005

The Licensing (Scotland) Act 2005 contains a definition of ?senior police officer" as being a constable of or above the rank of superintendent.

We agree with the suggestion of ACPOS that the current definition of senior police officer will make it difficult to arrange emergency closure orders. This is as a result of the way in which town and city centre policing is normally carried out, where the most senior officer on duty may well be an Inspector or Chief Inspector. As the essence of the emergency closure order is that closure of the premises is necessary in the interests of public safety and that the risk to public safety is such that it is necessary to do so immediately and without making an application to the Licensing Board, it would cause practical problems if a more senior officer had to be found to make the order. We therefore propose that the definition of "senior police officer" in relation to closure orders is adjusted so that it means an officer of the rank of Inspector or above. In order to ensure consistency and avoid confusion the change will apply to all closure orders.

BENEFIT OF MAKING THE PROPOSED CHANGE

While maintaining the need for a senior officer to take decisions about prohibiting the sale of alcohol these changes will accord better with the practicalities of day to day policing by making the rank of officer required to take these decisions more appropriate.

NOTIFICATION OF APPLICATIONS AND SUBMISSION OF ANTISOCIAL BEHAVIOUR REPORTS - LICENSING (SCOTLAND) ACT 2005

The Licensing (Scotland) Act 2005 (the "2005 Act") requires Licensing Boards to provide notification of an application to a wide range of interested parties. These are as follows:

  • Each person having a notifiable interest in neighbouring land;
  • Any community council within whose area the premises are situated;
  • The council within whose area the premises are situated (except where the council is the applicant);
  • The appropriate Chief Constable; and
  • And the enforcing authority within the meaning of section 61 of the Fire (Scotland) Act 2005 (asp 5) in respect of the premises.

The 2005 Act also required that a copy of the application must also be sent to these parties along with notice of the application. A further requirement of the Act is that a duty was placed on Chief Constables to provide within 21 days a report detailing all cases of antisocial behaviour identified within the relevant period by constables as having taken place on, or in the vicinity of, the premises, and all complaints or other representations made within the relevant period to constables concerning antisocial behaviour on, or in the vicinity of, the premises.

As consideration was given to the implementation of the 2005 Act, it was considered these procedures were too onerous. Using regulatory powers, Scottish Ministers made transitional modifications that reduced the need to send a copy of the application to all interested parties so that only the relevant Chief Constable must be sent a copy of the application and reduced the requirement for the Chief Constable to provide a report on antisocial behaviour to only where the Board specifically requests it, or where it is a new application. Of course, the Chief Constable can make a report where he/she considers it necessary.

Boards and police agree that this has been successful, and we therefore intend to place these modifications on a permanent statutory footing through amendments to the 2005 Act.

Relevant weblinks

The Licensing (Transitional and Savings Provisions) (Scotland) Order 2007

http://www.opsi.gov.uk/legislation/scotland/ssi2007/pdf/ssi_20070454_en.pdf

BENEFIT OF MAKING THE PROPOSED CHANGE

Gives permanent effect to useful transitional arrangements that have assisted in reducing burdensome notification and reporting requirements on the police.

APPLICATION FOR A PERSONAL LICENCE: OFFENCE TO HOLD 2 PERSONAL LICENCES - LICENSING (SCOTLAND) ACT 2005

We propose an amendment to allow the Licensing Board to refuse to process or issue a personal licence if the applicant already held a valid personal licence. It would also make it an offence to apply for a second personal licence under the Licensing (Scotland) Act 2005 if the applicant already held a personal licence.

BENEFIT OF MAKING THE PROPOSED CHANGE

Clarifies the law on applying for second licences.

MODIFICATION OF LAYOUT PLANS - LICENSING (SCOTLAND) ACT 2005

Section 20(1) of the Licensing (Scotland) Act 2005 provides that an application may be made to a Licensing Board for a premises license. Section 20(2) then provides that an application must be accompanied by (amongst other things) an operating plan for the subject premises and a layout plan, in the prescribed form, of the subject premises.

Section 23(7) then provides that where the Licensing Board considers that they would refuse the application as made, but if a modification proposed by them were made to the operating plan for the subject premises accompanying the application, they would be able to grant the application, the Board must, if the applicant accepts the proposed modification, grant the application as modified.

The effect of section 23(7) appears to be that the Board has no power to modify the layout plan. It must therefore either grant the application as it stands or reject it.

We consider this an unnecessarily restrictive position and we therefore intend to allow the Board to propose a modification to the layout plan as one of the options open to them.

BENEFIT OF MAKING THE PROPOSED CHANGE

Improve the flexibility of the licensing system.

FAST TRACK FOR OCCASIONAL LICENCES - LICENSING (SCOTLAND) ACT 2005

When compared to the regime implemented by section 33 of the Licensing (Scotland) Act 1976 (the "1976 Act"), it has been suggested that the length of time it could take to progress an occasional licence application under the terms of the Licensing (Scotland) Act 2005 (the "2005 Act") could be excessive. The 1976 Act set no statutory time periods for determining an application, leaving such matters to local Licensing Boards and whatever arrangements they had with their local Police Forces.

We intend to make provision for a fast track occasional licence. We propose that the Licensing Board Clerk should be able, in certain circumstances to expedite an application. A Licensing Board or a delegated part of the Licensing Board should be able to decide if an occasional licence application should be fast tracked. It should then be for the Licensing Board to decide the procedures for processing the application. Licensing Boards should be required to forward a copy of the application to the Police and the Licensing Standards Officer; however they would not necessarily have the statutory 21 days within which to reply. If the Board decides not to hold a hearing the Licensing Board must nevertheless ensure the applicant is given an opportunity to "comment" on a refusal recommendation by the Chief Constable, a licensing standards officer report or an objection or representation as in section 59 of the 2005 Act.

BENEFIT OF MAKING THE PROPOSED CHANGE

Will allow the fast tracking of some occasional licences where there is very limited notice of the need for such a licence eg. a funeral.

EXTENDED HOURS APPLICATION - LICENSING (SCOTLAND) ACT 2005

Under section 68 of the Licensing (Scotland) Act 2005, an extended hours application can only be made by a person who already holds a premises licence. The Licensing Board can approve or refuse the application depending on whether they consider that the application is appropriate in accordance with the Act. Sections 68 to 70 do not make provision for the application being granted subject to conditions.

We believe there is a valid case for licensing boards to be able to attach additional conditions when granting extended hours applications. For example where a licensed premises has listed one of its activities as showing televised sport, a Licensing Board may see no reason to impose specific conditions. However if there was a request for extended hours to enable the screening of certain football matches during a major competition (for example the World Cup), the Licensing Board may wish to see additional conditions applied to the premises, e.g. extra door staff and the use of plastic glasses while those extended hours apply (and earlier in the day). We intend to bring forward amendments to permit this.

BENEFIT OF MAKING THE PROPOSED CHANGE

To allow flexibility to Licensing Boards so that they may impose additional conditions when granting extended hours applications.

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Page updated: Wednesday, September 24, 2008