REP A

Emily Fountain

Licensing Team

Brighton & Hove City Council

Bartholomew House

Bartholomew Square

Brighton

BN1 1JP

Date:

Our Ref:

e-mail:

19 August 2025

2025/02177/LICREP/EH

donna.lynsdale@brighton-hove.gov.uk

Dear Emily Fountain

Licensing Act 2003

Representation in support of an application by Sussex Police seeking a review of the Premises License - 2025/06905/LAREV

Zaf'ron Limited, 99 North Road, Brighton BN1 1YE

I am making a representation on behalf of the Council’s Licensing Team, in their capacity as a responsible authority, in relation to the above application made by Sussex Police seeking to review the Premises Licence for Zaf'ron, 99 North Road, Brighton BN1 1YE.

This representation is made as the Licensing Team have concerns that the licensing objective of the Prevention of Crime and Disorder and the Prevention of Public Nuisance are not being upheld.

The history of this matter is explained in more detail in the application of Sussex Police.

On 17 November 2023 at 23:49, accompanied by Police Licensing we visited the premises. At the time of this visit the premises was open and taking orders via delivery websites without a Late-Night Refreshment Licence. On 23 November 2023 I wrote to the premises and issued them a warning for trading without a Late-Night Refreshment Licence. A copy of my email is attached as Appendix A.

On 18 June 2024, an application was received from Zaf’ron Limited applying for a new premises licence for Late-Night Refreshment.

On 3 August 2024, during Pride weekend, a visit was carried out by Sussex Police, where they found the premises open and trading without a LNR licence. On 13 August, I sent a further warning letter for carrying out unauthorised licensable activities without a valid premises licence. A copy of my email is attached as Appendix B.

On 20 August 2025 a licence panel hearing was held following representations on behalf of the Licensing Team and by Sussex Police Licensing regarding the application made by Zaf’ron Ltd. A copy of the Decision letter is attached as Appendix C.

Following the grant of the premises licence and a subsequent appeal, conditions were added to the premises licence.

On 9 January 2025, accompanied by Police Licensing, I visited the premises and carried out a full licensing inspection. On 13 January 2025, I wrote to the PLH detailing the breaches found. A copy of my email is attached as Appendix D.

On 6 February 2025, I wrote to the PLH again following complaints received from local residents and including evidence that they were trading past their permitted hours. A copy of my email is attached as Appendix E (which includes a response from the PLH and further email from myself.

On 11 February 2025, I resent my email to the current PLH as I was informed that on 1 February 2025, a change of Director was updated on Companies House. A copy of this email is attached as Appendix F (which includes follow up emails and response from the PLH).

On 9 June 2025, I wrote to the PLH again following complaints received from local residents. A copy of this email is attached as Appendix G (which includes a response from the PLH).

These premises fall within the Licensing Authority’s Cumulative Impact Area (CIZ), which was adopted to give greater power to control the number of licensed premises within the city’s centre. The SPCI was introduced because the Licensing Authority determined that the concentration of licensed premises and the subsequent numbers of people drawn into the city centre is causing exceptional problems of crime and disorder and public nuisance.

The effect of the SPCI is that applications for variations of premises licences, which are likely to add to the existing Cumulative Impact, will be refused following relevant representations. The applicant can rebut this presumption of refusal if they can show that their application will have no negative cumulative impact on licensing objectives, including prevention of crime and disorder and public nuisance.

It is my opinion that this premises has clearly demonstrated that they are not operating to the conditions attached to the premises licence. Continue to trade past their permitted hours and based on the number of complaints received are causing a public nuisance to the surrounding residents. I have no confidence in the management of the running of the premises.

The Licensing Team fully support the application submitted by Sussex Police and invite the panel to revoke the premise licence.

Yours sincerely

REDACTED

Donna Lynsdale

Licensing Officer

Licensing Team

Appendix A – Email sent on 23 November 2023.

Appendix B – Email sent on 13 August 2024.

Appendix C – Copy of Decision letter following grant of premises licence.

Appendix D – Email sent on 13 January 2025 following licensing inspection.

Appendix E – Email sent on 6 February 2025 following complaints received and evidence of trading

past permitted hours.

Appendix F – Email sent 11 February 2025 to current PLH.

Appendix G – Email sent 9 June 2025 following further complaints received.

REP A - Appendix A

From: Donna Lynsdale
Sent: Thursday, November 23, 2023 11:29 AM
To: REDACTED; REDACTED
Cc: Brighton.Licensing@sussex.police.uk
Subject: Unauthorised Licensable Activities - Zaf’Ron, 99 North Road, Brighton BN1 1YE - 2023/02848/LICENQ/EH
Importance: High

Dear REDACTED and REDACTED

Licensing Act 2003 - Unauthorised Licensable Activities

Zaf’Ron, 99 North Road, Brighton BN1 1YE

I am writing to you following a visit to your premises accompanied by Mark Thorogood, Police Licensing on Friday, 17 November 2023 at 23:49. 

At the time of our visit, your premises was open and taking orders via delivery websites without a Late-Night Refreshment Licence.  

Supply of Late-Night Refreshment is a licensable activity under the Licensing Act 2003.  Any hot food or hot drink sold between 11pm and 5am is classed as the licensable activity of supply of Late-Night Refreshment.

It is an offence under the Licensing Act 2003, S136(1) and (4) to carry on unauthorised licensable activities.  The legislations states that:-

(1) A Person commits an offence if –

   (a)   he carries on or attempts to carry on a licensable activity on or from any premises otherwise than under and in accordance with an authorisation, or

   (b)   he knowingly allows a licensable activity to be carried on. 

(4) A person guilty of an offence under this section is liable on summary conviction to imprisonment for a term not exceeding six months or to an unlimited fine, or to both.

If you continue to trade without a Late-Night Refreshment Licence past 11pm, then this may be taken into consideration if you submit any application in the future.

Please note this Authority and Sussex Police have officers monitoring the City both day and night and we will be monitoring the premises.  If it is witnessed that your premises is carrying out further unauthorised licensable activities, then enforcement action will be taken.

I have copied Police Licensing into this email.

Please acknowledge receipt of this email.    When responding please reply to all.

Yours sincerely

Donna Lynsdale| Fair Trading Officer & Licensing Officer (Trading Standards & Licensing), Safer Communities

Brighton & Hove City Council, 2^nd Floor, Barts House, Barts Square, BN1 1JP

T REDACTED | REDACTED

REP A - Appendix B

From: Donna Lynsdale
Sent: Tuesday, August 13, 2024 10:06 AM
To: REDACTED

Cc: Brighton.Licensing@sussex.police.uk
Subject: Unauthorised Licensable Activities - Zaf’Ron, 99 North Road, Brighton BN1 1YE - 2024/02010/LICENQ/EH
Importance: High

Dear REDACTED

Licensing Act 2003 - Unauthorised Licensable Activities

Zaf’Ron, 99 North Road, Brighton BN1 1YE

I am writing to you in your capacity as the owner and sole Director Zaf’ron Ltd of the above premises.

I have been informed that Sussex Police visited your premises on 3 August 2024 at 23:50. At the time of this visit, they advised that on approaching the premises staff were seen to be rushing to close the shop insisting that they had closed already.  However, they could see that food was still being cooked on the grill and the sign on the door indicating the premises was open.

It is an offence under the Licensing Act 2003, S136(1) and (4) to carry on unauthorised licensable activities.  The legislations states that:-

(1) A Person commits an offence if –

   (a)   he carries on or attempts to carry on a licensable activity on or from any premises otherwise than under and in accordance with an authorisation, or

   (b)   he knowingly allows a licensable activity to be carried on. 

(4) A person guilty of an offence under this section is liable on summary conviction to imprisonment for a term not exceeding six months or to an unlimited fine, or to both.

In light of the above, I am issuing you with a Warning.

The above is very disappointing as previous warnings have been sent for trading without a Late Night-Refreshment Licence.  Please be advised that I will be submitting a copy of this email and requesting that it is taken into consideration at the licensing hearing on 20 August 2024 to decide on your application.

I have copied Police Licensing into this email.

Please acknowledge receipt of this email.    When responding please reply to all.

Yours sincerely

Donna Lynsdale| Fair Trading Officer & Licensing Officer (Trading Standards & Licensing), Safer Communities

Brighton & Hove City Council, 2^nd Floor, Barts House, Barts Square, BN1 1JP

T REDACTED | REDACTED

REP A - Appendix C

Licensing Panel hearing held on Tuesday 20 August 2024 virtually in respect of the application for a Late-Night Refreshment Licence for Zaf’ron, 99 North Road, Brighton, BN1 1YE

The panel has read all the papers including the report and relevant representations and listened to the submissions put forward at the hearing. The panel has also had regard to the council’s Statement of Licensing Policy (SOLP) and the section 182 Licensing Act 2003 statutory guidance.

