Rana Ihsan ul Haq v Registrar of Approved Driving Instructors

1. I have considered the appeal bundle, the written materials, and the oral submissions made at the hearing on 11 February 2026. The Appellant appeals against the Respondent’s refusal to grant a second trainee driving instructor licence.

2. The legal framework governing trainee licences is set out in the Road Traffic Act 1988 and the Driving Instructors (Registration) Act 2016 , together with associated statutory instruments. The purpose of these provisions is not to create an alternative route to registration, but to provide a strictly time-limited opportunity for trainee instructors to obtain practical experience while preparing for the Approved Driving Instructor (ADI) qualification examinations.

3. The Respondent’s policy and published guidance emphasise that trainee licences are exceptional and limited in duration. They are intended to allow a trainee instructor to gain experience for up to six months, after which the trainee should ordinarily be in a position to reach the required standard.

4. The Appellant passed the driving ability test but has failed the instructional ability test once. He also cancelled two further test dates scheduled for 11 December 2024 and 19 March 2025. Despite a lengthy period of opportunity, he has not demonstrated sufficient progress towards achieving ADI registration.

5. The Appellant submitted an application for a second trainee licence before the expiry of his first licence. Under the statutory scheme, this had the effect of keeping his existing licence in force until determination of the application, and subsequently, until disposal of this appeal. He has therefore been able to continue to give paid instruction throughout.

6. The Respondent refused the application on the grounds that the statutory purposes would be undermined by granting a further licence where the Appellant has already had ample time and has not demonstrated progress to the required standard. The Respondent also noted that refusal of a second licence does not prevent the Appellant from continuing his training: a trainee licence is not required to attempt the instructional ability test, nor is it required for unpaid practice or for training with an Approved Driving Instructor.

7. I accept and adopt the Respondent’s reasoning. The statutory purpose is clear: trainee licences are strictly time-limited training opportunities, not an indefinite extension. Granting a further licence in circumstances where the Appellant has cancelled test dates, failed to demonstrate progress, and had more than sufficient time to prepare would frustrate the legislative intention and place an undue administrative burden on the licensing system.

8. I also note that the Appellant has a further attempt at the instructional ability test booked for April 2026. He is not prevented from sitting that test by the refusal of a second licence.

9. I therefore find that the Respondent’s refusal was proportionate, fair, and fully consistent with the statutory principles governing trainee driving instructor licensing.

10. The appeal is therefore dismissed. Judge Brian Kennedy Tribunal Judge 11 February 2026