Agenda item

Admiral, 1A Bedford Street, WC2E 9HH


Site Name & Address


Licensing Reference No.

St James’s

West End*


Admiral, 1A Bedford Street, WC2E 9HH

New Gambling Premises Licence


*Cumulative Impact Area
** Special Consideration Zone






Thursday 4 November 2021


Membership:           Councillor Jim Glen (Chairman) Councillor Richard Elcho and Councillor Maggie Carmen


Officer Support:       Legal Advisor:         Steve Burnett

                                Policy Officer:          Kerry Simpkin

                                Committee Officer:  Georgina Wills

                                Presenting Officer:  Karyn Abbott


Application for a New Gambling Premises Licence in respect ofADMIRAL 1A BEDFORD STREET LONDON WC2E 9HH 21/01830/LIPN


Present:  Richard Wormald QC (Legal Representative, Future Leisure Limited), Elizabeth Speed (Group General Counsel, Future Leisure Limited), Shaun Hooper (Regional Operations Director, Future Leisure Limited), Mark Thompson (Head of Risk and Compliance, Future Leisure Limited) Kevin Jackaman (Licensing Authority), PC Bryan Lewis (Metropolitan Police), Ms E Kwong, (Mr Fogg’s Society of Exploration, Inception Group), Mr Marcus Lavell of Keystone Law, (representing Ms E Kwong) Mr Satta Padham (Witness for Mr Rajbir Sawhney, owner and operator of Speciality Drinks), David Kaner (Covent Garden Community and Association (CGCA)) and  Richard Brown, (Citizen Advice Bureau, representing CGCA)


Full Decision




Admiral 1A Bedford Street London WC2E 9HH




Future Leisure Limited


Cumulative Impact Area


West End




St James's


Summary of Application


This is an application under Section 159 of the Gambling Act 2005 (2005 Act). The Premises plans to operate as an Adult Gaming Centre (AGC).


Activities and Hours applied for


Hours premises are open to the public


Monday to Sunday 00:00 to 00:00


Representations received


  • Metropolitan Police (PC Bryan Lewis)
  •  Licensing Authority (Kevin Jackaman)
  • City Inception Group
  • Covent Garden Community and Association (CGCA)
  • The Northbank Bid
  • A local Business Owner


Summary of issues raised by objectors


The Metropolitan Police had maintained representation as the application may not promote the licensing objectives, contained within the 2005 Gambling Act namely:


  • Preventing gambling from being a source of crime or disorder, being associated with crime or disorder or being used to support crime.


  • Protecting children and other vulnerable people from being harmed or exploited by gambling.


There were also concerns about the plan to trade 24 hours a day in a high-risk area. The applicant has provided a comprehensive risk assessment but has not proposed any licence conditions to support the steps offered to manage risk.


The Licensing Authority maintained their representations on the grounds contained within the 2005 Act namely:


·       Preventing gambling from being a source of crime or disorder, being associated with crime or disorder or being used to support crime.

·       Ensuring that gambling is conducted in a fair and open way.

·       Protecting children and other vulnerable persons from being harmed or exploited by gambling.


The City Inception Group, Covent Garden Community and Association, The Northbank Bid, and a local business owner had maintained their representations on the grounds contained within the 2005 Act namely:


·       Preventing gambling from being a source of crime or disorder, being associated with crime or disorder or being used to support crime.

·       Protecting children and other vulnerable persons from being harmed or exploited by gambling.


There were also concerns raised regarding Public Nuisance.


Policy Position


Policies OBJ1, OBJ2, OBJ3, AGC1 and LOC1 of the City of Westminster Statement of Licensing Principles for Gambling apply.





The Sub-Committee considered an application by Future Leisure Limited for a New Gambling Premises Licence in respect of Admiral 1A Bedford Street London WC2E 9HH. The Presenting Officer provided a summary of the application and confirmed that representations had been maintained by the Licensing Authority, Metropolitan Police, Ellie Kwong, City Inception Group, the owners of Fogg’s Society of Exploration, Covent Garden Community and Association (CGCA), The Northbank Bid, and a local business owner. The Applicant and Objectors had submitted additional information, and these were circulated to all parties.


The Premises is situated in the St James's Ward. 


