Appendix
A1
Statement of Exceptional Circumstances in Support of Late Night Refreshment
Licence Application
Applicant: London Export
and Import Ltd
STATION
GRILL
Premises: 62
Queens Road, Brighton BN1 3XD Business Type: Mixed
Egyptian and Turkish
Cuisine
This
statement is to demonstrate exceptional
circumstances for our Late Night Refreshment Licence application:
1. Consultation with and Meeting
Requirements of Responsible Authorities
We are committed to working closely
with responsible authorities, including Sussex Police, Environmental Health, and Licensing
Officers. We have proactively consulted with these bodies to ensure our operation meets all public
safety, nuisance prevention,
and public order standards. Any specific concerns raised during the application
process will be addressed swiftly and appropriately.
2. Corporate Social
Responsibility (CSR) Policy
Our business
upholds a clear Corporate Social Responsibility (CSR) approach. We aim to:
·
Employ local residents, offering
fair pay and safe working
conditions.
·
Implement robust waste management procedures to minimise
litter and maintain street
cleanliness.
·
Provide staff training in responsible service
and conflict resolution.
·
Ensure
the premises remain a safe and respectful environment for customers and
neighbours.
3. Community Contribution to Offset Impact
We are willing to contribute to the local community in ways that mitigate the impact of late-night trading. This
may include:
·
Financial support
or partnership with local schemes
(e.g. street cleaning
or CCTV).
·
Keeping the immediate area clean and monitored by staff.
·
Providing litter
bins outside the shop and regularly cleaning
the frontage.
4. Community Support
We have received
positive feedback from local residents
and businesses who see value in having a reliable, clean,
and safe food outlet open late, especially for workers and visitors in the
area. We are collecting letters of support, which can be made available upon
request. Furthermore, we have received emails along with the local authority
and the police supporting our application.
5.
Alcohol
Sales Ancillary to Primary Business Activity (NOT applicable
While our main business of our restaurant is the preparation and sale of hot food,
we have no intention at all to sell alcohol either now or in the future.
6- The following licensing activities are encouraged and valued by the licensing authority:
outdoor regulated
entertainment, community-based street parties, members clubs, traditional pubs outside
the city centre and non-alcohol led licensable
activities (which is our case as being a restaurant), particularly
within city centre.
Restaurants - the
licensing authority may be prepared to look favourably upon an application for
the grant of a licence, subject to the agreed conditions.
Furthermore:
Prevention of Crime and
Disorder
The data set used shows that up to 80% of arrests
made in the timeframe
20:00 – 06:00 on these days were affected by alcohol
and not hot food providers. For full details of these statistics see the Cumulative Impact
Assessment at Appendix E.
7- we will be a member of:
Business Crime Reduction Partnership and
other approved schemes, The BCRP NightSafe radio scheme, pub-watch schemes,
and/or any accredited scheme.
8- I am SIA door supervisor:
The policy recognises the use of registered Door
Supervisors All Door Supervisors will be licensed by the Security Industry
Authority. We will use Mobile security units or similar systems which are in
use by some premises operators as a means of providing security cover at very
short notice at premises which may not normally require a permanent security presence. This policy endorses
the use of units
following such guidance and standards in appropriate circumstances.
9- we will display
prominent, legible signs at exits reminding customers to leave in a
quiet, peaceful, orderly manner.
10- we will install a digital
CCTV system by liaison with, and to a standard
approved by, Sussex Police.
11- policies for dispersal
of customers which may include signage regarding taxi
services’ telephone numbers and advice to respect neighbours and minimize
noise.
12- we will be:
·
A
membership of Business Crime Reduction Partnership, Pubwatch, Neighbourhood
Watch or similar schemes
·
use of ‘Night Safe’
radio system or similar accredited scheme
·
regular
training and reminders for staff in respect of licensing legislation, policies
and procedures; records of which should be properly recorded and available for
inspection
·
systems
in place to ensure details of barred clients are exchanged with other operators
·
giving
an agreed minimum notice of special events (screening of major sports events,
birthday parties, adult entertainment, etc.) to relevant authorities and use of
appropriate additional measures at such events.
Conclusion
We respectfully request that our
application be considered under these exceptional circumstances. We are confident that our approach
demonstrates a strong commitment to responsible business
operations, community engagement, and minimising any negative impact associated
with late-night trading.
Yours sincerely REDACTED
London Export and Import LTD
28/06/2025
Second statement of exceptional circumstances
Dear sir / madam,
Just to confirm that we believe
our application should
be considered as exceptional
circumstances because of:
1-
the operation
of this premises will not negatively add to the cumulative impact in the area and that exceptional
circumstances do exist.
