CHA licence revocation held disproportionate after prolonged suspension, with prior punishment deemed sufficient for established compliance lapses.

Established lapses in supervision and compliance with licensing regulations can justify penal action against a CHA, but continued revocation may be excessive where the licensee has already remained out of business for more than 3.5 years. The punishment already suffered was treated as sufficient in the circumstances, so the revocation of the CHA licence was set aside and the licence was directed to become operative with immediate effect.

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Issues: Whether revocation of the CHA licence and other consequential action were justified for the proved lapses, or whether the punishment already suffered made further revocation excessive.

Analysis: The appellant was found to have committed lapses in supervision and compliance with the licensing regulations, and such lapses justified penal action. However, the appellant had already remained out of business for more than 3.5 years. In the circumstances, the punishment already suffered was considered sufficient, and continued revocation was held to be disproportionate to the facts of the case.

Conclusion: The revocation of the CHA licence was set aside and the licence was directed to become operative with immediate effect.

Ratio Decidendi: Where lapses are established but the licensee has already suffered a long period of business suspension, further revocation may be modified if the punishment already undergone is sufficient in the circumstances.

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