Mr Richard Wormald QC, Applicants’ Legal Representative presented the premises as a small fronted, basement building situated in Bedford Street. He stated that the building was ‘discreet’ and ‘modest’, it would not be attractive to either children or other vulnerable persons and was suited for its proposed use.  The Sub-Committee was advised that the Applicant’s overarching Company had an excellent reputation in the industry and oversaw over 240 venues and employed over 2400 staff within nearby localities. Mr Wormald advised that since its inception in 2007 there had been no problems which required some form of intervention from any of the Responsible Authorities.

He stated that the Applicant Company was an extremely well run and professional organisation.


Counsel explained that Ms Elizabeth Speed, Group General Counsel, Future Leisure Limited, was the current chair of the Back to Social Responsibility Committee and Mr Shaun Hooper, Regional Operations Director, Future Leisure Limited was also a member of the same body. Both individuals consulted and devised policies in these subject areas. Mr Wormald informed the Sub-Committee that Mark Thompson, Head of Risk and Compliance at Future Leisure Limited, previously worked for the Metropolitan Police and various local Authorities including Westminster. Mr Thompson had sat on the Crime and Serious Crime Unit in the Borough and was familiar with the locality. Counsel submitted that there was extensive training for staff members and commented that the Metropolitan Police had been consulted and had recommended that the premises personnel are of sufficient calibre, worked in the company for over 6 months and are trained. Courses provided for employees included leadership, organisational skills, and compliance.

Mr Wormald confirmed that the application was for an Adult Gaming Centre (AGC) and not for a licensed betting office. The Premises previously traded as a William Hill betting office for a 30-year period. The Sub-Committee was informed that licensed betting offices could have B2 machines which had a higher stake and that these machines were not and could not be present in AGCs. He reminded the Sub-Committee that B2 Machines were more of a concern regarding their usage by vulnerable persons. He advised that AGCs were not amusement arcades with video games and would not be attractive to children and young people and that these premises attracted a different type of clientele.


Mr Wormald highlighted that under the 2005 Act, AGCs did not have any restriction of hours on their operations and that this was indicative that they were viewed as having lower level of concerns. The premises layout had been designed to ensure that there are no blind spots. The cash desk would be clearly visible and that there was no sight line into the main basement area of the premises from the street level. This would help to ensure that children, vulnerable persons, and passers-by are not ‘drawn into’ the Premises. Mr Wormald QC asserted that the premises was in a good location, had excellent travel links and this would help with their dispersal policy. A SIA door supervisor would be present from 18:00 onwards and would monitor patrons entering the premises. The Sub-Committee was advised that this measure would ensure that patrons do not congregate near the premises. Mr Wormald added that the premises position would ensure that there were no noise spillage or vibrations into neighbouring properties.


The Applicants referred to national data indicated that the ‘rolling usage’ of AGCs machines were between 5 to 7 customers at any time and that the maximum number of patrons were between 12 to 14 people. It was asserted that patrons do not dwell in AGCs and that the number of machines at the premises should not be viewed as an indicator of the number of patrons that would be present at the premises. A high number of machines were present to ensure that there was a wide range of machines on offer. 


Counsel continued by informing the Sub Committee that the GamCare Helpline Report found that gambling addiction was overwhelmingly related to online gambling and that only 3% was in relation to AGCs. He reminded the Sub-Committee that only slot machines were permitted to be in operation in Bingo Halls after they closed.  He advised that the AGCs were well supervised, had machines which offered low stakes and that no alcohol could be consumed on the premises. Staff would be trained to observe patrons’ who exhibit a particular pattern of behaviour and to intervene when appropriate. There will be self -exclusion policies in place. 


The premises exterior had been designed in a style that was deliberately unattractive to children and young persons and reminded that there would be no video or arcade games available at the venue. The Applicants commented that Challenge 25 would be rigorously enforced, and that staff not adhering to this policy would amount to gross misconduct and termination of employment. The Sub-Committee was advised that Mr Hooper had reviewed information on 38 sites operated by the applicant and there had been 3767 requests for IDs and that on these occasions, 3083 had provided the requisite ID. The remainder of these checks, patrons were unable to provide the requisite IDs. Mr Wormald advised that there had been no events of patrons gambling without suitable IDs. The applicant operated AGCs in other London Boroughs which were located near schools and that there were no concerns with children and young people entering these Premises.


