I have not yet commented on the new red and yellow-card scheme for "backsliding" licensees because it seems to me to be yet another Home Office-inspired attempt by the Government to gain headlines at the expense of the trade.
Ministerial statements would suggest that part of the backsliding is by local authorities, which are not "pulling their weight" when it comes to punishing errant individual sellers. The implication seems to be that councils are being soft on the trade, which in fact is far from the truth.
The Licensing Act itself was meant to be corrective, not punitive. The whole object of reviewing a licence was to put matters right and meet the licensing objectives in future.
In fact, the statutory Guidance issued by the Department for Culture Media & Sport under the Act stresses that a review should not be seen as an opportunity for additional punishment for some infringement, but as an examination of the causes of the event and a discussion on how to remedy the situation.
But ministers are going nowhere near that principle in the latest rounds. They have a different agenda and that is to highlight the licensed trade's involvement in the evils of alcohol abuse, principally the sale of drink to minors.
To cut the number of ascertained offences from three to two and then to issue a kind of death sentence as a result is a very severe pressure on any industry, let alone one where it is well established that much of the fault lies with the purchasers themselves.
What I am most concerned about is the pressure being placed on local authorities to be "tougher", as if they are not issuing enough death sentences on licensees' businesses. In my experience, most councils approach the issues on a basis that allows the accused individual to explain the circumstances, suggest remedies of his own accord and reach a situation where the licence does not have to be extinguished.
In the main, we are talking about a "crime", which in itself does not involve a totally outlawed activity — the consumption of alcohol in this country by persons under 18 is not in itself illegal.
But the Government is working for political reasons to demonise the whole of the licensed trade for the shortcomings of a very small minority and the accidental errors of a considerable number more.
The yellow and red-card "scheme", if it exists, cannot be tacked on to the existing law and is merely another form of window dressing.
It should be confined to football, where it belongs.