The application is for a new Late Night Refreshment Licence authorising the sale of hot food and drink to members of the public between 23.00 and 03.00 hours every day.

The premises are situated within the Cumulative Impact Area (CIA). This is an area where the council has determined that the concentration of licensed premises in an area of the city centre is causing problems of crime and disorder and public nuisance, and that an approach to “Cumulative Impact” is necessary as part of its SOLP. That approach provides that applications for new or varied licences in the CIA which are likely to add to the existing Cumulative Impact will be refused following relevant representations. The presumption of refusal can be rebutted if the applicant can show that their application will have no negative Cumulative Impact.

A “matrix” approach to licensing decisions has been adopted by the council in its SOLP. It sets out a framework of what the licensing authority would like to see within its area and gives an indication of the likelihood of success to any applicant. The matrix suggests that Late Night Refreshment Licences will not be

granted in the CIA.

Two representations were received from responsible authorities, the Police and Licensing Authority setting out concerns relating to the Prevention of Crime and Disorder, Public Safety, the Prevention of Public Nuisance and Cumulative Impact.

The Police representative amplified the Police objection. He provided details of the closing time of other licensed premises in the vicinity and stressed that 3am was significantly later. There were no other late-night takeaways in the immediate vicinity. Late night trading will impact on residents, both through delivery vehicle movements and by attracting people to the area who would otherwise not be there. Based on their interactions to date with the applicant, the Police had concerns about management’s attitude.

The Licensing Authority representative also expanded upon their objection and shared the Police’s concerns about the management of the premises.

We heard from the sole director of the applicant company. In their presentation, and in answer to our questions we were told that:

· The application for extended hours was in response to a demand from regular customers.

· The company did not employ sufficient staff to operate as a restaurant until 3am. The plan was to operate as a takeaway and provide a delivery service. He would use not only his employees for this, but also third-party delivery operators, such as Uber and Deliveroo. He did not wish to pursue extended hours at Christmas and New Year.

· He only became a director of the company in January 2024 and therefore could not comment on the unauthorised trading in November 2023.

· With regard to the alleged unauthorised trading in August 2024, that was on Pride weekend. The premises had been busy, and at the time of the Police visit, staff were cooking food for themselves and not the public.

· He was not in a position to change the trading hours on Facebook. That was controlled by previous directors of the company.

· There had been no complaints from local residents about the operation of the premises, nor any reported crime.

· The director was an experienced SIA registered door supervisor, capable of de-escalating problem behaviour, and of training staff to do the same. He intended to be at the premises as much as possible and would have an agreement with a security company if he was not.

The panel has considered this application on its merits. We note the policy objections to the application – both the CIA and Matrix, but we are particularly struck by the fact that there are no other late- night takeaways in the immediate area, which is somewhat unusual. No residents have objected to the application, and apart from the out of hours trading, no crime has been associated with the premises. The application does not include the sale of alcohol. We found the director’s explanation of the late hours for the premises on Facebook credible, together with his explanation for the apparent breach of the licensing hours over the Pride weekend. The measures proposed in the operating schedule, appearing as Appendix A in the agenda on page 25, propose a number of measures to address any public nuisance and crime and disorder concerns.

They include a Door Supervisor, CCTV and signs requesting patrons to respect the needs of neighbours. We do not believe that the application will add to the issues associated with cumulative impact.

The application is therefore granted with:-

i) A condition limiting the operation of the premises between 23.00 and 03.00 every day to takeaway and deliveries only.

ii) conditions consistent with the operating schedule.

The Panel believes that the above conditions are appropriate for the promotion of the licensing objectives.

The minutes of the panel will be available on the Council’s website under the rubric ‘Council and Democracy’. A webcast of the meeting is also available.

REP A - Appendix D

From: Donna Lynsdale
Sent: 13 January 2025 14:52
To: REDACTED

Cc: Brighton.Licensing@sussex.police.uk; Chinwe Ihemefor <REDACTED>
Subject: Zaf’ron, 99 North Road, Brighton BN1 1YE - 2025/00088/LICRSK/EH
Importance: High

Dear REDACTED

Licensing Act 2003 – Breach of Conditions

Zaf’ron, 99 North Road, Brighton BN1 1YE

Premises Licence Number:  1445/3/2024/04125/LAPRMV

I am writing to you in your capacity as the Premises Licence Holder (PLH) for the above premises.

On Thursday, 9 January 2025 at 15:52, accompanied by my colleagues Hannah Staplehurst and PC Wade, we visited your premises and carried out a full licensing inspection.  At time of this visit we spoke with ‘READACTED’.

Below are our findings and details of breaches of your premises licence conditions:

Annex 2 - Conditions consistent with the Operating Schedule:

In regard to Minor Variation application 2024/04125/LAPRMV to remove and replace with conditions agreed with Sussex Police under Annex 2:

Prevention of Crime and Disorder:

3. Subject to GDPR guidance and legislation:

     a)    Digital CCTV and appropriate recording equipment to be installed in accordance with Home Office Guidelines relating to UK Police Requirements for Digital CCTV System (PSDB Publication Number 09/05), operated and maintained throughout the premises internally and externally to cover all public areas, including the entrances/exits to the premises as well as any outside space. The system shall be on and recording at all times the premises licence is in operation.

     b)    The CCTV cameras and recording equipment must be of sufficient quality to work in all lighting levels inside the premises at all times.

     c)     CCTV footage will be stored for a minimum of 31 days

     d)    The management will give full and immediate cooperation and technical assistance to the Police in the event that CCTV footage is required for the prevention and detection of suspected or alleged crime.

     e)    The CCTV images will record and display dates and times, and these times will be checked regularly to ensure their accuracy.

     f)     The management of the premises will ensure that key staff are fully trained in the operation of the CCTV and will be able to download selected footage onto a disk (or other electronic portable device acceptable to Police e.g. USB) or provide footage via an online link as initiated by Police, without difficulty or delay and without charge.

     g)    Any breakdown or system failure will be notified to the police immediately & remedied as soon as practicable - brighton.licensing@sussex.police.uk .

     h)    In the event of the CCTV system hard drive being seized as evidence as part of a criminal investigation by Police or for any other reason, the premises will be expected to install a replacement hard drive, or a temporary replacement drive as soon as practicable.

The CCTV was only storing for 30 days and not 31 days in accordance with the above condition.  The time showing was one hour ahead. The staff member was unable to operate the system until they spoke with yourself to obtain the password.

4. There will be a minimum of 1 SIA licensed door staff at all times the premises opens past midnight. The door staff will be on duty from midnight until close.

We were informed that you have an SIA licensed door staff, however the staff member did not know if they were independent or supplied by a door supervisor company.

5. SIA licensed door supervisors shall be employed on any other occasions when a requirement is identified by the licence holder's written risk assessment or requested by Sussex Police in writing at least 48 hours in advance. The written risk assessment will be reviewed at least once every calendar year. The written risk assessment will take into account information or guidance offered by the police, and also taking into account busy periods such as Bank Holidays, Season Variations and other City Events e.g. Football, Pride, Music Events. The written risk assessment will be available on the premises for inspection by police and authorised officers of the Licensing Authority.

You did not have an SIA risk assessment available at the time of our visit.

6. At all times the premises is open to the public, the management will contract the backup services of an approved mobile support unit (MSU) that operates at all times the premises is open to the public, with a minimum of 2 SIA registered Door Supervisors operating from it. A copy of the MSU contract will be retained at the premises and made available for immediate inspection upon request by Sussex Police or Council Officials. The MSU will be accredited by the Brighton Crime Reduction Partnership (BCRP) or other similar organisation approved by Sussex Police should the BCRP not be in existence.

At the time of our inspection, you did not have an MSU contact.

7. The premises will become a member of the Brighton Crime Reduction Partnership or similar scheme approved by the Licensing Authority. The scheme must operate, subject to local coverage, radios and additionally an exclusion/banning scheme of named individuals within both the day and nighttime economy.

At the time of our inspection, you did not have a membership with BCRP.

8. a)   An incident log will be maintained by the premises showing a detailed note of incidents that occur in the premises. The log will be inspected and signed off by a manager at least once a month.

     b)    The logbook should be kept on the premises and be available for inspection at all times the premises are open by authorised officers of the Licensing Authority or the police. An incident will be defined as being one which involves an allegation of a criminal offence.