Mr Wormald said that the AGCs would not be attractive to individuals that are homeless. He advised that the Premises would have a spot camera and that patrons would need to request access to the premises when the doors are not being monitored by the door staff. There would always be a minimum of two staff member present at the premises and one of the employees would have 6 months experience of working in AGCs. Staff would be aware of the patrons that are present in the premises and would actively interact with these individuals.


The Applicant confirmed that they had been granted planning permission and allowed for its operation of usage to be until 02:00 and the objectors concerns regarding the overall amenity of the location is not a relevant consideration. The Sub-Committee were reminded that AGCs did not have any restrictions on their hours of operation and that 26 AGCs operated by the Applicant, were based in the capital and in various settings which include the High Streets and operated 24hrs. There have been no concerns regarding these premises.

Mr Wormald advised that the Applicant would be applying to disapply the Byelaw which currently restricts the Premises hours of operation. The Sub-Committee were informed that there were other licensed premises in the Borough which operated for 24 hours despite the Byelaw. 


The Metropolitan Police had been consulted. The Applicants emphasised that The Gambling Licensing Objectives Preventing Crime and Disorder had been addressed and that the Applicant operating until 06:00 would mitigate concerns. There had been a raft of conditions agreed with the Metropolitan Police and this included mandatory conditions. Mr Wormald commented that conditions which had been agreed included for a SIA registered Door Supervisor to be present after 18:00, for quarterly meetings to be held with the Metropolitan Police, comprehensive CCTV systems, a spotter monitor, Challenge 25 Policy, mag lock for the front shop door, two staff members to be present on the shop floor, the appointment of a staff member who had a minimum of 6months work experience in AGCs and extensive training for employees. He commented that these conditions would mitigate concerns regarding the Gambling Licensing Objectives.


The evidence submitted showed that the Applicant had first operated AGCs in 2007 and had acquired 19 centres in this year and 240 venues across the United Kingdom during the past 14 years. 38 of the AGCs were based in London and throughout the trading periods there had not been any complaints or an application to Review before a Licensing Sub-Committee.

In response to the Sub-Committee question, Mr Wormald stated that the Applicant did not operate any AGCs within the Borough. The Sub-Committee were also advised that the premises would have a range of machines and that there was sufficient space for them, and this include a bank of portable tablets. Mr Wormald advised that B3 machines will only make up 20% of the overall number of machines in the venue. He advised that portable tablets would be accessible to patrons and that individuals would not need to engage with staff when obtaining these devises. The portable devices could be used in any area of the premises and could be used in conjunction with other machines.  There will be seating areas for patrons using portable devices.

Counsel advised that there was increase demand for gaming machines in the later hours of the day and the customer based during these hours included shift workers from the hospitality sector. He advised that the later hours of trade were the busiest periods for AGCs and that patrons did not come from drink led establishments. The Sub-Committee noted that the Applicant had a wide range of experience in operating AGCs in the United Kingdom and commented that the objector’s concerns was about the unique characteristics of the proposed premise’s location. The Sub-Committee reminded the meeting that the Borough had one of the highest street populations in the country, and these included homeless persons, vulnerable adults and street drinkers. The Applicant confirmed that they did not have any premises in Westminster.


The Sub-Committee noted that representations had been made by a Homeless Shelter and that two Hostels were located near to the Premises. In response to questions from the Sub-Committee, Mr Hooper advised that it was Company Policy to refuse entrance to any individuals who were under the influence of alcohol or homeless. He acknowledged that it was not always clear whether individuals were homeless, and he advised that these persons were not permitted to congregate at premises. The Sub-Committee were advised that the Applicant were aware of the concerns regarding the premises location.


In response to questions from the Sub-Committee, Mr Thompson advised that he had policing experience in the Borough and informed that acquisitive crimes were not associated with gambling. He advised that staff members received extensive training and are required to ensure that stolen goods are not sold in the premises. The premises staff members would actively patrol the shop floor and interact with patrons. The Sub-Committee were advised that the premises door supervisor will be fully trained. Ms Speed added that the Applicant Company had traded prior to the Gambling Act 2005 and had extensive experience.  


