In revoking the five-vehicle O-Licence held by Kamlesh Kumar, trading as Mazza Coaches, Traffic Commissioner (TC) Sarah Bell disqualified him and Services Transport, of which Mr Kumar was the sole director, from holding or obtaining an O-Licence in any British traffic area as a sole trader, partner or director, or being engaged in the management, administration and/or control of an entity that holds or obtains such a licence in Great Britain for a period of 10 years.
Finding that Kamlesh Kumar was unfit to manage the transport activities of an undertaking, the TC disqualified him from acting as a transport manager (TM) and from being designated as a TM on any O-Licence for a period of 10 years.
The TC said that Mr Kumar asked her to accept that he found himself in his current position through innocent mistake, lack of knowledge and/or negligence, rather than through dishonesty or a lack of integrity. He said that he simply took his eye off the ball regarding drivers’ hours and driver management.
Mr Kumar acknowledged that he should have ensured formality around vehicle hire, saying he had not read forms properly and he had not realised the significance for his O-Licence by his use of Services Transport. He assured the TC he would do better in future with an O-Licence in the correct name, a different TM and a transport consultant.
Longstanding failings
Mr Kumar obtained an O-Licence in 2007 based on a false declaration. On 16 June 2012 he signed the O-Licence continuation checklist and submitted it to the licensing team in Leeds as accurate. He failed to disclose a fraud conviction even though it was clearly not spent.
This was Mr Kumar’s second Public Inquiry (PI). Mr Kumar attended a PI in June 2012 where he also failed to notify of his fraud conviction. He also requested a period of grace to demonstrate financial standing, while hiding the true extent of his financial challenges. He had additionally fraudulently obtained and spent £51,000.
In September 2015 Mr Kumar continued to hold the business assets protected within his limited company and failed to disclose his bankruptcy to the Office of the TC. By that point the O-Licence should most likely have been revoked or terminated in 2011, 2012 and 2015. Instead, Mr Kumar continued to do as he pleased and obtained an increased authorisation to five vehicles in 2019.
At some point through ‘commercial necessity’ Services Transport became the operator as a matter of law. Mr Kumar failed to identify when the incremental changes likely crystallised to unlawful operation/O-Licence lending. It appeared to be some considerable time before 2023.
The limited company and Mr Kumar were equally culpable as Mr Kumar was the sole director. Among all this Mr Kumar failed to fulfil his duties as a TM. He failed as director and owner to exercise quality monitoring and control of the transport operations. The failings were deep and of long standing.
Integrity and safety
Mr Kumar’s good repute as operator and TM were so inextricably linked as to not be divisible. He had merged the roles to such a degree that there was no separation.
The mendacious Mr Kumar had no place in this regime when his business “was built on bankruptcy, fraud, lies, and manipulation.” Mr Kumar was a risk to road safety and the level playing field which was so crucial to the integrity of the O-Licensing regime.
It was many years since TC Bell had come across such a combination of deceit, self-interest, and dereliction of duty. The failings went back to the start of the O-Licence and continued all the way through to the end of Mr Kumar’s evidence.
It was important that those who relied on the O-Licensing regime understood that if it took years, even decades, for misconduct to be uncovered, a robust and meaningful outcome would follow. It would send entirely the wrong message that getting away with something serious over the passage of time would diminish the outcome.
In her judgement, a significant period of disqualification was appropriate, and proportionate, to protect the hard-working, legitimate industry.
Dry-hire warning
TC Bell was aware that revocation and disqualification could not completely remove Mr Kumar from the coach industry in that he might continue to ‘dry hire’ vehicles.
However, she reminded all operators that for hired vehicles the user should ‘lock in’ and ‘lock out’ the vehicle unit to preserve their data, as the duty to produce records was an undertaking on the O-Licence; and that the user must ensure that the vehicle was roadworthy and in line with their own safety declarations.
As the O-Licence was revoked, an application to nominate Desmond McNulty as TM was also formally refused. TC Bell says she would not have accepted Mr McNulty as TM as of 23 December 2025.
He had completed two TM1 forms for the sole trader O-Licence and Services Transport. The latter application was withdrawn but both forms included false declarations.
Mr McNulty failed to declare the revocation of the O-Licence held by Plan Ahead Travel on 19 December 2023, of which he was the sole director and TM. It was shortly after that revocation that Mr McNulty began to drive for Mr Kumar.
Mr McNulty committed tachograph offences as a driver. It was unclear if there were other vehicle or financial arrangements between Mr Kumar and Mr McNulty. There was reference to Mr Kumar paying Mr McNulty’s mortgage on two occasions. In TC Bell’s judgement, the relationship was too close for Mr McNulty to be the TM for Mazza Coaches even if the O-Licence continued.
She was aware there was an application by Mr McNulty to be TM in the Eastern Traffic Area. She noted that he had failed to declare the revocation again on that application. It would be for the TC for the East of England to determine that application.
However, she knew the current decision would be considered. Mr McNulty might benefit from a hearing before a different TC, where his repute could be considered moving forward, away from the connections to Mr Kumar.
