Work that had to hold up
Each of the engagements below began with real exposure — a statutory duty at risk, a decision that could be challenged, an audit finding that demanded an answer. In every case the test was the same: not whether we could state the law, but whether the client was left with something defensible, usable and built to survive scrutiny. The deliverables are set out in each study. Client names are used with permission.
Decision-Making Assurance & Equality Duty Compliance
The pressure
Like most authorities setting a budget under acute financial strain, Brent faced a specific legal exposure: savings decisions affecting frontline services can be quashed on judicial review where the authority cannot show it discharged the Public Sector Equality Duty under section 149 of the Equality Act 2010, or where consultation falls short of the Gunning principles. A single successful challenge can unwind a savings programme mid-year and force costly re-decisions. Brent’s decision-making framework had grown inconsistently, and the evidential trail behind major decisions was weaker than its risk demanded.
Our role
Devol Legal was instructed to review how significant budget and service-change decisions were taken and recorded, and to give the authority a single, defensible decision-making model that officers and members could actually follow under time pressure.
What we delivered
- Reviewed the governance architecture and decision pathways for budget and service-change decisions
- Assessed equality duty compliance and the strength of the supporting evidence base
- Designed a proportionate equality impact assessment framework and standard decision templates
- Built consultation guidance aligned to the Gunning principles, with a compliance checklist
- Delivered member and officer training on lawful, well-evidenced decision-making
Deliverables
- Equality impact assessment framework and proportionality guidance
- Member decision-report and cabinet-report templates
- Consultation compliance checklist (Gunning principles)
- Half-day training pack for members and statutory officers
Outcome
Brent moved to a consistent decision-making model in which major budget and service decisions now carry a documented equality and consultation audit trail. The authority is materially better placed to defend contested decisions, and officers have a repeatable framework rather than a case-by-case scramble.
Why it mattered: A lawful decision that is badly evidenced is almost as vulnerable as an unlawful one. The work gave the authority a defensible foundation under scrutiny, not merely better paperwork.
City-Wide Markets & Street Trading Modernisation
The pressure
High-street recovery and town-centre regeneration depend on markets that are vibrant and well run. Devonshire East’s street trading regime, built up under the Local Government (Miscellaneous Provisions) Act 1982, had become a patchwork of historic consents, inconsistent conditions and legacy instruments. It was slow to administer, inconsistent to enforce, and actively obstructed the council’s regeneration ambitions rather than supporting them.
Our role
Devol Legal was instructed to rationalise and modernise the framework, and to produce a single coherent regime suited to efficient administration and aligned with the council’s economic objectives.
What we delivered
- Reviewed the historic and current regulatory architecture and consent categories
- Identified the legal and administrative friction points slowing the service
- Drafted a modern street trading policy with rationalised consent categories
- Produced model consent conditions and a defensible fees structure
- Aligned the regulatory framework with the wider regeneration strategy and scheme of delegation
Deliverables
- Consolidated street trading policy
- Model consent conditions and fees structure
- Scheme of delegation for trading decisions
- Officer administration handbook
Outcome
The council moved from a fragmented inheritance to a single, coherent regime: faster consent processing, consistent enforcement, and a regulatory framework that works with the regeneration strategy instead of against it.
Why it mattered: Markets and street trading are economic and political questions as much as regulatory ones. The engagement mattered because it treated all three together rather than producing a tidy policy that ignored delivery.
Licensing & Illegal Working Enforcement Alignment
The pressure
Under the Immigration Act 2016, licensing authorities are responsible authorities for illegal-working considerations in alcohol, late-night refreshment and taxi and private hire licensing. In practice the approach varied widely between areas, information-sharing between licensing teams and immigration enforcement was inconsistent, and decisions risked being taken on an unclear legal and data-protection footing — a poor position from which to defend a refusal or revocation.
Our role
Devol Legal was asked to bring consistency and legal clarity to the interface between local authority licensing and immigration enforcement, in a form capable of adoption beyond the initial pilot areas.