PC Bryan Lewis confirmed that the Metropolitan Police Licensing Team was not objecting the application and that the Applicant had agreed to a raft of conditions. The representations had been made to assist the Sub-Committee with proposed conditions. In response to the Sub-Committee, PC Bryan advised that the Police would monitor the Premises to ensure that it was trading correctly, and that conditions imposed were fit for purpose. The Sub-Committee noted that the Premises Planning Application granted allowed the Premises operational hours to be until 02:00 and that the Metropolitan Police had agreed for operations to cease at 06:00. PC Lewis advised that 06:00 had been requested by the Applicant and this time was accepted due to the raft of conditions which had been agreed. These include for a door supervisor, the Premises having a lock door and extensive training for staff. In response to question from the Sub-Committee Mr Hooper advised that locks were fitted on all the doors of each Premises, and this was undertaken to enable staff to control who enters these venues. PC Bryan stated that AGCs were of a low concern and there were only occasional incidents involving these premises.

Kevin Jackaman, Licensing Authority, confirmed that representations had been maintained and this was in accordance with Policy AGC1. Policy AGC1 required the applications to be determined under the relevant criteria in policies OBJ1, OBJ2, OBJ3 and other relevant Licensing Principles for Gambling. Policy LOC1 had been included and this was due to the Premises location. He advised that Policy LOC1 defined a sensitive location as where a Premises is in close proximity to or main route to a school, education institution, hostel and there is potential exposure to children, young people, and vulnerable persons to gambling. Policy LOC1 needed to be considered due to the local area profile of the local area in which the premises was situated. He advised that within the vicinity there was a large number of alcohol licensed premises which attracted a wide range of age groups, and this included vulnerable persons.  The Sub-Committee were advised that the Applicant had agreed to a number of conditions following consultation with the Metropolitan Police on the aim of preventing gambling being a source of crime or disorder and these were welcomed.


Mr Jackaman stated that the Applicant had submitted information regarding vulnerability, signage, and training and these were included in the additional information that were submitted. The Applicant was reported to have submitted extensive documents about the operations of their AGCs Premises, operational procedures, training manual and signage. Mr Jackaman repeated that Applicant oversaw 240 AGCs nationwide. The Applicants had agreed with the OBJ3 Council Policy definition of a Vulnerable Person and that the Applicant had provided self-exclusion forms, their staff training guide on vulnerable persons and also contacts they will have with local services. There will also be displays of support agencies such as GamCare on the Premises. The Sub-Committee was advised that they would need to be satisfied that the Applicant met all the policy objections requirements of AGC1, the relevant criteria’s under OBJ1, OBJ2, OBJ3, and Policy LOC1.


In response to questions from the Sub-Committee Mr Jackaman advised that Policy LOC1 was relevant and that the premises locality was considered a ‘sensitive location’ due to the large number of licensed premises and high number of the homeless population near the Strand and Covent Garden. Mr Jackaman confirmed that the West End had a high level of crime and disorder in the locality. He further agreed that the layout of the premises was satisfactory and was of a suitable design to ensure the prevention of crime.

Richard Brown, Citizen Advice Bureau representing Covent Garden Community and Association, CGCA, confirmed that CGCA representation included an analysis of the Applicant’s Local Area Gambling Risk Assessment. That document was important and had been assessed by the CGCA and that the Amenity Society had used their expert local knowledge of the area when reviewing the document. Mr Brown reminded the Sub Committee that the Premises locality was a ‘unique area’ of the country and that the Risk Assessment, submitted by the Applicant was incomplete and did not include the relevant factors and therefore its conclusion was flawed.

Mr Brown added that the mitigations proposed in the Risk Assessment and the conditions offered did not meet the standards which would allow for the application to be granted. He went on to state that Licensed Betting Shops had been permitted to have four B2 machines before April 2019 and had stakes up to £100 and these had now been reduced. Licence Betting Shops could have four B2 machines with stakes up to £2 with a maximum prize of £500. Mr Brown commented that AGCs could have 20% of the total machines to be B3 Machines and these machines had the same stake and prizes of B2 machines. He commented that the differences between AGCs and License Betting Shop were now minimal, and this may have contributed to the decline of the latter. Mr Brown commented that the game play on B3 gaming machines were quicker than B2 machines.


