The Law permits DVSA to impound a Vehicle if it is used without an Operator Licence putting members of the public at risk. In this case a Dutch company had been warned on several occasions that their vehicles could be impounded if they broke the rules. The vehicle would be sold by DVSA and net proceeds of sale given to the Owner. The company appealed to the Upper Tribunal against the decision of the Traffic Commissioner. They argued that they had taken steps to prevent unlawful use and future unlawful use. DVSA were represented by me in opposing the Appeal. New law was made by the Upper Transport Tribunal that, in interpreting the word 'steps', the appellant must prove that it had taken all reasonable steps and provided a list of documents that the court would expect to be produced to meet the test.