At the time of our visit the staff member was unable to show us an incident log.  The incident logbook should be inspected and signed off by a manager at least once a month.

Prevention of Public Nuisance:

9. The management will ensure that delivery vehicles waiting or arriving to collect orders will be parked/waiting legally and not causing a public nuisance by way of obstructing the highway or footpaths.

Following the licensing inspection, we witnessed one of your delivery drivers had left a Moped on double yellow lines.

10. Notices shall be prominently displayed at all exits requesting patrons to respect the needs of local residents and businesses and leave the area quietly.

There were no notices on display.

Protection of Children from Harm:

11.  a)  All staff will be trained in:

· Identifying persons who are vulnerable which could include but not limited to, their age or due to intoxication and or drugs as well as identifying potential perpetrators.

· Conflict management.

            The operator will have a policy in place assisting staff in how to deal with such situations.

b) All training undertaken by staff members shall be fully documented and recorded. All training records shall be made available to Sussex Police, officers of the local authority and officers   from the Trading

Standards team upon request.

c)  Further verbal reinforcement/refresher training covering the above will be carried out thereafter at intervals not to exceed 8 weeks, with the date and time of the verbal reinforcement/refresher training documented.

There were no training records available at the time of our visit.

I remind you that non-compliance with conditions constitutes a breach of the Premises Licence issued under the above legislation. Please ensure that all conditions on the licence are adhered to. It is an offence under the Licensing Act 2003, S136(1) and (4) to carry on unauthorised licensable activities.  The legislations states that:-

(1) A Person commits an offence if –

     (a)  he carries on or attempts to carry on a licensable activity on or from any premises otherwise than under and in accordance with an authorisation, or

     (b)  he knowingly allows a licensable activity to be carried on. 

(4) A person guilty of an offence under this section is liable on summary conviction to imprisonment for a term not exceeding six months or to an unlimited fine, or to both.

Irrespective of the permission's and restrictions attached to any premises licence, all licensed premises are required to operate with regard to the 4 licensing objectives, which are;

o     The Prevention of Crime and Disorder

o     Public Safety

o     Prevention of Public Nuisance

o     Protection of Children from Harm

Please be aware that any enforcement action is taken in line with our Licensing Enforcement Policy.  You are also reminded that at any stage, following the grant of a premises licence, a responsible authority, such as the Police, Environmental Health, or an interested party such as a resident living in the vicinity of the premises, may ask the Licensing Authority to review the licence because of a matter arising at the premises in connection with any of the four licensing objectives.

It was very disappointing that despite providing you will all the relevant documentation to comply with your premises licence, you have chosen not to use them and breaching your licence conditions.

Also, this authority is still receiving complaints from residents in the surrounding area.  The residents are alleging that they are being disturbed on a regular basis from loud music coming from your premises.  Also, from your customers parking on double yellow lines and that you are trading past your permitted times and causing a public nuisance. 

I note that my colleague previously emailed you regarding complaints that we have received.  To date you have not acknowledged her email or responded.

We will be carrying out a follow up visit in the near future.  Please ensure the above has been rectified and complied with.

I have copied into this email Police Licensing and Chinwe Ihemefor (Environmental Protection).

Please acknowledge receipt of this email.  When responding please reply to all.

Yours sincerely

Donna Lynsdale| Fair Trading Officer & Licensing Officer (Trading Standards & Licensing), Regulatory Services

Brighton & Hove City Council, 2^nd Floor, Barts House, Barts Square, BN1 1JP

T REDACTED |REDACTED

Appendix E

From: Donna Lynsdale <Donna.Lynsdale@brighton-hove.gov.uk>
Sent: 06 February 2025 12:18
To: 'REDACTED' < REDACTED >
Cc: 'Brighton.Licensing@sussex.police.uk' <Brighton.Licensing@sussex.police.uk>; Chinwe Ihemefor < REDACTED>
Subject: Zaf’ron, 99 North Road, Brighton BN1 1YE - 2025/00088/LICRSK/EH

Hi REDACTED

I can assure you that it is not a misunderstanding.

As provided below the dates and times that I have given all evidenced to show that the premises is trading past their permitted hours.

Please be aware that if you continue to trade past your permitted hours, enforcement action will be taken.

Regards

Donna Lynsdale| Fair Trading Officer & Licensing Officer (Trading Standards & Licensing), Regulatory Services

Brighton & Hove City Council, 2^nd Floor, Barts House, Barts Square, BN1 1JP

T REDACTED | M REDACTED | REDACTED

From: REDACTED
Sent: 06 February 2025 12:08
To: Donna Lynsdale
Cc: Brighton.Licensing@sussex.police.uk; Chinwe Ihemefor
Subject: Re: Zaf’ron, 99 North Road, Brighton BN1 1YE - 2025/00088/LICRSK/EH

Hi Donna. I hope you’re doing good. I just received your email stating that we have been trading past 3 am which i believe is a misunderstanding and i am sure we have never traded past the closing time. Whatever evidence you think you have i am ready to go through it with you. Thank you.

On 6 Feb 2025, at 11:54 am, Donna Lynsdale REDACTED wrote:

Dear REDACTED

Licensing Act 2003 – Breach of Conditions

Zaf’ron, 99 North Road, Brighton BN1 1YE

Premises Licence Number: 1445/3/2024/04125/LAPRMV

I am writing to you in your capacity as the Premises Licence Holder (PLH) for the above premises.

Following on from my previous email sent to you on 13 January 2025, where I advised that we had received complaints from residents in the surrounding area. Alleging that they are being disturbed on a regular basis from loud music coming from your premises. Also, from your customers parking on double yellow lines and that you are trading past your permitted times and causing a public nuisance. (See copy of email below).

I now advise that I have evidence that you have been trading past your permitted hours. The evidence shows that on 22 January 2025 at approximately 03:57 and 1 February 2025 at approximately 03:59.

Below are the details of breaches of your premises licence:

Times the licence authorises the carrying out of licensable activities

Late Night Refreshment

Every Day: 23:00 - 03:00 Outdoors - Takeaways and Deliveries only

The opening hours of the premises

Every Day: 12:00 - 03:00

As stated above, you have been trading past your permitted licensable activity times.

Annex 2 – Operating Schedule

In regard to Minor Variation application 2024/04125/LAPRMV to remove and replace with conditions agreed with Sussex Police under Annex 2:

Prevention of Crime and Disorder:

4. There will be a minimum of 1 SIA licensed door staff at all times the premises opens past midnight. The door staff will be on duty from midnight until close.

On both occasions you did not have SIA on the premises in accordance with the above condition.

Prevention of Public Nuisance:

On 1 February 2025, a motorcycle delivery driver was parked on double yellow lines. This is a breach of the above condition.

(1) A Person commits an offence if –

(a) he carries on or attempts to carry on a licensable activity on or from any premises otherwise than under and in accordance with an authorisation, or

(b) he knowingly allows a licensable activity to be carried on.

(4) A person guilty of an offence under this section is liable on summary conviction to imprisonment for a term not exceeding six months or to an unlimited fine, or to both.

Irrespective of the permission's and restrictions attached to any premises licence, all licensed premises are required to operate with regard to the 4 licensing objectives, which are;

o The Prevention of Crime and Disorder

o Public Safety

o Prevention of Public Nuisance

o Protection of Children from Harm

Please be aware that any enforcement action is taken in line with our Licensing Enforcement Policy. You are also reminded that at any stage, following the grant of a premises licence, a responsible authority, such as the Police, Environmental Health, or an interested party such as a resident living in the vicinity of the premises, may ask the Licensing Authority to review the licence because of a matter arising at the premises in connection with any of the four licensing objectives.

The above is extremely disappointing, especially as I had previously highlighted that we had received complaints that you are trading past your permitted hours.#

As a result of the above I am issuing you with a Warning.

I have copied into this email Police Licensing and Chinwe Ihemefor (Environmental Protection).

Please acknowledge receipt of this email. When responding please reply to all.

Yours sincerely

Donna Lynsdale| Fair Trading Officer & Licensing Officer (Trading Standards & Licensing), Regulatory Services

Brighton & Hove City Council, 2^nd Floor, Barts House, Barts Square, BN1 1JP

T REDACTED | REDACTED

From: Donna Lynsdale
Sent: 13 January 2025 14:52
To: ' REDACTED' <REDACTED >
Cc: Brighton.Licensing@sussex.police.uk; Chinwe Ihemefor <REDACTED >
Subject: Zaf’ron, 99 North Road, Brighton BN1 1YE - 2025/00088/LICRSK/EH
Importance: High

Dear REDACTED

Licensing Act 2003 – Breach of Conditions

Zaf’ron, 99 North Road, Brighton BN1 1YE

Premises Licence Number: 1445/3/2024/04125/LAPRMV

I am writing to you in your capacity as the Premises Licence Holder (PLH) for the above premises.