2-
Exceptional Circumstances Apply SoLP states that:
3- 1.9 Furthermore,
this special policy is not absolute. Upon receipt of a relevant representation, the licensing authority
will always consider
the circumstances of each
case and whether there are exceptional circumstances to justify departing from
its special policy in the light of the individual circumstances of the case. If an
application is unlikely to add to the cumulative impact of the area, it may be
granted. The impact can be expected to be different for premises with
different styles and characteristics. For example, while a large nightclub or
high capacity public house might add to problems of cumulative impact, a small restaurant, theatre or live music venue (where
alcohol is not the primary activity) may be considered exceptional
circumstances. And we are operating as a
small restaurant, so we should be considered exceptional circumstances.
Notes on matrix as per SoLP
Subject to
the following notes, the policy, as represented in the matrix, will be strictly
adhered to:
5-
Exceptional
circumstances may include: consultation with and meeting requirements of
responsible authorities ( WE ARE HAPPY TO CO-OPERATE
WITH THE POLICE AND ACCEPT POLICE PROPOSED CONDITIONS, INCLUDING INSTALLING CCTV,
AND I WILL BE A SIA DOOR SUPERVISOR AND have a
CONTRACT WITH MSU), an
appropriate corporate social responsibility policy( MY plan
showing how my business will act responsibly and support the local community
for example, Hiring local
staff, Reducing noise or litter Offering
discounts to NHS workers and students, Sponsoring local events or charities
and I mentioned all of that in my supporting documents which are attached and during the application process),community contribution to offset impact (such
as financial contribution to infrastructure)( I will be offering
something to compensate for any potential negative
impact such as Help fund extra street cleaning, Install outdoor bins, Contribute to a community safety scheme (like CCTV on
the street). community
support (the licensing team and myself have received
too many witness statements from the local residents, customers and neighbours
to support our application and they confirmed my premises is
beneficial, our shop will help
keep the area safer, They prefer regulated food
options, our business provides a good community service as per their emails and
letters),alcohol sale ancillary to business activity (demonstrable
to responsible authorities and licensing authority, for instance by licence
condition allowing authorised officers access to sales accounts)(we will NOT
sell alcohol
at all and this should make our case stronger in
the CIZ and be considered as exceptional circumstance)
The following licensing
activities are encouraged and valued by the licensing authority: outdoor
regulated entertainment, community-based street parties, members clubs,
traditional pubs outside the city centre and non-alcohol led licensable
activities, particularly within city centre (which is
our case a restaurant in the city centre).
Our premises
is:
·
Non-alcoholic
·
Food-focused
·
Small in size
·
Willing to accept licence
conditions
·
Committed to hiring trained
staff and implementing public safety measures
I mentioned
all of that in my submitted documents
during this application
process.
Given the distinction between this operation and typical late-night venues
in the area, I strongly
believe that this application
meets the criteria for exceptional circumstances. Its presence will not increase
disorder, and may instead help reduce
it.
The statement of
licensing policy (SoLP) states that, ‘if an application is unlikely to add to the cumulative impact of an area, it may be granted. The impact can be expected to be different
for premises with different styles
and characteristics’. And it does not give to what extend and
what percentage, it says unlikely, and we believe that this application will
not negatively add to the cumulative impact in the area and that exceptional
circumstances do exist.
1. Support for a Non-Alcohol, Food-Only Operation
This premises is applying only
to provide hot food and soft drinks, with no alcohol, no music, and no
entertainment. Its business model is focused on collection and delivery only
after midnight. This is clearly different in nature from most late-night
venues in the area, many of which serve alcohol and contribute significantly to
anti- social behaviour.
I believe that a well-lit, monitored, food-only outlet
in this area is more likely
to reduce crime and disorder
2. Public Safety and Night-Time Economy
As
a local business owner, I have first-hand experience of the
Queens Road area during late hours.
The reality is that people will still be moving through this part of the city after midnight
— either from the train station, bars, or workplaces —
regardless
of whether food is available or not. Especially there is a late night
refreshment premises REDACTED
provides a different cuisine
and they are open till 03:00 am. This make it unfair
competition.
Disparity and Possible Discrimination
It is unfair and possibly discriminatory
that a neighbouring takeaway REDACTED is allowed to trade until 03:00 am, while
Station Grill is being prevented from doing the same. If the only difference is
that the other shop has been there longer or the owner is older, that should
not entitle them to more favourable treatment. Station Grill’s manager is
younger but just as responsible, experienced, and capable, and he deserves a
fair chance to operate on equal terms.
