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Police Opposition to Limited Licence Applications

By R M Norris, Barrister

The police prosecutor can oppose your limited licence application. Here is when opposition is likely, what it looks like in practice, and how to address it.

The police prosecutor has the right to make submissions on your limited licence application — including opposing it entirely or seeking narrower conditions. Understanding when opposition is likely and how to address it helps you prepare a stronger application.

The prosecutor's role

The police prosecutor reviews your application after it is served on them. Their role is to assist the court by:

  • Identifying any statutory bars that may apply
  • Assessing whether the hardship evidence meets the threshold under s105
  • Considering whether the proposed conditions are appropriate from a public safety perspective
  • Making submissions to the judge at the hearing

The prosecutor is not automatically adversarial — in many cases they will not oppose a well-prepared application.

When opposition is likely

Statutory bar applies

If the prosecutor identifies a statutory bar under s103(2), they will oppose. This includes:

  • Interlock bar (s103(2)(e))
  • Repeat offence bar (s103(2)(d))
  • Indefinite disqualification (s103(2)(a))
  • Driving while disqualified (s103(2)(c))
  • Currently on interlock or zero alcohol licence (s103(2A))

If a bar applies, the court cannot grant the licence regardless of hardship. This is not really "opposition" in the discretionary sense — it is pointing out a legal impossibility.

Weak hardship evidence

If the prosecutor considers the evidence insufficient to meet the hardship threshold under s105:

  • Vague affidavit without specifics
  • No sworn employer affidavit or third-party confirmation
  • Claims of hardship that are not documented
  • Alternative transport options that appear available but are not addressed

Broad proposed conditions

Even where hardship is accepted, the prosecutor may submit that the proposed conditions are too generous:

  • Driving hours broader than necessary for work
  • Driving area larger than the actual work routes
  • Including weekend or evening driving without justification
  • Requesting conditions for purposes beyond those supported by evidence

Serious offence

For more serious offences (high readings, injury involved, aggravating circumstances), the prosecutor may oppose on public safety grounds — even if the hardship evidence is strong.

Driving record

A history of previous driving offences, previous limited licence applications, or previous breaches of limited licence conditions may prompt opposition.

Types of opposition

Type What the prosecutor seeks
Outright opposition Application should be declined entirely
Condition-based opposition Grant the licence but with narrower conditions
Adjournment request More time needed to review the application
Request for further evidence Application is incomplete — more information needed

In practice, condition-based opposition is the most common form. The prosecutor accepts that a limited licence is appropriate but submits that the conditions should be tighter.

How to address opposition

Before the hearing

  • Serve promptly — give the prosecutor enough time to review
  • Strong evidence — comprehensive affidavit, sworn employer affidavit, transport research
  • Reasonable conditions — do not ask for more than you actually need
  • Address weaknesses — if you know a point is vulnerable, address it proactively in your evidence

At the hearing

If the prosecutor opposes, the judge will typically:

  1. Hear the prosecutor's submissions (their reasons for opposing)
  2. Give you (or your lawyer) the opportunity to respond
  3. Ask questions of either party
  4. Make a decision

Your response should:

  • Address each specific point raised by the prosecutor
  • Refer to your evidence that counters their concerns
  • Be willing to accept modified conditions if reasonable
  • Remain respectful and factual — do not argue with the prosecutor

Accepting modified conditions

Often the most practical approach is to accept reasonable modifications. If the prosecutor seeks narrower hours or a smaller driving area, and you can work within those constraints, agreeing to the modification may secure the licence more quickly than disputing the point.

If the application is declined

If the court declines the application after police opposition, you may be able to:

  • Reapply with stronger evidence addressing the court's concerns
  • Appeal the decision (though this is rare for limited licence matters)
  • Wait until circumstances change (e.g. stand-down period passes, evidence improves)

A declined application is not the end of the road — but it does mean the court was not satisfied on the evidence presented. Addressing the specific deficiency and reapplying is usually the practical path forward.

Frequently asked questions

Most straightforward applications with strong evidence are not opposed. Opposition is more common where the offence was serious, the proposed conditions are too broad, or the hardship evidence is weak.

Common grounds include: a statutory bar applies (e.g. interlock or repeat offence bar), insufficient hardship evidence, proposed conditions are too broad, public safety concerns, or the nature of the offence warrants opposition.

Yes. Police opposition does not automatically defeat the application. The judge makes the final decision. If your evidence is strong and no statutory bars apply, the court can still grant the licence — potentially with modified conditions.

Not always. Some prosecutors will contact you or your lawyer before the hearing to indicate their position. Others will only indicate their stance at the hearing itself.

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