On Thursday, 9 January 2025 at 15:52, accompanied by my colleagues Hannah Staplehurst and PC Wade, we visited your premises and carried out a full licensing inspection. At time of this visit we spoke with ‘REDACTED’.

Below are our findings and details of breaches of your premises licence conditions:

Annex 2 - Conditions consistent with the Operating Schedule:

In regard to Minor Variation application 2024/04125/LAPRMV to remove and replace with conditions agreed with Sussex Police under Annex 2:

Prevention of Crime and Disorder:

1. Subject to GDPR guidance and legislation:

a) Digital CCTV and appropriate recording equipment to be installed in accordance with Home Office Guidelines relating to UK Police Requirements for Digital CCTV System (PSDB Publication Number 09/05), operated and maintained throughout the premises internally and externally to cover all public areas, including the entrances/exits to the premises as well as any outside space. The system shall be on and recording at all times the premises licence is in operation.

b) The CCTV cameras and recording equipment must be of sufficient quality to work in all lighting levels inside the premises at all times.

c) CCTV footage will be stored for a minimum of 31 days

d) The management will give full and immediate cooperation and technical assistance to the Police in the event that CCTV footage is required for the prevention and detection of suspected or alleged crime.

e) The CCTV images will record and display dates and times, and these times will be checked regularly to ensure their accuracy.

f) The management of the premises will ensure that key staff are fully trained in the operation of the CCTV and will be able to download selected footage onto a disk (or other electronic portable device acceptable to Police e.g. USB) or provide footage via an online link as initiated by Police, without difficulty or delay and without charge.

g) Any breakdown or system failure will be notified to the police immediately & remedied as soon as practicable - brighton.licensing@sussex.police.uk .

h) In the event of the CCTV system hard drive being seized as evidence as part of a criminal investigation by Police or for any other reason, the premises will be expected to install a replacement hard drive, or a temporary replacement drive as soon as practicable.

The CCTV was only storing for 30 days and not 31 days in accordance with the above condition. The time showing was one hour ahead. The staff member was unable to operate the system until they spoke with yourself to obtain the password.

2. There will be a minimum of 1 SIA licensed door staff at all times the premises opens past midnight. The door staff will be on duty from midnight until close.

We were informed that you have an SIA licensed door staff, however the staff member did not know if they were independent or supplied by a door supervisor company.

3. SIA licensed door supervisors shall be employed on any other occasions when a requirement is identified by the licence holder's written risk assessment or requested by Sussex Police in writing at least 48 hours in advance. The written risk assessment will be reviewed at least once every calendar year. The written risk assessment will take into account information or guidance offered by the police, and also taking into account busy periods such as Bank Holidays, Season Variations and other City Events e.g. Football, Pride, Music Events. The written risk assessment will be available on the premises for inspection by police and authorised officers of the Licensing Authority.

You did not have an SIA risk assessment available at the time of our visit.

4. At all times the premises is open to the public, the management will contract the backup services of an approved mobile support unit (MSU) that operates at all times the premises is open to the public, with a minimum of 2 SIA registered Door Supervisors operating from it. A copy of the MSU contract will be retained at the premises and made available for immediate inspection upon request by Sussex Police or Council Officials. The MSU will be accredited by the Brighton Crime Reduction Partnership (BCRP) or other similar organisation approved by Sussex Police should the BCRP not be in existence.

At the time of our inspection, you did not have an MSU contact.

5. The premises will become a member of the Brighton Crime Reduction Partnership or similar scheme approved by the Licensing Authority. The scheme must operate, subject to local coverage, radios and additionally an exclusion/banning scheme of named individuals within both the day and nighttime economy.

At the time of our inspection, you did not have a membership with BCRP.

6. a) An incident log will be maintained by the premises showing a detailed note of incidents that occur in the premises. The log will be inspected and signed off by a manager at least once a month.

b) The logbook should be kept on the premises and be available for inspection at all times the premises are open by authorised officers of the Licensing Authority or the police. An incident will be defined as being one which involves an allegation of a criminal offence.

At the time of our visit the staff member was unable to show us an incident log. The incident logbook should be inspected and signed off by a manager at least once a month.

Prevention of Public Nuisance:

7. The management will ensure that delivery vehicles waiting or arriving to collect orders will be parked/waiting legally and not causing a public nuisance by way of obstructing the highway or footpaths.

Following the licensing inspection, we witnessed one of your delivery drivers had left a Moped on double yellow lines.

8. Notices shall be prominently displayed at all exits requesting patrons to respect the needs of local residents and businesses and leave the area quietly.

There were no notices on display.

Protection of Children from Harm:

9. a) All staff will be trained in:

1. Identifying persons who are vulnerable which could include but not limited to, their age or due to intoxication and or drugs as well as identifying potential perpetrators.

2. Conflict management.

The operator will have a policy in place assisting staff in how to deal with such situations.

Standards team upon request.

c) Further verbal reinforcement/refresher training covering the above will be carried out thereafter at intervals not to exceed 8 weeks, with the date and time of the verbal reinforcement/refresher training documented.

There were no training records available at the time of our visit.

(1) A Person commits an offence if –

(a) he carries on or attempts to carry on a licensable activity on or from any premises otherwise than under and in accordance with an authorisation, or

(b) he knowingly allows a licensable activity to be carried on.

(4) A person guilty of an offence under this section is liable on summary conviction to imprisonment for a term not exceeding six months or to an unlimited fine, or to both.

Irrespective of the permission's and restrictions attached to any premises licence, all licensed premises are required to operate with regard to the 4 licensing objectives, which are;

o The Prevention of Crime and Disorder

o Public Safety

o Prevention of Public Nuisance

o Protection of Children from Harm

Please be aware that any enforcement action is taken in line with our Licensing Enforcement Policy. You are also reminded that at any stage, following the grant of a premises licence, a responsible authority, such as the Police, Environmental Health, or an interested party such as a resident living in the vicinity of the premises, may ask the Licensing Authority to review the licence because of a matter arising at the premises in connection with any of the four licensing objectives.

It was very disappointing that despite providing you will all the relevant documentation to comply with your premises licence, you have chosen not to use them and breaching your licence conditions.

Also, this authority is still receiving complaints from residents in the surrounding area. The residents are alleging that they are being disturbed on a regular basis from loud music coming from your premises. Also, from your customers parking on double yellow lines and that you are trading past your permitted times and causing a public nuisance.

I note that my colleague previously emailed you regarding complaints that we have received. To date you have not acknowledged her email or responded.

We will be carrying out a follow up visit in the near future. Please ensure the above has been rectified and complied with.

I have copied into this email Police Licensing and Chinwe Ihemefor (Environmental Protection).

Please acknowledge receipt of this email. When responding please reply to all.

Yours sincerely

Donna Lynsdale| Fair Trading Officer & Licensing Officer (Trading Standards & Licensing), Regulatory Services

Brighton & Hove City Council, 2^nd Floor, Barts House, Barts Square, BN1 1JP

T REDACTED | REDACTED

REP A - Appendix F

From: REDACTED

Sent: 26 February 2025 17:22
To: REDACTED < REDACTED >; Donna Lynsdale < REDACTED>
Cc: Brighton.Licensing@sussex.police.uk; Chinwe Ihemefor < REDACTED>
Subject: Zaf’ron, 99 North Road, Brighton BN1 1YE - 2025/00088/LICRSK/EH

   This email originates from outside of Brighton & Hove City Council. Please think carefully before opening attachments or clicking on links.  

Hi dear sir/Madam 

Yes I acknowledge receipt

Manana thanks 

Sent from Outlook for iOS

From: REDACTED

Sent: Wednesday, February 26, 2025 5:08:46 PM
To: Donna Lynsdale < REDACTED>
Cc: REDACTED < REDACTED >; Brighton.Licensing@sussex.police.uk <Brighton.Licensing@sussex.police.uk>; Chinwe Ihemefor < REDACTED>
Subject: Re: Zaf’ron, 99 North Road, Brighton BN1 1YE - 2025/00088/LICRSK/EH

Hi Dona! I just spoke to REDACTED and he said I can’t see any email in the inbox. 

