The Licensing Sub Committee D met on Thursday 5 February 2026 to consider a review of the premises licence for Best Foods Mega Mart. The committee decided to keep the existing licence but imposed additional conditions, including those from the Home Office, to address concerns about illegal working.

Review of Best Foods Mega Mart Premises Licence

The committee considered an application for the review of the premises licence for Best Foods Mega Mart, located at 445 to 453 Bromley Road, BR1 4PH. The review was initiated by Home Office Immigration Enforcement due to concerns about illegal working at the premises.

Alex Romano, representing the Home Office, presented the case, highlighting that two individuals were found working illegally at the store on 11 April 2025. Both were paid in cash, recruited informally, and paid well below the National Minimum Wage, indicating labour exploitation. No right-to-work checks were carried out. This led to an £80,000 civil penalty, which remained outstanding at the time of the review application, although payments have since commenced. Mr. Romano argued that illegal working undermines the licensing objective of preventing crime and disorder, and that revocation of the licence should be considered, citing Section 182 Guidance¹ of the Licensing Act 2003.

Councillor Billy Harding, Vice Chair of the Audit and Risk Committee, questioned the outstanding penalty amount and the ongoing risk of crime and disorder. Mr. Romano stated he did not have the exact figures for the outstanding penalty but expressed a lack of confidence in any mitigations put in place, as no proactive steps to prevent future breaches were evident.

Councillor Rachel Onokosi inquired about the continued risk, noting the significant civil penalty. Mr. Romano explained that civil penalties confirm illegal working, which is a criminal matter engaging the prevention of crime and disorder objective. He clarified that the civil penalty system encourages employers to conduct proper checks. He also confirmed that nine individuals were encountered during the visit, with seven cleared of immigration offences.

Sean Rodway from the Metropolitan Police stated that he supported the review application, noting the failure to implement robust right-to-work checks. He reported that a premises licence check conducted on 13 January 2026 found two minor offences: a lack of notices advising customers to respect neighbours and leave quietly, and the sale of four items with an alcohol content of 7.5% ABV or above, which were later confirmed to be premium beers and therefore not an offence. Mr. Rodway confirmed that, to his knowledge, the premises had not been known to the local police for other licensing issues.

Andrea Forrest, representing the licence holder, Mr. Subramaniam, argued that the Licensing Act is remedial, not punitive, and that her client had learned from his mistakes. She stated that all relevant documents, including right-to-work checks and staff training records, had been submitted. Ms. Forrest highlighted that her client was making payments towards the £80,000 penalty and that since the immigration visit, there had been no further issues reported by the police. She referred to Section 1120 of the statutory guidance, which suggests that remedial action should be directed at the causes of concerns, and that revocation is not inevitable if robust remedial action has been taken.

During the questioning of Ms. Forrest, Councillor Harding asked for more details about the allegation of staff being paid below the minimum wage. Ms. Forrest stated that her client accepted he had made mistakes and was now rectifying them, with all staff now paid through a PAYE system.

After deliberation, the committee decided to allow the existing licence to remain in place, subject to the existing conditions. However, they imposed additional conditions, including those outlined by the Licensing Authority on pages 51 and 52 of the report pack, and the following three conditions from the Home Office:

1. The licence holder must carry out relevant right-to-work checks for all prospective employees prior to the commencement of employment, including individuals undergoing trial shifts or those working on a casual basis.
2. The licence holder must retain copies of documents obtained during right-to-work checks. These documents must be stored securely at the premises or be digitally accessible from the premises to facilitate inspection by an authorised person.
3. The licence holder or any person representing them must be able to produce documents relating to right-to-work checks without delay upon request by an authorised person.

Where there was duplication between the Licensing Authority's conditions and the Home Office conditions, the Home Office conditions would take precedence. A decision notice detailing the reasons for this decision would be sent out within five working days.