What we delivered
- Mapped the legal and operational interfaces between licensing and immigration enforcement functions
- Identified where local practice and statutory expectations were misaligned
- Drafted a multi-agency operating protocol for consistent cross-agency working
- Built an information-sharing framework compliant with the UK GDPR and Data Protection Act 2018
- Produced licensing decision templates and practitioner guidance suitable for wider adoption
Deliverables
- Multi-agency operating protocol
- Lawful information-sharing agreement (UK GDPR / DPA 2018)
- Licensing decision and reasons templates
- Practitioner guidance note
Outcome
Participating areas moved to a consistent, defensible approach with a clear lawful basis for sharing information and reaching decisions. The framework provided a disciplined foundation for cross-agency coordination and a model suitable for broader rollout.
Why it mattered: This is a sensitive area where inconsistency invites challenge. The value lay in making a difficult statutory framework lawful, consistent and genuinely usable by frontline officers.
Taxi Licensing Reform & Driver Standards Framework
The pressure
Westborough’s taxi licensing regime had grown incrementally over more than a decade without a comprehensive review, and sat uneasily against the Department for Transport’s Statutory Taxi and Private Hire Vehicle Standards and the safeguarding expectations that now drive the fit-and-proper test. Driver standards, vehicle conditions and enforcement thresholds varied in practice. Two judicial review challenges in the preceding eighteen months had already exposed procedural weaknesses in how decisions were made and recorded.
Our role
Devol Legal was instructed to find the root causes of the procedural failures and to give the council a modern, safeguarding-led licensing regime built to withstand challenge from the outset.
What we delivered
- Conducted a full policy and procedural audit across hackney carriage and private hire licensing
- Analysed both judicial review decisions and pinpointed the governance weaknesses behind them
- Drafted a revised licensing policy covering driver standards, vehicle conditions and enforcement escalation
- Redesigned the committee decision-making process with structured decision and reasons templates
- Delivered training for licensing committee members and officers
Deliverables
- Revised hackney carriage and private hire licensing policy
- Driver fit-and-proper assessment framework
- Committee decision templates and scheme of delegation
- Member and officer training programme
Outcome
Westborough adopted a modernised regime with markedly stronger procedural foundations. No further judicial review challenges have been brought since implementation, officer confidence in decision-making improved, and member satisfaction with committee processes increased.
Why it mattered: The council had been reacting to challenges without addressing their cause. The work mattered because it replaced a fragile regime with one designed to hold up under scrutiny.
Regulatory Services Restructure & Operating Model
The pressure
Against the financial backdrop that has pushed several authorities towards section 114 notices, Wirral had to take 25% out of its regulatory services budget while holding statutory service levels across environmental health, trading standards and licensing. Earlier restructuring attempts had stalled, blocked by a lack of confidence in the proposed model and unresolved concerns about legal risk to statutory functions.
Our role
Devol Legal was engaged to provide the combined legal and operational advice needed to design and implement a new operating model that could deliver the savings without breaching statutory duties.
What we delivered
- Mapped the full regulatory services function across three directorates
- Identified duplication, over-specification and misaligned resource allocation
- Designed a consolidated, risk-based operating model across all regulatory functions
- Built a governance framework with escalation pathways and performance indicators
- Supported the formal consultation process through to go-live
Deliverables
- Risk-based target operating model
- Governance and escalation framework
- Performance indicator set
- Consultation and implementation plan
Outcome
The restructure was implemented on schedule and within budget, delivering a 27% cost reduction while maintaining full statutory compliance. The risk-based model improved case prioritisation and cut average case resolution times by 18%.
Why it mattered: This was not a headcount exercise. The challenge was to redesign how regulatory services worked so the reduction was absorbed through better design rather than reduced capability.
Procurement Remediation & Procurement Act 2023 Transition
The pressure
An internal audit identified significant weaknesses in procurement governance — incomplete documentation trails, inconsistent evaluation and weak oversight of contract variations — at precisely the moment the Procurement Act 2023 came into force, bringing new transparency, debarment and contract-management duties. The authority had to remediate the audit findings and transition to the new regime at the same time, without stalling live procurements.