This is his details

Phone : + REDACTED

Email : REDACTED

On 26 Feb 2025, at 4:42 pm, Donna Lynsdale < REDACTED> wrote:

Dear REDACTED

Following on from my emails sent on 11 February 2025 and 18 February 2025, I note that you have not acknowledged receipt.

Please can you do so by Friday, 28 February 2025, replying to all.

If I do not get an acknowledgement, I need to advise you that further enforcement action will be considered.

Yours sincerely

Donna Lynsdale| Fair Trading Officer & Licensing Officer (Trading Standards & Licensing), Regulatory Services

Brighton & Hove City Council, 2^nd Floor, Barts House, Barts Square, BN1 1JP

T REDACTED | REDACTED

From: Donna Lynsdale
Sent: 18 February 2025 16:32
To: REDACTED

Cc: Brighton.Licensing@sussex.police.uk; Chinwe Ihemefor < REDACTED>; 'r REDACTED' < REDACTED>
Subject: Zaf’ron, 99 North Road, Brighton BN1 1YE - 2025/00088/LICRSK/EH
Importance: High

Dear REDACTED

Following on from my email sent on 11 February 2025, I note that you have not acknowledged receipt.

Please can you so, replying to all.

Many thanks

Yours sincerely  

Donna Lynsdale| Fair Trading Officer & Licensing Officer (Trading Standards & Licensing), Regulatory Services

Brighton & Hove City Council, 2^nd Floor, Barts House, Barts Square, BN1 1JP

T REDACTED | REDACTED

From: Donna Lynsdale
Sent: Tuesday, February 11, 2025 12:40 PM
To: REDACTED
Cc: Brighton.Licensing@sussex.police.uk; Chinwe Ihemefor < REDACTED>; 'REDACTED < REDACTED>
Subject: Zaf’ron, 99 North Road, Brighton BN1 1YE - 2025/00088/LICRSK/EH
Importance: High

Dear REDACTED

I have been informed that as of the 1 February 2025, you have once again been appointed as the sole director of ‘Zaf’ron Ltd’ company registered number: 14238128.

Please see below warning sent on the 6 February 2025 to REDACTED regarding ongoing complaints and breaches of the above premises licence.

Once you have read the contents of my email, can you please acknowledge receipt.  When responding please reply to all.

I have copied into this email Police Licensing, Chinwe Ihemefor (Environmental Protection) and REDACTED.

Yours sincerely

Donna Lynsdale| Fair Trading Officer & Licensing Officer (Trading Standards & Licensing), Regulatory Services

Brighton & Hove City Council, 2^nd Floor, Barts House, Barts Square, BN1 1JP

T 01273 292494 | donna.lynsdale@brighton-hove.gov.uk

From: Donna Lynsdale <Donna.Lynsdale@brighton-hove.gov.uk>
Sent: 06 February 2025 12:18
To: REDACTED < REDACTED >
Cc: Brighton.Licensing@sussex.police.uk; Chinwe Ihemefor < REDACTED>
Subject: RE: Zaf’ron, 99 North Road, Brighton BN1 1YE - 2025/00088/LICRSK/EH

Hi REDACTED

I can assure you that it is not a misunderstanding.

As provided below the dates and times that I have given all evidenced to show that the premises is trading past their permitted hours.

Please be aware that if you continue to trade past your permitted hours, enforcement action will be taken.

Regards

Donna Lynsdale| Fair Trading Officer & Licensing Officer (Trading Standards & Licensing), Regulatory Services

Brighton & Hove City Council, 2^nd Floor, Barts House, Barts Square, BN1 1JP

T REDACTED | M REDACTED | REDACTED

From: REDACTED < REDACTED>
Sent: 06 February 2025 12:08
To: Donna Lynsdale <Donna.Lynsdale@brighton-hove.gov.uk>
Cc: Brighton.Licensing@sussex.police.uk; Chinwe Ihemefor < REDACTED>
Subject: Re: Zaf’ron, 99 North Road, Brighton BN1 1YE - 2025/00088/LICRSK/EH

   This email originates from outside of Brighton & Hove City Council. Please think carefully before opening attachments or clicking on links.  

On 6 Feb 2025, at 11:54 am, Donna Lynsdale <Donna.Lynsdale@brighton-hove.gov.uk> wrote:

Dear REDACTED

Licensing Act 2003 – Breach of Conditions

Zaf’ron, 99 North Road, Brighton BN1 1YE

Premises Licence Number:  1445/3/2024/04125/LAPRMV

I am writing to you in your capacity as the Premises Licence Holder (PLH) for the above premises.

Following on from my previous email sent to you on 13 January 2025, where I advised that we had received complaints from residents in the surrounding area.  Alleging that they are being disturbed on a regular basis from loud music coming from your premises.  Also, from your customers parking on double yellow lines and that you are trading past your permitted times and causing a public nuisance.  (See copy of email below).

I now advise that I have evidence that you have been trading past your permitted hours.  The evidence shows that on 22 January 2025 at approximately 03:57 and 1 February 2025 at approximately 03:59.

Below are the details of breaches of your premises licence:

Times the licence authorises the carrying out of licensable activities

Late Night Refreshment

Every Day:                          23:00 - 03:00           Outdoors - Takeaways and Deliveries only

The opening hours of the premises

Every Day:                          12:00 - 03:00

As stated above, you have been trading past your permitted licensable activity times.

Annex 2 – Operating Schedule

In regard to Minor Variation application 2024/04125/LAPRMV to remove and replace with conditions agreed with Sussex Police under Annex 2:

Prevention of Crime and Disorder:

4.         There will be a minimum of 1 SIA licensed door staff at all times the premises opens past midnight. The door staff will be on duty from midnight until close.

On both occasions you did not have SIA on the premises in accordance with the above condition.

Prevention of Public Nuisance:

9.         The management will ensure that delivery vehicles waiting or arriving to collect orders will be parked/waiting legally and not causing a public nuisance by way of obstructing the highway or footpaths.

On 1 February 2025, a motorcycle delivery driver was parked on double yellow lines.  This is a breach of the above condition.

(1) A Person commits an offence if –

     (a)  he carries on or attempts to carry on a licensable activity on or from any premises otherwise than under and in accordance with an authorisation, or

     (b)  he knowingly allows a licensable activity to be carried on. 

(4) A person guilty of an offence under this section is liable on summary conviction to imprisonment for a term not exceeding six months or to an unlimited fine, or to both.

Irrespective of the permission's and restrictions attached to any premises licence, all licensed premises are required to operate with regard to the 4 licensing objectives, which are;

o     The Prevention of Crime and Disorder

o     Public Safety

o     Prevention of Public Nuisance

o     Protection of Children from Harm

The above is extremely disappointing, especially as I had previously highlighted that we had received complaints that you are trading past your permitted hours.#

As a result of the above I am issuing you with a Warning.

I have copied into this email Police Licensing and Chinwe Ihemefor (Environmental Protection).

Please acknowledge receipt of this email.  When responding please reply to all.

Yours sincerely

Donna Lynsdale| Fair Trading Officer & Licensing Officer (Trading Standards & Licensing), Regulatory Services

Brighton & Hove City Council, 2^nd Floor, Barts House, Barts Square, BN1 1JP

T REDACTED | REDACTED

From: Donna Lynsdale
Sent: 13 January 2025 14:52
To: ' REDACTED' < REDACTED>
Cc: Brighton.Licensing@sussex.police.uk; Chinwe Ihemefor < REDACTED>
Subject: Zaf’ron, 99 North Road, Brighton BN1 1YE - 2025/00088/LICRSK/EH
Importance: High

Dear REDACTED

Licensing Act 2003 – Breach of Conditions

Zaf’ron, 99 North Road, Brighton BN1 1YE

Premises Licence Number:  1445/3/2024/04125/LAPRMV

I am writing to you in your capacity as the Premises Licence Holder (PLH) for the above premises.

Below are our findings and details of breaches of your premises licence conditions:

Annex 2 - Conditions consistent with the Operating Schedule:

In regard to Minor Variation application 2024/04125/LAPRMV to remove and replace with conditions agreed with Sussex Police under Annex 2:

Prevention of Crime and Disorder:

Subject to GDPR guidance and legislation:

     b)    The CCTV cameras and recording equipment must be of sufficient quality to work in all lighting levels inside the premises at all times.

     c)     CCTV footage will be stored for a minimum of 31 days

     e)    The CCTV images will record and display dates and times, and these times will be checked regularly to ensure their accuracy.

     g)    Any breakdown or system failure will be notified to the police immediately & remedied as soon as practicable - brighton.licensing@sussex.police.uk .