On behalf of CGCA, Mr Brown made representations that the Council Policy indicated that gaming machines were potentially harmful to children and vulnerable persons. He added that mitigations which are put in place to address these concerns need to be suitable for the locations. The Applicant’s submission on measures put in place to protect under 18s were sufficient and could be easily implemented. However, there were concerns regarding the Applicants submission in relation to measures that would be put in place to address concerns with other vulnerable person such as homeless persons, individuals with mental health impairment and persons with substance dependency. These were inadequate and this was due to the premises locality. He advised that there were several hostels in the vicinity and that the locality attracted a high number of homeless persons who arrived throughout the day.


Mr Brown contended that gaming machines which are available throughout the day could cause harm to vulnerable persons and that the Applicant’s Risk Assessment had failed to sufficiently address these concerns. He commented that the initial mapping tool used in the production of the initial Risk Assessment had failed to acknowledge relevant Premises such as St Martins and the homeless centre at the Zimbabwean High Commission. This was a potential indicator as to why the risks to vulnerable persons had been assessed as low. Mr Brown then referred to the updated Risk Assessment, stating it was not an improvement and noted that the Applicant had failed to take into the CGCA submission when the document had been redrafted. He advised that the Applicant risk assessment regarding vulnerable persons continued to be low, despite strong evidence of the concerns regarding the area and its demographics. The Risk Assessment was found by the CGCA not to have grasped the issues and vague. The updated Risk Assessment did not go much further and found the potential harm to the vulnerable to be low.

Mr Brown noted that the Applicant’s training document was voluminous, and that staff were required to assess patrons’ age, vulnerability and observe patrons’ behaviour whilst using machines. He highlighted that homelessness was not always visible and commented that only two staff members would be present at the Premises and were required to adhered to a substantial raft of regulatory operations. There was a high concentration of homeless persons in the locality and Mr Brown noted that a SIA door supervisor would be present after 18:00. However, homeless persons frequented the area throughout the whole day.


Mr Brown also identified that B3 machines were located near the walls and patrons would be faced away from staff members. Employees would have to engage in conversations with individuals to distract them from the gaming machines.


Mr Brown informed the Members that there was a high level of crime in the vicinity and noted that the updated Risk Assessment stated that patrons found to be involved in criminal activities on the premises would be barred and that it was in the interest of the Applicant to implement this policy. There were a high number of licensed premises which offered alcohol in the area and reminded that the Cumulative Impact Zone, (CIZ) objectives was to ensure that patrons do not remain in the area. Mr Brown commented that the Premises was situated in a CIZ and highlighted the importance of joint working and local decision making. 


Mr Marcus Lavell of Keystone Law, representing Ms E Kwong, Inception Group and operators of Fogg’s Society of Exploration, would be calling witnesses, and this included Ms E Kwong and Mr S Padham (Witness for Mr R Sawhney, owner and operator of Speciality Drinks). Mr Sawhney was unable to attend the Sub-Committee. Mr Lavell commented that the large amount of evidence which had been provided by the Applicant were based on national statistics and indicated the lack of experience of operating premises in the Borough. He agreed that the premises was situated in a ‘unique location’ and that the Sub-Committee were aware of the concerns regarding the area. The locality had the highest saturation of alcohol licensed premises in the country. He reminded the Sub-Committee that the West End CIZ had been implemented to ensure that crowds do not remain in the locality and that those under the influence of alcohol are not victims of crime or cause public nuisance. Mr Lavell expressed concerns regarding patrons entering the premises during the latter hours whilst they were intoxicated. He commented that the view that the majority of patrons visiting the premises during the latter trading hours would be commuters was flawed.


In response to questions from Mr Lavell, Ms Kwong informed that she worked next door to the proposed premises and advised that there was a large concentration of homeless individuals and vulnerable persons in the locality. Her premises was affected by this demographic and these persons would position themselves at the doorway of her establishment. Her premises had implemented several measures to ensure homeless persons are identified and prevented from congregating near the venue. This included employing Designated Premises Supervisor (DPS) and SIA Door Supervisors and having regular staff training. 19 staff Members are present during shifts and commented that only two staff members would be present at the proposed AGCs and part of their roles included monitoring and controlling vulnerable persons.