Our role
Devol Legal was instructed to lead the remediation programme and to align the authority’s procurement framework with the new statutory regime in a single coordinated effort.
What we delivered
- Reviewed procurement procedures, documentation and governance arrangements end to end
- Addressed each audit finding with a specific remediation plan and timetable
- Redrafted standing orders and procurement procedure rules to reflect the Procurement Act 2023
- Introduced risk-based supplier tiering across 280+ active contracts and a transparency-notice workflow
- Delivered training for procurement officers and budget holders
Deliverables
- Revised standing orders and procurement procedure rules (Procurement Act 2023-aligned)
- Evaluation and contract-management protocols
- Supplier risk-tiering model and transparency-notice workflow
- Officer and budget-holder training programme
Outcome
All audit findings were resolved within the agreed timetable. The follow-up audit found no outstanding issues and rated the function as providing “substantial assurance”, and the new framework has since been adopted as a model by two neighbouring authorities.
Why it mattered: Procurement failures in the public sector carry real consequences — legal challenge, wasted public money and reputational damage. The work converted a crisis into a stronger system that was already fit for the new statutory regime.
Statement of Licensing Policy & Cumulative Impact Assessment
The pressure
Croydon’s Statement of Licensing Policy under the Licensing Act 2003 had not been substantively reviewed for three statutory cycles. It no longer reflected current case law, lacked a defensible cumulative impact assessment, and was increasingly exposed to being characterised in appeals as an inadequate framework — a serious problem for an authority that cannot afford to lose contested decisions at hearing.
Our role
Devol Legal was commissioned to review and redraft the Statement of Licensing Policy and to build an evidence-based cumulative impact assessment for two defined areas of the borough.
What we delivered
- Reviewed the existing policy against current legislation, statutory guidance and case law
- Engaged responsible authorities, residents’ groups and the licensed trade
- Built a cumulative impact evidence base from crime, environmental health and public health data
- Drafted a revised Statement of Licensing Policy covering all four licensing objectives
- Supported the formal consultation and committee adoption process
Deliverables
- Revised Statement of Licensing Policy
- Cumulative impact assessment and evidence base (two areas)
- Consultation framework and responses analysis
- Committee report and adoption pack
Outcome
The revised policy was adopted unanimously and has since been cited positively in two appeal proceedings. The cumulative impact assessment gives the authority a stronger evidential basis for contested decisions in the defined areas.
Why it mattered: A weak licensing policy undermines every decision made under it. The work gave the authority a defensible foundation for its licensing function rather than a document that existed only in name.
Fitness to Practise Governance & Process Review
The pressure
The NMC’s fitness to practise function faced rising caseloads and lengthening resolution times, under the close watch of the Professional Standards Authority. External stakeholders had raised concerns about procedural consistency, and an independent review had found fragmentation in how cases were triaged, investigated and escalated across practice areas. The framework had to be strengthened without disrupting live casework.
Our role
Devol Legal was instructed to identify the procedural and structural weaknesses driving delay and inconsistency, and to design and support an improved operating model.
What we delivered
- Reviewed the fitness to practise process from referral through to panel hearing and disposal
- Mapped decision pathways and pinpointed inconsistency, duplication and unnecessary delay
- Redesigned the triage and case-allocation framework to reduce bottlenecks
- Built escalation protocols, quality-assurance mechanisms and performance indicators
- Supported phased implementation through staff engagement across all practice teams
Deliverables
- Redesigned triage and case-allocation framework
- Escalation protocols and quality-assurance mechanism
- Performance indicator set
- Phased implementation and staff engagement plan
Outcome
The revised framework cut average case resolution times by 23% in the first year. Procedural consistency improved measurably, internal quality audits reported significantly less process variation, and the improvements were noted positively in the NMC’s subsequent annual performance review.
Why it mattered: Regulatory bodies exist to protect the public, and delay or inconsistency in fitness to practise work undermines that mission directly. The work strengthened the NMC’s ability to discharge its core function more effectively and more fairly.