There will be a minimum of 1 SIA licensed door staff at all times the premises opens past midnight. The door staff will be on duty from midnight until close.

We were informed that you have an SIA licensed door staff, however the staff member did not know if they were independent or supplied by a door supervisor company.

SIA licensed door supervisors shall be employed on any other occasions when a requirement is identified by the licence holder's written risk assessment or requested by Sussex Police in writing at least 48 hours in advance. The written risk assessment will be reviewed at least once every calendar year. The written risk assessment will take into account information or guidance offered by the police, and also taking into account busy periods such as Bank Holidays, Season Variations and other City Events e.g. Football, Pride, Music Events. The written risk assessment will be available on the premises for inspection by police and authorised officers of the Licensing Authority.

You did not have an SIA risk assessment available at the time of our visit.

At all times the premises is open to the public, the management will contract the backup services of an approved mobile support unit (MSU) that operates at all times the premises is open to the public, with a minimum of 2 SIA registered Door Supervisors operating from it. A copy of the MSU contract will be retained at the premises and made available for immediate inspection upon request by Sussex Police or Council Officials. The MSU will be accredited by the Brighton Crime Reduction Partnership (BCRP) or other similar organisation approved by Sussex Police should the BCRP not be in existence.

At the time of our inspection, you did not have an MSU contact.

The premises will become a member of the Brighton Crime Reduction Partnership or similar scheme approved by the Licensing Authority. The scheme must operate, subject to local coverage, radios and additionally an exclusion/banning scheme of named individuals within both the day and nighttime economy.

At the time of our inspection, you did not have a membership with BCRP.

a)   An incident log will be maintained by the premises showing a detailed note of incidents that occur in the premises. The log will be inspected and signed off by a manager at least once a month.

At the time of our visit the staff member was unable to show us an incident log.  The incident logbook should be inspected and signed off by a manager at least once a month.

Prevention of Public Nuisance:

The management will ensure that delivery vehicles waiting or arriving to collect orders will be parked/waiting legally and not causing a public nuisance by way of obstructing the highway or footpaths.

Following the licensing inspection, we witnessed one of your delivery drivers had left a Moped on double yellow lines.

Notices shall be prominently displayed at all exits requesting patrons to respect the needs of local residents and businesses and leave the area quietly.

There were no notices on display.

Protection of Children from Harm:

 a)  All staff will be trained in:

Identifying persons who are vulnerable which could include but not limited to, their age or due to intoxication and or drugs as well as identifying potential perpetrators.

Conflict management.

            The operator will have a policy in place assisting staff in how to deal with such situations.

Standards team upon request.

There were no training records available at the time of our visit.

(1) A Person commits an offence if –

     (a)  he carries on or attempts to carry on a licensable activity on or from any premises otherwise than under and in accordance with an authorisation, or

     (b)  he knowingly allows a licensable activity to be carried on. 

(4) A person guilty of an offence under this section is liable on summary conviction to imprisonment for a term not exceeding six months or to an unlimited fine, or to both.

Irrespective of the permission's and restrictions attached to any premises licence, all licensed premises are required to operate with regard to the 4 licensing objectives, which are;

o     The Prevention of Crime and Disorder

o     Public Safety

o     Prevention of Public Nuisance

o     Protection of Children from Harm

It was very disappointing that despite providing you will all the relevant documentation to comply with your premises licence, you have chosen not to use them and breaching your licence conditions.

I note that my colleague previously emailed you regarding complaints that we have received.  To date you have not acknowledged her email or responded.

We will be carrying out a follow up visit in the near future.  Please ensure the above has been rectified and complied with.

I have copied into this email Police Licensing and Chinwe Ihemefor (Environmental Protection).

Please acknowledge receipt of this email.  When responding please reply to all.

Yours sincerely

Donna Lynsdale| Fair Trading Officer & Licensing Officer (Trading Standards & Licensing), Regulatory Services

Brighton & Hove City Council, 2^nd Floor, Barts House, Barts Square, BN1 1JP

T REDACTED | REDACTED

Appendix G

From: REDACTED <REDACTED>
Sent: 09 June 2025 11:55
To: Donna Lynsdale <Donna.Lynsdale@brighton-hove.gov.uk>
Cc: Brighton Licensing <brighton.licensing@sussex.police.uk>; Chinwe Ihemefor < REDACTED>
Subject: Zaf’ron, 99 North Road, Brighton BN1 1YE - 2025/01395/LICPRM/EH

 Dear Donna,

Thank you for your email and expressing your concerns, recently there was work carried out in the premises but it was during the working hours and it was before 10pm the shop was also closed for a day and more, I am Very strict when it comes to closing times I have strictly instructed my staff to close the shop at 3am and we do not serve after 2:30am to clear the restaurant before the time, I also check my camera at all the times so far there hasn't been any day that we have passed the 3am line, furthermore we do not allow anyone to dine in after 10:45pm. 

I assure you that we adhere with our licensing agreement and never exceed our standard operating hours. 

If you would like to visit our restaurant to meet and discuss this further I am always available.

If you require any further clarification kindly do not hesitate to contact us.

Kind regards 

REDACTED

Sent from Outlook for iOS

From: Donna Lynsdale <Donna.Lynsdale@brighton-hove.gov.uk>
Sent: Monday, June 9, 2025 8:52:44 AM
To: REDACTED < REDACTED >
Cc: Brighton Licensing <brighton.licensing@sussex.police.uk>; Chinwe Ihemefor < REDACTED>
Subject: Zaf’ron, 99 North Road, Brighton BN1 1YE - 2025/01395/LICPRM/EH

Dear REDACTED

Licensing Act 2003 – Breach of Conditions

Zaf’ron, 99 North Road, Brighton BN1 1YE

Premises Licence Number:  1445/3/2024/04125/LAPRMV

I am writing to you in your capacity as the Premises Licence Holder (PLH) for the above premises.

The Licensing Authority have received further complaints from residents in the surrounding area.  The residents are alleging that your premises has been carrying out building works late at night and going into the early hours of the morning.  Also, that you are continuing to trade past your permitted hours and disturbing and causing a public nuisance to your neighbours. 

This is not the first time I have had cause to write to you regarding complaints received and trading past your permitted hours.

(1) A Person commits an offence if –

     (a)  he carries on or attempts to carry on a licensable activity on or from any premises otherwise than under and in accordance with an authorisation, or

     (b)  he knowingly allows a licensable activity to be carried on. 

(4) A person guilty of an offence under this section is liable on summary conviction to imprisonment for a term not exceeding six months or to an unlimited fine, or to both.

Irrespective of the permission's and restrictions attached to any premises licence, all licensed premises are required to operate with regard to the 4 licensing objectives, which are;

o     The Prevention of Crime and Disorder

o     Public Safety

o     Prevention of Public Nuisance

o     Protection of Children from Harm

The above is extremely disappointing, especially as I have already raised similar concerns about your premises.

I have copied into this email Police Licensing and Chinwe Ihemefor (Environmental Protection).

Please acknowledge receipt of this email.  When responding please reply to all.

Yours sincerely

Donna Lynsdale| Fair Trading Officer & Licensing Officer (Trading Standards & Licensing), Regulatory Services

Brighton & Hove City Council, 2^nd Floor, Barts House, Barts Square, BN1 1JP

M REDACTED | REDACTED

REP B

From: Cllr Mitchie Alexander REDACTED
Sent: 19 August 2025 14:34
To: EHL Licensing <EHL.Licensing@brighton-hove.gov.uk>
Subject: Zefron, North Rd license review representation

EF CON ENDS 10.09.2025 VALID PCD, PPN, PCH and PS (B)

Hello,

I am sending you a representation on behalf of local residents on why myself as a city councillor and the residents who live very close by believe that Zefron, 99 North Rd, Brighton BN1 1YE should not continue with their current licence terms.

Prevention of Crime and Disorder:

Local residents have told me that they have witnessed drug dealing going on centred around this premises.

I also understand that a REDACTED resident and the staff REDACTED Recently REDACTED This is not an action that should be tolerated of course, but rather than phoning the police, REDACTED neighbours are very upset about this REDACTED as they all care what happens to REDACTED After this REDACTED. And a short time afterwards REDACTED

The nearby residents also say that the shop has continually broken it’s licence by staying open to 5am on many occasions.

Public Safety:

The residents living close to Zefron say that they do not feel safe. Some of the residents who live REDACTED have stated that they feel unsafe REDCATED they feel afraid that REDACTED This includes children and teenagers who live REDACTED The REDACTED was not safe in REDACTED neighbourhood.

