Do the proposals give rise to doubts whether it is ultra vires?
104. We have no concerns to raise under these headings. Do the proposals require elucidation or appear to be defectively drafted? 105. The lengthy sections of the Licensing Act 1964 appended to the Explanatory Document (in the form of a Keeling Schedule) provide ample evidence of the complexity of the licensing laws in their current state. Although implementation of the two parts of the present proposal might be thought to offer some simplification, it is hardly likely to simplify life for restaurateurs to be presented with this change in the knowledge that the whole licensing regime is likely now to be overhauled. Although we have no grounds for opposing the proposal on the technical grounds of defective drafting, we regard this as a further argument against implementation at this stage. Do the proposals appear to be incompatible with any obligation arising from membership of the European Union? 106. We have no concerns to raise under this heading. Extent 107. The proposed Order would