In response to questions from the Sub-Committee, Ms Kwong advised that alcohol was sold at her establishment and the Premises operational hours were between 18:00 to 02:00. However, all patrons entering her premises were closely monitored and assessed by all staff members. The Sub-Committee was advised that patrons who are under the influence of alcohol are refused further sales and requested to leave the Premises. Staff would enquire whether patrons needed an Uber Taxi.  Mr Lavell informed the Sub-Committee that there were not always visible signs that an individual was under the influence of alcohol and that there were concerns that these persons would be unable to make informed decisions and that there was a large concentration of such individuals in the area.


Mr S Padham informed the Sub-Committee that he operated a homeless Charity for 12 years in the locality. Over 3500 meals were served per week to the homeless and that these individuals were engaged with regularly. Mr Padham stated that the homeless population had increased over the past decade and commented that not all individuals in these demographic displayed signs of homelessness. In response to questions from the Sub-Committee, Mr Padham confirmed that his Charity had chosen to operate in the locality due to the high concentration of homeless people.  Homeless individuals who are given donations would inevitably seek to increase the amount and he stated that that AGCs would be a method of achieving this. Mr Padham commented that gaming machines with low level stakes would be appealing to vulnerable persons. The Homeless persons had an excellent grasp of the area and were aware which locality they were likely to receive donations and obtain shelter. Mr Padham advised that Bedford Street attracted a large number of homeless individuals and commented on the importance of protecting vulnerable individuals.   


The Sub – Committee adjourned at 11:21 and resumed at 11:25


David Kaner, Chair of Covent Garden Community and Association CGCA, advised that there was historically a large homeless person and rough sleepers’ population in the vicinity and in particular near the Strand. Individuals from across the capital were attracted to the area and this was due to the large number of services that were available in the area for vulnerable persons and good opportunities for obtaining donations. There had been an increase in the homeless population following the post Convid-19 Pandemic lockdown. He advised that homeless persons requested cash donations and would seek to increase the amount which were gifted. AGCs would be of attraction for these individuals who wanted to increase the donations that had been received. The Sub-Committee were reminded that individuals did not always present as homeless and commented that gambling was more prevalent in this demographic in comparisons to other groups. Mr Kaner felt that these aspects needed to be considered by the Sub-Committee and commented that the Applicant’s ‘scope mapping tool’ did not adequately take these factors into consideration.

Mr Kaner informed the Members that residents regularly interacted with homeless persons and would sign post individuals to appropriate agencies rather than give cash donations. There were concerns regarding the premises operational hours and commented that extended opening hours would encourage individuals to remain in the vicinity. Representations were usually maintained for any licence application which sought to operate 24hrs and this was due to concerns regarding the CIZ. Mr Kaner agreed that the Premises having a capacity limit and reduced operational hours would be welcomed and this would ensure the number of persons entering the Premises are restricted and would help to mitigate concerns that have been raised.  

The Legal Officer advised that there were no restrictions preventing an application for a 24 hr AGCs operation, and the site could trade as such. The Sub-Committee were advised by Leading Council for the Applicant that they could impose conditions which could restrict the premises operational hours and that the Applicant was also required to comply with the Byelaws that were in place.


In response to questions from the Sub-Committee the Policy Officer advised that the application needed to be considered under the Location Policy and whether the area it was situated was ‘sensitive’. The Policy Officer noted that the Licensing Authority and other objectors had raised concerns regarding homeless persons and informed that these demographics were considered as vulnerable. The Sub-Committee were informed that this demographic had a 11.6% higher risk factor than the national average. Mr Kaner advised that the gambling addiction was 20 times higher in the homeless population than in any the other groups.


In response to the Policy Officer, Mr Hooper advised that B3 gaming machined were physical machines and that 60% of patrons preferred to be sat down whilst in front of machines. He advised that there would be adequate space to allow patrons to be positioned in-between the B3 machines and that the layout of the Premises and accessibility of machines all complied with the Gambling Commission requirements.


Mr Brown advised that the Premises was situated in a sensitive area and that the Sub-Committee was required to consider the suitability of the proposed AGCs location. He advised that there had been no evidence provided on how the Applicant would protect vulnerable persons apart from children. Mr Brown noted that the premises operated as a Betting Shop previously and had several B2 machines. He commented that 20% of the overall machines would be B3 in the new Premises and these machines had the same stakes and prizes as B2. Mr Brown reminded the Sub-Committee that Planning Permissions should not be taken into consideration and that AGCs were permitted to operate 24hrs. He advised that the premises terminal hour should be 22:00 and commented that the previous Betting Licence Shop ceased trade at this hour. Mr Brown commented that concerns regarding vulnerable persons would still not be mitigated with the premises operations ceasing at 22:00 and that the application should be refused.    