Prevention of Public Nuisance:

The residents state that their sleep is very negatively impacted, due to the comings and goings of cars and motorbikes visiting the shop during the nighttime hours. They state that vehicles will hoot their horns. The very fact that the residents are in fear REDACTED residents REDACTED have complained about the anti social activities surrounding the shop (violence, menacing behaviour, noise from vehicles, breaking their licence etc).

Protect children from harm:

It has been stated to me that various children REDACTED because of fear of the Zefron staff and visitors. No child should be afraid REDACTED their home ! These same children are now even more afraid as they have heard REDACTED Whether or not REDACTED children living in the REDACTED No child should live in fear in their own home.

I am happy to give a representation on behalf of the residents in this area at the review hearing.

Best Regards

Mitchie

Cllr Mitchie Alexander

REP C – Cllr Sue Shanks 4.9.25

Complaints about Zafron

In late 2024 residents of REDACTED complained to ward councillors, myself and Cllr Macleay and to the local MP Sian Berry about noise and disturbances accused by taxi drivers congregating outside Zafron as well as concerns about the restaurant operating beyond its licensed hours.

A full inspection with the police followed the complaints in January.

The complaints included doors opened and music playing really loud. Including men standing in the street talking loudly, also slamming car doors and playing loud music. Residents complained but were met with REDACTED

I visited Zafron and the manager was pleasant and denied they were trading late or making a noise outside.

In July I received more complaints. It was hot and residents had to keep their windows open. Noise from a group of people shouting and swearing outside the shop. This kept children awake and REDACTED complained to restaurant asking them to keep the door shut and keep customers in the shop.

Customers then REDACTED The resident stated ‘Zafron should have ask them nicely and to explain we have children trying to sleep not tell them what bedrooms it is coming from,.We even heard things like "REDACTED " "yeah one of these REDACTED .It's really scary for the children.

Other issues highlighted were the use of Zafron as a place to meet by non customers, bright lighting outside the building , ‘ The sign on windows that says respect neighbours is at the bottom of the shop and is not visible at all at night as the massive bright menu cancels it out’. Male staff were shouting at their friends outside REDACTED.

The delivery drivers also cause noise, shouting for orders. Beeping. Reving engines.

‘people outside the premises, perhaps from REDACTED shouting at staff hello and staff letting them loiter outside the shop with dogs barking is not acceptable. They shake their hands come out to talk to them. The stay around here sometimes arguing REDACTED‘

Following a REDACTED at Zafron recently I spoke to a police person, REDACTED, who said the license would be stopped and then reviewed, as we now know it couldn’t be as is not alcohol.

I feel that a late licence has proved inappropriate in this area. I did speak to Zafron staff who were pleasant and said REDACTED that is in the hands of the police.

Due to the complaints outlined above and the recent police involvement I support the termination of the late license. I feel it meets the threshold for removal due to all 4 factors of :

Prevention of crime and disorder, Public safety,Prevention of public nuisanceProtection of children from harm

REP D

Emily Fountain

Licensing Officer

Brighton & Hove City Council

Bartholomew House

Bartholomew Square

Brighton

BN1 1JP

Date:

Our Ref:

Phone:

5^th September 2025

2025/02151/EPLIC/EH

01273 REDACTED

E-mail:

REDACTED

EF CON ENDS 10.09.2025 VALID PPN (C)

Dear Emily Fountain

Formal Representation for a Premises Licence Review Application

Re: Zaf’ron, 99 North Road Brighton, BN1 1YE

In reference to an application for the review of the Late-night Refreshment (LNR) Licence of Zaf’ron, 99 North Road Brighton, BN1 1YE to operate between 2300 hours and 0300 hours by the Sussex Police, seven days a week, I write as a consultee on behalf of the Environmental Protection Team to formally make a representation on the grounds of the Prevention of Public Nuisance; one of the four objectives as specified by the Licensing Act 2003.

The Environmental Protection Team received three complaints about noise and odours from the business on the 13^{th of} September 2023, even before a LNR licence was granted to them. We were told the disturbance was from noisy staff after closing times, strong cooking odours and smoke, and banging during clean-up.

On the 31^st of July 2024, another complaint was made about loud music played after closing times between 2300 hours and 0100 hours nearly every day; noise from loud metal banging during afterhours cleaning with the doors left open, and shouting. The disruption was causing neighbours to lose sleep.

Warnings were sent to the business on 21^st September 2023 and 9^th of August 2024, and diaries to residents but no responses from business.

On the 14^th of August 2024, another complaint about noise from loud banging, taking out thrash, and rowdy customers/workers came in.

A diary was returned 12^th of October 2024 detailing incidents of drunk people and people being rowdy outside the premises, beeping of horns, slamming car doors, taxis parked illegally on the road, noise from taking out rubbish late at night and loud music late at night. Based on this evidence, a stronger warning was emailed to the business on the 14^thof October 2025.

Premises Licence Holder called after this letter in October 2024 to say the complaints made about them were unjustified and they do not believe the complaints are from their neighbours, who were in support of their application for a LNR licence. They wondered how we could have gotten complaints as they only just started operating.

A 4^th complaint about odours and smoke from business affecting residents in their homes and gardens on the 5^th of November 2024.

Complaints resume on the 30^{th of} January 2025, which are still about men shouting, banging noise from cleaning after closing hours, which escapes through open doors, and intrusive bright lights from the premises but now the disturbance is said to continue till 0300 hours. Complainant claims residents were not consulted about the LNR application as they would have opposed the proposal considering the persistent issues when they could only operate until 2300 hours.

Another warning sent to business on the 17^th of January 2025 and a diary to the complainant.

On the 4^th of June 2025, it is alleged that construction work is being carried out at the premises till 0100 hours. A warning sent out and a diary to the complainant again.

In the past, it has been difficult engaging with the business, and it did not appear that they were actively seeking to address the issues raised by residents through the Environmental Protection Team by employing further preventive measures to uphold the Prevention of Public Nuisance objective.

The business has finally put forward proposals to deal with Nuisance, for example, cleaning up early and quietly, taking out trash at reasonable times, minimising noise from music, staff and customers and dimming lights at night.

The plan is to reduce the noise from cleaning by winding down operations before 0300 hours, asking staff to be quiet and avoid banging equipment.

It is questionable whether these measures will prove effective since cleaning after 2300 hours and before 0300 hours when the business did not have a LNR licence caused a disturbance, and it is tricky cleaning kitchen equipment without banging.

We are told the noise from cleaning is a problem because the doors of the premises are left open during the process, so it seems rational that keeping the doors closed except for access and ingress, in addition to the above proposals is more effective at reducing the noise but the business has not suggested this option. It is uncertain whether closing the doors is feasible.

In conclusion, I am not confident that the business is able to manage their activities sufficiently to avoid causing a Nuisance before 2300 hours let alone the 0100 hours closure time proposed, considering their track record and the fact that complaints from neighbours persist despite them employing the said mitigation.

The Environmental Protection Team does not support this proposal due to the reasons outlined in this representation, if the Licensing Panel decides to grant this licence for the provision of Late-Night Refreshment, we propose the additional conditions in the attached addendum to uphold the Prevention of Public Nuisance licensing objective.

Please do not hesitate to contact me if you wish to discuss the matter further.

Yours sincerely

Chinwe Ihemefor

Environmental Health Officer

Addendum

- Delivery personnel will only collect at the counter and will wait quietly to collect the orders to be delivered.

- Refuse shall be placed into receptacles outside the premises no later than 22:00 hours and no earlier than 07:00 hours.

- No noise, vibration or light shall emanate or be transmitted through the structure of the premises that gives rise to a nuisance.

- The premises license holder shall ensure that any extraction system associated with the premises is satisfactorily operated and maintained to prevent noise, smoke/fumes and/or odour from causing a nuisance.

- Doors of the premises shall be kept shut at 22:00 hours and during clean-up, except for ingress and egress.

REP E

From: Sian Berry MP REDACTED
Sent: 09 September 2025 17:18
To: EHL Licensing <ehl.licensing@brighton-hove.gov.uk>
Subject: Representation re: review of premises licence for Zaf'ron, 99 North Road, Brighton.

EF CON ENDS 10.09.2025 VALID PCD, PS and PPN (E)

Re: review of premises licence for Zaf'ron, 99 North Road, Brighton.

Over the course of this year I have received regular correspondence about these premises from several residents REDACTED. My constituents report ongoing nightly disturbances centred around this restaurant, which they say is connected to the late licence it holds, a licence they say has been breached on multiple occasions.