Human Rights
and Fair Treatment
It is important to note that the Licensing
Policy itself acknowledges the relevance of the
Human Rights Act 1998, including:
·
Article 1 of the First Protocol, which protects the right
to peaceful enjoyment of possessions, including the right to operate a lawful
business without unfair restrictions.
In this case, I believe that refusing or discouraging
Station Grill’s licence application, despite its high standards, responsible
management, and very high public demand, could be seen as a breach of these
rights, especially when a neighbouring business, REDACTED is allowed to operate
until 3:00 am under similar circumstances.
Every business owner—regardless of age
or how long they’ve been trading—should be treated fairly, with decisions based
on evidence and merit, not on
arbitrary factors. Station Grill meets every reasonable expectation of a
responsible, safe, and valuable late-night food venue, and should therefore be
given equal opportunity to trade.
We believe it is resident’s right to have access to a variety
of late-night refreshment
providers. Denying a late-night refreshment licence to new businesses
effectively limits their choices and compel them to purchase from a small
number of long-established shops that were granted such licences many years
ago.
This
practice raises concerns
of unfair discrimination, as it allows
existing licence holders to continue trading late into the night while
new businesses are excluded from the same opportunity. Such a policy
disproportionately favours older establishments and individuals who were able
to open their businesses in the past, while disadvantaging newer business
owners—often younger entrepreneurs—who are now being denied access to the same
trading rights.
·
For
instance, the premises at REDACTED is permitted to trade until 3:00 AM.
Meanwhile, Station Grill has been refused a comparable licence,
placing it at a clear competitive disadvantage.
We believe this situation undermines the principles of fairness and equal
opportunity. Every lawful business should be granted the ability to operate
under the same regulatory conditions, without arbitrary restrictions. Equal
access to trading rights is not only a matter of economic justice but also a
basic human right.
By providing a controlled location
where people can safely pick up food, we are in fact supporting
the safe dispersal of people, not hindering it. Having a small,
professional premises open with security measures is a better alternative than leaving the area with no
regulated food options.
3. We have Taken Reasonable Steps
I understand the concerns raised by Sussex Police and Licensing, but I also have
taken significant steps to comply:
·
Offered to operate as collection, takeaway
and delivery only after midnight no eat-in service.
·
I
am SIA-licensed door supervisor. I intended to be at the premises every night especially busy nights working
exclusively as a door supervisor.
·
Proposed to install CCTV,
external lighting, and digital order-only systems.
·
Committed to maintaining a clean, quiet,
and professional premises.
Any uncertainties raised
about experience or understanding should be
weighed against the practical steps I am willing to take — and many of those could be resolved through clear
licence conditions, co-operation and compliance checks, rather than outright
refusal.
Regards Station
Grill REDACTED 05/07/2025
Third statement of exceptional circumstances
Dear sir / madam,
Just to confirm with our previous
statements that we believe our application should be considered as exceptional
circumstances because of:
According to Statement of Licensing Policy
in Brighton and Hove:
1.
‘Furthermore,
this special policy is not absolute. Upon receipt of a relevant representation, the licensing authority will always consider
the circumstances of each case and whether there are exceptional
circumstances to justify departing from its special policy in the light of the individual circumstances of the case. If an application is unlikely to add
to the cumulative impact of the area, it may be granted.
The impact can be expected to
be different for premises with different styles and characteristics. For
example, while a large nightclub or high capacity public house might add to
problems of cumulative impact, a small restaurant,
theatre or live music venue (where alcohol is not the
primary activity) may be considered exceptional
circumstances. The fact that a
premises will be/is exceptionally
well managed with a well- qualified applicant, or that there are no residential
premises nearby, will not be considered exceptional.’
And
we confirm that our premises is a small restaurant and we will NOT sell alcohol
at all.
2.
Notes on
matrix-
5) Exceptional circumstances may include:
consultation with and meeting requirements of responsible authorities, an
appropriate corporate social responsibility policy, community contribution to offset impact
(such as financial contribution to infrastructure), community support, alcohol
sale ancillary to business activity (demonstrable to responsible authorities and licensing authority, for instance by licence
condition allowing authorised officers access to sales accounts).
This is our evidence
to support Station Grill’s premises licence application, addressing and
aligning with the policy’s definition of exceptional circumstances under paragraph 5 of the Notes on Matrix from
Brighton & Hove City Council’s Statement of Licensing Policy:
These are our supporting evidence that Station
Grill meets the criteria for exceptional circumstances as defined in
paragraph 5 of the Brighton & Hove Statement of Licensing Policy.
