Light motor vehicle licence covers light goods carriage within weight limits; later form changes apply prospectively.

A licence to drive a light motor vehicle, as understood under the statutory scheme then in force, authorised driving of a light goods carriage or transport vehicle within the prescribed weight limit. The later substitution of transport vehicle in the licence forms operated prospectively and did not retrospectively invalidate an existing licence. On that basis, the driver was treated as duly authorised to drive the offending vehicle, and the insurer could not avoid liability by alleging absence of proper authorisation.

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Issues: Whether a driver holding a licence to drive a light motor vehicle was authorised to drive the offending vehicle, which was a light goods carriage/transport vehicle, and whether the insurer could avoid liability on that basis.

Analysis: The statutory definition of light motor vehicle covered a transport vehicle whose gross vehicle weight or unladen weight did not exceed the prescribed limit. At the relevant time, the rules and forms framed under the Act treated light motor vehicle as including vehicles of the kind involved, while the later substitution of transport vehicle for medium and heavy goods vehicle in the forms was prospective. A licence valid for a light motor vehicle therefore continued to authorise driving of a light goods carriage, and the amendment could not be applied retrospectively to invalidate an existing licence.

Conclusion: The driver possessed a valid and effective licence for the vehicle involved, and the insurer could not avoid liability on the ground of absence of proper authorisation.

Ratio Decidendi: A licence to drive a light motor vehicle, as understood under the statutory scheme then in force, authorises driving of a light goods carriage within the prescribed weight limit, and a subsequent amendment expanding the form of authorisation operates only prospectively.

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