These incidents have been reported to the council and the police by my constituents, so I believe the licensing panel should have residents reports available to scrutinise directly. However, to summarise, my constituents have expressed concerns that loud disturbance in the street outside, and around this restaurant, regularly prevents local residents from sleeping, and that this regularly continues until 3am, and sometimes until 5am. They say the ongoing sleeplessness due to noise nuisance and incidents is having a significant effect on family life, and on children living in REDACTED whose loss of sleep my constituents believe is harming both their health and their schooling.

The correspondence I have received from residents leads me to urge the panel to listen carefully to their concerns, and to their experiences of living REDACTED this business, when you are considering the licensing objectives of prevention of public nuisance and the protection of children from harm.

I have been hearing from constituents for some time about the local community tensions they say the restaurant's late license creates. As the local authority will be aware, events have recently escalated REDACTED and residents continue to have concerns about the volatility of the situation. Given this, I would urge the licensing panel to give careful consideration to what both local residents and the police have to say about community tensions and risk, when deciding whether these premises can retain their licence while maintaining the licensing objectives of prevention of crime and disorder, and public safety.

Siân Berry MP

Siân Berry MP for Brighton Pavilion

Constituency Office of Siân Berry MP
Green Party, Brighton Pavilion
REDACTED

REP F

EF CON ENDS 10.09.2025 VALID PCD (F)

Immigration representation in support of an application for the review of a premises Licence

On behalf of the Secretary of State, Home Office (Immigration Enforcement) makes representations in support of the following application for the review of a premises licence, relating to the prevention of crime and disorder objective, including the prevention of illegal working and immigration crime in licensed premises.

IE wishes to make representations on an application for a review of a premises licence.

Details of Premises:
Premises Licence Holder:
Zaf’ron Limited
Name and Address of Premises:
Zaf’ron 99 North Road
Post Town:	Brighton	Post Code:	BN1 1YE

Representations are being made for the following reasons:

On 02 August 2025, officers from Brighton and Hove Police attended Zaf’ron, 99 North Road, Brighton, BN1 1YE to investigate REDACTED During the course of the investigation, several individuals suspected of being employed at the premises REDACTED It was subsequently discovered that one of these individuals did not possess the legal right-to-work in the UK.

REDACTED

REDACTED was encountered at the premises and was seen wearing a Zaf’ron branded uniform at the time. Home Office checks confirmed REDACTED made a claim for protection in July 2024 which was refused in April 2025. REDACTED was on immigration bail when encountered working at Zaf’ron, REDACTED bail conditions strictly prohibited him from undertaking any type of employment in the UK. Therefore, REDACTED was an illegal worker as he was found working in breach of bail conditions.

Zaf’ron is listed on Companies House under the trading name ZAFRON EASTBOURNE LIMITED. The company registration number for ZAFRON EASTBOURNE LIMITED is 16383295. Companies House shows that it was incorporated on 11 April 2025, is currently active and Norulah HABIBI is listed as the Director who was appointed on 11 April 2025.

It must be noted that Norulah HABIBI is currently listed as the active director of Zafron Crawley, officially registered under the name ZAFRON CRAWLEY LTD (Company No. 15437053). HABIBI was appointed as director on 21 March 2025.

On 14 March 2025, Immigration Enforcement officers conducted a visit to the premises; Zafron Crawley, located at 6–14 High Street, Crawley, RH10 1BN. During the visit, three individuals were found to be working illegally. During interviewing, REDACTED was named as the employer by an individual found working illegally, who also confirmed REDACTED was responsible for assigning duties and managing work schedules.

RIGHT TO WORK CHECKS AND THE PREVENTION OF CRIME AND DISORDER

The objective of the Licensing Act 2003 (the Act) is to provide a clear, transparent framework for making decisions about applications by individuals or businesses wishing to sell or supply alcohol or provide certain types of regulated entertainment and late-night refreshment.

There are four licensing objectives which underpin the Act, and which need to be taken into account and promoted throughout the licensing process.

The licensing objectives are:

• the prevention of crime and disorder

• public safety

• the prevention of public nuisance and

• the protection of children from harm

Zaf’ron under the control of Norulah HABIBI has been found employing illegal workers at both the premises in Brighton and Crawley. This business has clearly failed to meet the prevention of crime and disorder objective. The licence holder would have been aware of their responsibilities to uphold the licensing objectives as they are clearly defined as part of the premises licence application. It is an offence to work when a person is disqualified to do so, and such an offence can only be committed with the co-operation of a premises licence holder or its agents.

The employer could have protected themselves and prevented crime and disorder by completing a straightforward right to work check. In this case the employer had not conducted the right to

work checks even when he was presented with documents prior to commencing work. Should the licence holder have attempted these checks, the workers would have failed at the first stage. This would have quickly and easily confirmed that they did not hold the relevant right to work, and the licence holder could have protected themselves from employing an illegal worker. All employers are dutybound by law to conduct these checks if they wish to avoid being penalised if found to have employed someone who is prohibited from working, and guidance can be found on the gov.uk website or by using a search engine. Additional information on how to conduct these checks is available online, this includes the Home Office’s official YouTube page.

The use of illegal labour provides an unfair competitive edge and deprives the UK economy of tax revenue. Illegal workers are often paid below the minimum wage (itself an offence) and National Insurance payments are not paid. A key draw for illegal immigration is work and low-skilled migrants that are increasingly vulnerable to exploitation by unlawful enterprises, finding themselves in sub-standard accommodation and toiling in poor working conditions for long hours.

Whether by negligence or willful blindness illegal workers were engaged in activity on the premises. Section 182 guidance of the Licensing Act 2003 at point 11.27 states that certain activity should be treated particularly seriously, and this includes employing someone who is disqualified from that work by reason of their immigration status in the UK. 11.28 of the guidance states that it is expected that revocation of the licence – even in the first instance – should be seriously considered.

Details of Responsible Authority
Name and Address:
Immigration Enforcement Immigration Enforcement Licensing Compliance Team 6th Floor, 2 Ruskin Square Dingwall Road Croydon CR0 2WF
	Emailaddress (optional):	REDACTED

Signatures
Signature of Responsible Authority
Home Office Immigration Enforcement
Date:	10 September 2025	Capacity:	Responsible Authority

REP G

From: REDACTED
Sent: 10 September 2025 15:47
To: EHL Licensing <EHL.Licensing@brighton-hove.gov.uk>; Emily Fountain <Emily.Fountain@brighton-hove.gov.uk>
Subject: Za'fron, 99 North Road, Btn
Importance: High

EF CON ENDS 10.09.2025 VALID PCD and PPN (G)

To whom it may concern,

As part of any premises licence application, since August 2022 the planning department have been consulted. When a review of Za’fron’s premises licence was raised, I checked the Council’s systems to see what current planning permission there is for this address.

I have attached the current planning permission. This is still extant and condition 4 attached to BH2010/01036 states:

The premises can only be open for the following hours.

08.00 to 23.00 Monday to Friday

08.00 to 23.30 Saturdays

09.00 to 23.00 Sundays, Bank Holidays

This restaurant (planning class Use E) should not be open past 11pm or 11.30pm on Saturdays. If this restaurant were to open past the conditioned hours of opening in the future, then then the Council may consider further enforcement action for the breach of the conditioned opening hours, by serving a Breach of Condition Notice. There is no right of appeal against this notice and if breached in the future the Council may prosecute the responsible persons at Brighton Magistrates Court.

The previous planning use at this address were a delicatessen and café/restaurant (planning class Use E). These hours were set due to the location of the property, in a residential area and was to safeguard the amenities of the local area and to comply with Planning Policies SU10 and QD27 of the then Brighton & Hove Local Plan. The policy QD27 is still within the current City Plan Part 2, as DM20 (the main Planning document). This Policy prevents material nuisances and the loss of amenities to local residents. This is why the previous business was conditioned to close at the above hours to prevent any excessive noise, artificial lighting to any local residents.

Planning acknowledge that it is a separate regime to Licensing however it is felt that the breach of the conditioned opening hours is a contributing factor for the licence having to be reviewed. The Planning department were unaware that there was a breach of planning control at the restaurant and to prevent any future possible complaints from local residences that fall within the licensing objective of the Prevention of Public Nuisance. I support the review brought by the Police on the grounds of the Prevention of Crime & Disorder and the prevention of Public Nuisance.

Kind regards

REDACTED Senior Planning Officer | Development Management – Enforcement Team

Directorate of Place, 1^st Floor, Hove Town Hall, Norton Road, BN3 3BQ