PC Lewis advised the Sub-Committee that the Applicant could be requested to undertake a risk assessment on whether a SIA Door Supervisor was required during the daytime.  He advised that a condition should be imposed which require for a SIA Door Supervisor during the daytime for the first six months of trade and this would allow employees to settle in and demonstrate to children and vulnerable persons that there is an active entrance policy in place. 


Mr Wormald QC reminded that there were nearby premises which had very large capacity, served alcohol and operated until 02:00. He acknowledged that the premises was in a sensitive area and commented that the Metropolitan Police were content with the application. Mr Wormald highlighted that it had been reported that AGCs were of a low concern to the Metropolitan Police Licensing Team. He advised that the Applicant had various AGCs in city centres of several cities located in Northern England. He commented that in Manchester there was a high homeless population, vagrancy and high usage of prohibited substances and these factors were also prevalent in the other Cities. Mr Wormald advised that the AGCs in Manchester Piccadilly was several floors and housed 350 machines and was situated next to soup kitchens and hostels which are overseen by charities. It was further submitted that there had been no concerns from the Manchester Police, retail outlets or charities about the Premises. The Sub-Committee was advised that there were staff reports and weekly security reports produced, and no concerns raised about the AGCs proximity to the homeless population. 


Mr Wormald advised that patrons who entered the premises with large or small number of coins or wish to exchange coins for notes are viewed as a ‘potential problem’ and are challenged. He advised that there was no evidence regarding concerns with homeless persons and commented that public houses also had gaming machines. The Sub-Committee noted that there were no AGCs or similar premises in the vicinity and the effects of these venues in the locality were unknown. In response to questions from the Sub-Committee, Mr Wormald advised that it was preferred for operational hours to cease at 06:00 and commented that violent crimes and other anti-social behaviour were alcohol led.


Mr Wormald confirmed to the Sub-Committee’s Legal Adviser that the previous Premises Licence for William Hill had been surrendered in 2019.



The Sub-Committee has determined the application for a grant of a new Premises Licence under The Gambling Act 2005


Having carefully considered the committee papers, including the additional evidence and the submissions made by all the parties, both orally and in writing, the Committee has decided, after taking into account all the individual circumstances of this case and the licensing objectives: - 


The Sub-Committee are aware, as were the Applicants, of policies LOC1, OBJ3 and the sensitivities of the premises location given the concentration of vulnerable groups in the area including the street population attracted by, but not exclusively to, the nationally famous St Martins in The Field Charity and their excellent outreach organisations and other charities.


The Sub-Committee noted that there were 30 educational establishment, 14 places of worship and hundreds of licensed premises in the immediate vicinity as identified in the Applicant’s own submissions and evidence. The Sub-Committee noted these establishments may add, attract, and create vulnerable adults as well as attract or add children to the vicinity.

The Sub-Committee acknowledged that Greater Manchester, Leeds, and Birmingham also have concerns in relation to their locality and that the Applicants have traded in those areas without issue. However, it was noted that those areas did not have the concentration of vulnerable groups as seen in the capital and in particular in the vicinity of the Strand.  This area attracts a street population from across London, United Kingdom and further afield. Furthermore, each case is decided on its own merits.


The Sub-Committee noted that the risk assessment specific to this sensitive location was included in support of the application, as required by the Gambling Commission Social Responsibility Code. However, the evidence did not give the Sub-Committee confidence that the risk to children and other vulnerable persons, considering the location of the premises, had been addressed adequately.


The Sub-Committee accepts that Novamatic and the Admiral Brand are reputable Companies which have comprehensive procedures to mitigate the risks associated with the first two of the 2005 Act Licensing Objectives, namely addressing Crime and Disorder and the Fairness of Gambling.  The Sub-Committee accepted that there was some mitigation in place to protect children and the vulnerable.


However, the Sub-Committee did not have confidence that the risks to children and other vulnerable persons from being harmed or exploited by gambling had been suitably mitigated, given the written and oral evidence and the compelling evidence presented by the objectors to the Application.


Thus, the Sub-Committee rejected the Application.



Supporting documents: