The Licensing Panel (Licensing Act 2003 Functions) was scheduled to convene to discuss a review of the premises licence for Zaf'ron, a restaurant located at 99 North Road, Brighton. The review was prompted by an application from Sussex Police, citing concerns over crime and disorder. The panel was also expected to appoint a chair for the meeting and handle standard procedural business.

Zaf'ron Premises Licence Review

The primary item for consideration was the review of Zaf'ron's premises licence, initiated following an application by Sussex Police. The grounds for the review relate to the licensing objective of the prevention of crime and disorder.

According to the report pack, on 13 August 2025, the Licensing Authority received an application from Sussex Police to review the licence granted to Zaf'ron.

The report pack notes that the Licensing Authority had to:

Consider the application made in accordance with Section 51 Consider any relevant representations Take such steps (if any) as are considered appropriate for the promotion of the Licensing objectives.

The available steps included modifying the licence conditions, excluding a licensable activity, removing the designated premises supervisor, suspending the licence for up to three months, or revoking the licence.

Representations

The report pack states that the council received six representations from local councillors, a Brighton MP, Environmental Protection, Immigration and Planning, all supporting Sussex Police's application to revoke the licence. These representations cited concerns relating to:

• Prevention of crime and disorder
• Public safety
• Prevention of public nuisance
• Protection of children from harm

Licensing Team Representation

The Licensing Team submitted a representation detailing a history of issues at Zaf'ron, including operating without a licence, breaching licence conditions, and causing a public nuisance. [Donna Lynsdale], Licensing Officer, stated that the premises had clearly demonstrated that they are not operating to the conditions attached to the premises licence and that she had no confidence in the management of the running of the premises.

[Donna Lynsdale]'s representation included copies of emails sent to the premises licence holder [Rafiullah Khan] and [Norulah Habibi] regarding unauthorised licensable activities, breaches of conditions, and complaints from local residents.

Sussex Police Further Evidence

Sussex Police submitted further evidence expanding on their reasons for requesting a review of the licence. The document alleges that [Norulah Habibi] did not co-operate fully with the police investigation, and that the CCTV timestamp was still incorrect despite a licensing inspection in January 2025.

The document also provides a timeline of dealings with the venue, including instances of:

• Operating without a licence
• Operating beyond permitted hours
• Noise complaints
• Breaches of licence conditions

The timeline also notes several changes in directorship of Zaf'ron Ltd and Zafron Crawley Ltd.

Environmental Protection Team Representation

The Environmental Protection Team submitted a representation detailing numerous complaints about noise and odours from the business, even before a late-night refreshment licence was granted. [Chinwe Ihemefor], Environmental Health Officer, stated that it had been difficult to engage with the business and that they did not appear to be actively seeking to address the issues raised by residents.

[Chinwe Ihemefor] also questioned whether the business would be able to manage their activities sufficiently to avoid causing a nuisance, considering their track record and the fact that complaints from neighbours persisted despite them employing mitigation measures.

Planning Department Representation

The Planning Department submitted a representation noting that the current planning permission for the premises, BH2010/01036, includes a condition limiting opening hours to:

• 08:00 to 23:00 Monday to Friday
• 08:00 to 23:30 Saturdays
• 09:00 to 23:00 Sundays, Bank Holidays

The representation stated that the Planning Department was unaware that there was a breach of planning control at the restaurant and that the breach of conditioned opening hours is a contributing factor for the licence having to be reviewed.

Immigration Enforcement Representation

Immigration Enforcement submitted a representation stating that on 2 August 2025, officers from Brighton and Hove Police attended Zaf'ron 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.

The representation also noted that on 14 March 2025, Immigration Enforcement officers conducted a visit to Zafron Crawley, located at 6–14 High Street, Crawley, and found three individuals working illegally.

Immigration Enforcement stated that Zaf'ron, under the control of [Norulah Habibi], had been found employing illegal workers at both the premises in Brighton and Crawley, and that this business had clearly failed to meet the prevention of crime and disorder objective.

Representations from Councillors and an MP

Councillor [Mitchie Alexander] submitted a representation on behalf of local residents, stating that they had witnessed drug dealing going on centred around the premises, and that the shop had continually broken its licence by staying open to 5am on many occasions. Councillor [Mitchie Alexander] also stated that residents living close to Zaf'ron did not feel safe, and that children were afraid because of fear of the Zaf'ron staff and visitors.

Councillor [Sue Shanks] submitted a representation detailing complaints from residents about noise and disturbances caused by taxi drivers congregating outside Zaf'ron, as well as concerns about the restaurant operating beyond its licensed hours. Councillor [Sue Shanks] also stated that she supported the termination of the late licence due to concerns about the prevention of crime and disorder, public safety, prevention of public nuisance, and protection of children from harm.

[Siân Berry], MP for Brighton Pavilion, submitted a representation stating that she had received regular correspondence about the premises from several residents, who reported ongoing nightly disturbances centred around the restaurant, which they said was connected to the late licence it holds. [Siân Berry] urged the panel to listen carefully to the concerns of local residents and the police when deciding whether the premises can retain their licence while maintaining the licensing objectives of prevention of crime and disorder, and public safety.

Premises Licence Holder Response

[Norulah Habibi], the premises licence holder, submitted a representation responding to the allegations made by Sussex Police and the Licensing Authority. [Norulah Habibi] apologised for any noise or disturbance caused by delivery drivers or late-night cleaning, and outlined a range of remedial actions and proactive measures that had been implemented to ensure full compliance and promote the licensing objectives.

These measures included:

• Engagement of a professional licensing consultant
• Contract with Pagoda Security for SIA door supervisors
• Staff training and incident logging
• Joining the Brighton Crime Reduction Partnership
• Upgraded CCTV system
• Collaboration with delivery platforms to address driver conduct
• Noise control and neighbourhood respect

[Norulah Habibi] also proposed a voluntary reduction in the terminal hour from 03:00 to 01:00 as a demonstration of commitment to remedying problems and promoting the licensing objectives.

Brighton & Hove City Council Statement of Licensing Policy 2021

The report pack included extracts from the Brighton & Hove City Council Statement of Licensing Policy 2021, which outlines the council's approach to licensing decisions. The policy aims to promote the licensing objectives and sets out a general approach to making licensing decisions.

The licensing objectives are:

• Prevention of crime and disorder
• Public safety
• Prevention of public nuisance
• Protection of children from harm

The policy also includes a matrix approach for licensing decisions, which provides a framework of what the licensing authority would like to see within its area and gives an indication of the likelihood of success or otherwise to investor and businesses making applications. The matrix suggests that late-night takeaway licences will not be granted in Cumulative Impact Zones¹.