1. Consultation with and Meeting
Requirements of Responsible Authorities
·
I am happy to co-operate with Sussex Police and the Council’s Licensing Authority to discuss any
concerns, and I sent them many emails asking them
to contact me if they have
any concerns and require me to discus it or if they want to mitigate any
issues.
·
Security
measures have been incorporated into the operating schedule, including:
o Installation
of a full digital CCTV system covering entry, till, and customer areas.
o
Staff training
on licensing laws, and conflict
management.
·
We
are happy to discus and agree to adopt all proposed conditions from responsible
authorities to ensure full compliance with the four licensing objectives.
2. Corporate Social
Responsibility (CSR) Policy
·
Station Grill’s
CSR policy includes:
o Hiring
locally to
provide employment opportunities to Brighton residents.
o Staff
training programmes focusing on food safety, health and hygiene,
conflict management.
o Minimising
waste and
reducing single-use plastics by switching to biodegradable packaging and
compostable containers.
o
Commitment to community safety, including regular
litter patrols.
o Inclusivity
policy ensuring
a welcoming and safe space for all customers regardless of background or
status.
o Hiring local staff,
Reducing noise or litter Offering discounts
to NHS workers and students, Sponsoring local events or charities
and I mentioned all of that in my supporting documents which are attached and
during the application process.
3. Community Contribution to Offset Impact
·
The
business has invested in improving the shop and external lighting,
contributing to the vibrancy and safety of the surrounding area.
·
I
will be committed to working with local community safety
officers and is open to a voluntary financial
contribution or collaboration with community initiatives (e.g., waste
collection or anti-litter campaigns).
·
We are willing to engage in voluntary participation in local business
groups
or city council-led community
safety partnerships.
·
I will be offering something
to compensate for any potential negative impact such
as Help fund extra street cleaning,
put outdoor bins, Contribute to a community safety scheme (like CCTV on the
street)
4. Community Support
·
Over
30 written witness statements have been received from nearby residents,
local workers, and business owners, showing broad community support for
Station Grill and its contribution to the neighbourhood.
·
The statements confirm that the premises is not a source of antisocial behaviour and is seen as a positive,
well-managed food establishment.
·
Local
support reflects trust in the business and recognition of its role in enhancing
evening food options without encouraging late-night disturbance.
·
the licensing team and myself have received over 30 witness
statements from the local residents, customers and neighbours to support our application and they confirmed my premises is beneficial, our shop will help keep the area safer, They
prefer regulated food options, our business provides a good community service
as per their emails and letters.
5. Alcohol Sale Ancillary to Business Activity
·
Alcohol will NOT be
sold at all
·
We are prepared to accept licence
conditions in general.
·
The
menu and pricing structure further emphasise the food-led nature of the
business, NO ALCOHOL SALE AT ALL.
·
we will NOT sell alcohol at all and this should
make our case stronger in the CIZ and be considered as exceptional
circumstance)
Conclusion
The evidence presented
above demonstrates Station Grill’s clear alignment with the Licensing Authority’s definition of exceptional circumstances. The business does not pose a risk of adding to
cumulative impact and is committed to operating responsibly, with
strong community support and full engagement with regulatory
standards.
We respectfully request the Licensing
Committee to consider
this evidence when determining our application.
Kind Regards
REDACTED
Station Grill
09/07/2025
SIA License Door Supervisor
Dear sir / Madam,
Just to let you know that, I have received my SIA License
now.
And
I will be available to work and present in the restaurant as much as I can as a
door supervisor exclusively in all busy nights at Station Grill. With no other
duties at all during working at these nights as a door supervisor.
Please accept this as a confirmation that I am taking a
serious and important steps towards
this premises license
to promote the 4 license
objectives, and I am aware of
all challenges that may be in CIZ
including data about crimes may be existing in the area whether it is related
to ALCOHOL or not, and to confirm that I understand fully
the statement of license policy,
have the required
experience as being working in the late night kebab
shop for over than a year and understand late night economy, and the challenges associated in the late
night economy.
I think this was confirmed
through my practical steps that I am taking and willing to take, plus over 30
witness statements that all of us received from the community and validated by
the licensing team.
Please note that, any uncertainties raised about experience or understanding should be weighed against
the practical steps
I am willing to take
— and many
of those could be resolved through clear licence conditions, co- operation and
compliance checks, rather than outright refusal.
Please find attached letter
from SIA. Regards
