Decision

1. Merkur Slots UK Limited (“the Applicant”) applied for a variation of a Premises Licence, for the purposes of ‘Bingo’ on 12th February 2026 for Merkur Slots, 40 Deptford High Street, London SE8 4AF (“the Premises”).
2. The Application was advertised in accordance with Regulation 12 of the Gambling Act 2005 (Premises Licences and Provisional Statements) Regulations 2007. The last date for representations was 12th March 2026. The Application sought the following amendments:

•                     To replace condition 1 of Annex 1 with the following: “The provision of gambling activities and the premises opening hours are: 09:00 to 06:00 the following morning Monday to Sunday.’”

•                     To updated condition 13 of Annex 1 to state: “There shall be no pre-planned single staffing between 20:00 and 06:00.”

•                     To amend the reference to operational hours stated under Part 3 of the premises licence and replace with the following wording:
“The following conditions, which would otherwise attach to the licence by virtue of regulations made under section 168 of the Gambling Act 2005, have been excluded by the issuing authority under section 169(1)(b) of that Act:
- Subject to paragraph 2, no facilities for gambling shall be provided on the premises between the hours of midnight and 9am.
- The condition in paragraph 1 shall not apply to making gaming machines available for use.”

1. Seven representations were received from interested persons on the grounds of the following licensing objectives:
   To prevent gambling from being a source of crime & disorder
   To protect children & other vulnerable persons from being harmed or exploited by gambling
2. The Licensing Sub-Committee A held a hearing on 10th June 2026 to consider the Application.
3. The Applicant was represented by Sarah Le Fevre of Counsel. Ms Le Fevre explained that the premises had had a bingo premises licence since 7th September 2021. Ms Le Fevre stated that the Applicant was an extremely experienced operator, with well over 230 premises across the country. Ms Le Fevre referred to the legal framework set out in paragraphs 30-35 of her skeleton argument, stating that unlike the Licensing Act 2003 gambling was an explicitly permissive regime given the ‘aim to permit’ principle. Ms Le Fevre submitted that the gambling licensing objectives did not include public nuisance and that the Applicant had provided robust, concrete evidence of how the Application would promote the licensing objectives. The extension in hours applied for meant that it would not affect schools, and any suggestion that additional gambling was inherently a risk of harm was incorrect. Ms Le Fevre stated that planning matters were expressly excluded by statute and that need was also irrelevant. Ms Le Fevre submitted that the fact that there were no objections from responsible authorities was important, as this reflected their lack of concerns. Ms Le Fevre advised that there was voluminous and concrete evidence as to how the premises operated in a calm, considered and controlled manner, with a very high ratio of staff to customers.
4. Meredith Eddy from the Deptford Society advised that this was a highly residential area and that allowing the premises to be open for almost 24hrs would be disruptive and contribute to crime and disorder. Ms Eddy stated that granting the Application would be incompatible with this particular High Street and the Council’s policies which seek to protect vulnerable people, as it would encourage gambling related harms. Ms Eddy concluded by saying that this was an area of very high deprivation and offering extended hours to gamble was counter-intuitive to anyone who was familiar with the High Street and knew the kind of vulnerable people that are on the High Street.
5. In summing-up, Ms Le Fevre commended the detailed evidence in the bundle to the Sub-Committee, which showed how the premises operates from the inside. Ms Le Fevre emphasised that it was not a betting shop and that there were few customers, typically just into double digits. Ms Le Fevre stated that customers were very carefully looked after and staff were engaged to identify any vulnerability. Ms Le Fevre concluded by stating that the Applicant was experienced, committed and responsible, and there had been no issues identified at the premises from responsible authorities. Stuart Jenkins, Director of Leveche Associates Ltd, added that he had worked with the Applicant for a number of years and that there was no evidence of children or vulnerable people being attracted to the premises. If they were attracted to the premises, then there were extensive measures in place to stop people entering the premises.
6. In summing-up, Ms Eddy stated that vulnerable people were people who put money in slot machines. Although there was no objection from the police, that was no guarantee there would not be any issues when the hours were extended.
7. In making its decision the Sub-Committee has considered all the papers contained in the report pack and submitted documents, including written submissions, together with the oral submissions made at the hearing. The Sub-Committee also considered the Council’s Statement of Principles for Gambling 2024-2027 and the Gambling Commissions’ Codes of Practice and Guidance to Licensing Authorities.
8. The Sub-Committee’s decision is to reject the application. Its reasons for doing so are as follows:

a.     Paragraph 6.2 of the Council’s Statement of Principles for Gambling 2024-2027 provides that the Council considers the term ‘vulnerable persons’ to include ‘people who gamble more than they want to; people who gamble beyond their means and people who many not be able to make informed or balanced decisions about gambling due to a mental impairment, changes in circumstances such as bereavement, loss of employment or ill health or due to alcohol or drugs.’

b.     The Applicant’s own Local Area Risk Assessment (“LARA”) demonstrates that the premises is located in an area of high deprivation, with the LARA stating that ‘Deprivation in Deptford High Street, London, SE8 4AF can be rated as 9 out of 10 or high.’ The Sub-Committee also had regard to the high concentration of nearby sensitive premises set out in the Applicant’s LARA, including vulnerable and addiction support services, homeless shelters and food banks, pawnbrokers and loan shops and other gambling premises. The Sub-Committee considered that the extension in hours sought would attract vulnerable people late at night and put them at greater risk of gambling-related harms. The Sub-Committee had regard to the operational safeguards put in place by the Applicant but did not consider these sufficient to ensure that vulnerable people would not be harmed or exploited by gambling. The Sub-Committee therefore did not consider that the Application would be consistent with the gambling licensing objectives.

c.      The Sub-Committee recognised that section 153 of the Gambling Act 2005 provides that in exercising its functions a licensing authority shall aim to permit the use of premises for gambling so far as the authority think it- (a) in accordance with any relevant code of practice under section 24, (b) in accordance with any relevant guidance issued by the Commission under section 25, (c) reasonably consistent with the licensing objectives (subject to paragraphs (a) and (b)), and (d) in accordance with the statement published by the authority under section 349. However, the aim to permit principle does not mandate granting every application in every location. Since the Sub-Committee concluded that granting the Application for the premises in this particular location would not protect vulnerable people from being harmed or exploited by gambling, the Sub-Committee considered that rejecting the application did not conflict with the aim to permit principle.

d.     The Sub-Committee considered whether its concerns could be addressed via condition but concluded that no conditions could address their concerns, which stemmed from an extension of hours in an area of such high deprivation with so many vulnerable people.

There is a right of appeal against this decision. Any appeal should be made to the Magistrates’ Court within 21 days beginning with the day on which the Applicant was notified of the decision.