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The Hardship Test for Limited Licences Under s105

By R M Norris, Barrister

To get a limited licence, you must prove extreme hardship to yourself or undue hardship to another person. Here is how the court assesses hardship under section 105.

To obtain a limited licence under section 105 of the Land Transport Act 1998, you must demonstrate either extreme hardship to yourself or undue hardship to another person. This is the central evidentiary requirement — without it, the court will not grant a limited licence regardless of your circumstances.

The statutory test

Section 105 provides that the court may make an order authorising the issue of a limited licence if satisfied that the disqualification or suspension will cause, or is causing:

  • Extreme hardship to the applicant, or
  • Undue hardship to any other person

The applicant bears the burden of proof. You must present evidence that makes the court satisfied on the balance of probabilities that the hardship threshold is met.

Extreme hardship (to you)

Extreme hardship is a high threshold. The court looks for specific, concrete consequences — not general inconvenience. Common categories include:

Employment hardship

The most common and strongest basis for a limited licence. You need to show:

  • Your job requires driving (deliveries, site visits, client meetings, transport between workplaces)
  • You will lose your job or face serious professional consequences without a licence
  • No reasonable alternative exists (public transport is unavailable, impractical, or insufficient)
  • Your employer confirms the situation in a sworn affidavit

Business hardship

For self-employed applicants or company directors:

  • The business depends on your driving for operations
  • You are the sole or primary driver — no employee or contractor can substitute
  • The business will suffer serious financial loss or may fail without your driving
  • Financial records support the claimed dependence

Medical hardship

  • You need to attend regular medical appointments that require driving
  • Public transport or other alternatives are not available or practical
  • The medical condition is serious and treatment cannot be delayed

Educational hardship

  • Attending a course or training programme essential for employment
  • No alternative transport to the institution

Undue hardship (to another person)

Undue hardship focuses on the impact on someone else — not you. This is a slightly lower threshold than "extreme" but still requires specific evidence:

Dependants

  • A child who needs transport to school, medical appointments, or therapy
  • An elderly or disabled family member who depends on you for transport
  • A spouse or partner who cannot drive and has essential transport needs

Employer or colleagues

  • Your employer or business partner will suffer if you cannot perform your role
  • Colleagues may be required to take on unreasonable additional duties

Clients or patients

  • If you work in healthcare, social services, or similar fields where your clients depend on your mobility

Evidence that supports hardship

Hardship type Key evidence
Employment Sworn employer affidavit, employment contract, job description, roster
Self-employed Financial records, client contracts, business registration
Medical Specialist letter, appointment records, treatment plan
Dependants Affidavit explaining dependant's needs, school/medical letters
Transport alternatives Bus/train timetables, Google Maps showing lack of routes

What does NOT constitute hardship

The court will not accept:

  • General inconvenience — "It's hard to get around without a car"
  • Lifestyle impact — "I can't visit friends" or "I can't go to the gym"
  • Self-created hardship — situations where you deliberately put yourself in a position requiring a licence
  • Vague claims — "I need my licence for work" without specifics

The evidence must be specific, documented, and supported by sworn third-party confirmation (employer affidavit, medical certificates, affidavits from dependants).

The court's discretion

Even where hardship is established, the court retains a residual discretion under s105. The court considers:

  • The nature and seriousness of the offence
  • Public safety — whether granting the licence poses a risk
  • Whether the applicant has shown insight and remorse
  • The proposed conditions — whether they adequately mitigate risk

In practice, if the statutory test is met and no bars apply, limited licences are generally granted — particularly for first offenders with strong employment evidence. Police opposition, if it occurs, is most often directed at the proposed conditions rather than the grant itself.

Frequently asked questions

Extreme hardship applies to you personally — typically loss of employment or inability to earn a living. Undue hardship applies to another person who depends on you — for example, a child who needs transport to medical appointments or a family member who cannot drive.

No. The inconvenience of not having a licence is not hardship. You must show specific, concrete consequences — such as actual risk of job loss, inability to reach medical treatment, or a dependant left without essential transport.

Yes. Many successful applications combine employment hardship with hardship to dependants. The stronger and more varied your evidence, the more compelling the application.

Not necessarily. Under s105, the court has discretion. Even if hardship is established, the court considers public safety and the nature of the offence. However, if the statutory test is met and no bars apply, limited licences are generally granted.

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