Not our Fantasy: Template Objection Letter


Fantasy 'Gentleman's Club' looking a little worse for wear.
Fantasy ‘Gentleman’s Club’ looking a little worse for wear.

Fantasy, 12-14 Bath Road, Cheltenham GL53 7HA has applied for a Sex Establishment Licence for the purpose of lap dancing.

Objections to this application need to be with Cheltenham Borough Council by Friday 5th May. The best way to do this is by email to

Alternatively, send to Licensing, Cheltenham Borough Council, Municipal Offices, Promenade, Cheltenham GL50 1PP.   Guidelines for anyone wishing to make a representation are available on the council’s website.

We have drafted a template letter  which you are welcome to use. Please include your name and address but your personal details should be redacted when any objections are passed on to the applicant or published as part of the Licensing Committee records.  If this venue has any impacts on your own particular circumstances, for example if you live, work or worship nearby or have a business in the vicinity, please include details.

Objection to the Sexual Entertainment Venue Licence for Fantasy, 12-14 Bath Road, Cheltenham GL53 7HA.

This is an objection letter to the application for this licence and I call for the council to refuse it.

I believe that the Council should refuse Fantasy’s Sexual Entertainment Licence application under the Discretionary Grounds for Refusal of the current Cheltenham Borough Council’s Sexual Entertainment Venues Licensing Policy on the following grounds:


In Cheltenham Borough Council’s SEV Policy 2014 it states that

Cheltenham is a relatively small urban borough that is predominantly residential in nature. The Council has already resolved that it is inappropriate to licence SEVs in or in the vicinity of, amongst others, residential areas. It is the Council’s policy therefore that there is no locality outside of the adopted Central Shopping Area in which it would be appropriate to license a SEV. Accordingly the appropriate number of SEVs for outside of the adopted Central Shopping Area is nil.

Fantasy is located outside the Central Shopping Area, in a location where the appropriate number of SEVs is nil.

The licensing committee should also have regard to other aspects of Fantasy’s location in line with Cheltenham Borough Council’s SEV policy on sensitive locations:

Properties with sensitive uses or in sensitive locations

  • 4  In considering if the grant, renewal or variation of the licence would be inappropriate, having regard to the character of the relevant locality or to the use to which any premises in the vicinity are put, the Council shall consider, inter alia, whether the grant of the application would be appropriate, having regard to:

a)  The fact that the premises are sited in a residential area;

Vernon Place which is adjacent to Fantasy and reached by the road next to Fantasy’s side entrance is exclusively residential. There are many residential properties nearby on the High Street, Bath Street, Wellington Street, Bath Road, Cambray Place and Bath Parade.  Residential property in and around the town centre makes use of otherwise redundant space above shops and provides much needed affordable housing particularly for young adults.

b)  Whether the premises are sited near shops used by or directed at families or children, or on frontages frequently passed by the same;

Sainsbury’s Local which is on the corner of Bath Road and the High Street is open until 11pm.

c)  Whether the premises are sited near properties which are sensitive for religious purposes e.g. churches, mosques, temples;

Fantasy is near both the Salvation Army Community Church in Bath Road and Cambray Baptist Church.  The club is in the direct sightline of Cambray Baptist Church. Both these places of worship have evening worship and activities, including youth activities.

d)  Whether the premises are sited near premises or areas which are sensitive because they are frequented by children, young persons or families, including but not limited to educational establishments, leisure facilities such as parks, libraries or swimming pools, markets and covered markets.

Fantasy is close to Sandford Park, and directly adjacent to the designated cycle trail through the park.  It is near the Playhouse Theatre which has activities for children and teenagers as well as evening shows aimed at the whole family.  Nearby schools include the Inlingua Language School, Janet Marshall Dance Studios & Hickory Dickory Day Nursery in Cambray Place. It is next to a taxi rank and a bus stop. At some time, in the not too distant future, Cheltenham Borough Council will be relocating to Delta Place, on the opposite side of Bath Road to Fantasy.  The council holds regular evening meetings open to the public.

Although the Licensing Committee has previously approved an SEV licence in this location, each application is an opportunity to look at the case afresh.  The Council is asked to note that in the last few years Leeds City Council successfully defended a refusal to renew two SEV licenses at judicial review:

R (Bean Trading A Ltd) v Leeds City Council (2014)

It was held that a council can “take a fresh look” despite no changes to the character of locality.

The case of Thompson v Oxford City Council (2014) was also supported at court of appeal, and the Council told they could “take a fresh look” at any application for renewal.

The Council is also asked to note the following from Philip Kolvin regarding licence renewal:

‘Given that there is potential for the discretion to be exercised afresh, the renewal should not just be a rubber stamping exercise, but an opportunity, if needed, to review the principle and content of the license.

The Public Sector Equality Duty and Gender Equality

Cheltenham Borough Council has “statutory obligations in relation to disability, race and gender” ensuring that these factors are not used to discriminate against anyone.  I believe that a sexual entertainment venue directly discriminates against women by normalising the sexualisation and objectification of women, and that this contributes to their sexualisation and objectification in other areas of society.  The Council has a fundamental and non-delegable role to give due regard to the Public Sector Equality Duty, including tackling gender inequality.  This applies notwithstanding the fact that Parliament has legislated to allow the possibility for SEVs to be licensed in specific areas – subject to the choices of the local communities.   Many women have voiced their concerns and fears about the presence of Fantasy in previous objections.

When walking around this area, which as a Council you encourage people to do due to the other businesses and services in the area, women feel nervous because of the SEV and have to change their behaviour because of it being there, for example having to look around to see if there are people coming out of the SEV, take a different route walking to the centre of town so that they do not have to go past the SEV. Women should not have to feel like this in their town and this is discriminatory.

As Philip Kolvin (2010) cites the Royal Town Planning Institute’s Gender and Spatial Planning Good Practice Note:

In relation to the 24-hour economy policy, ensure that the views of women are considered.  Evidence shows that in certain locations, lap-dancing and exotic dancing club make women feel threatened or uncomfortable’

Kolvin continues with:

‘If a woman, whether objectively justified or not, fears to use part of the town centre characterised by sex establishments, this may be argued to amount to discrimination, in that her access to the public infrastructure of the town is impaired in comparison to that of men.  Where relevant these considerations ought properly to be taken into account by authorities at the decision-making stage, and possibly at the policy-making stage[2].

This is further corroborated by 2012 research published in Criminal Justice Matters which states that:

‘. . . the women describe feeling frightened, disempowered, violated, embarrassed, unsafe (particularly if men are around) and avoid certain streets at night where they know there is a lap dancing club.’

Cheltenham prides itself on the quality of its night time economy, which is well deserved judging by its Purple Flag award.  This award recognises towns and cities that have a vibrant and diverse mix of dining, entertainment and culture while promoting the safety and wellbeing of visitors and local residents.  This should include all residents, including women and girls.

Has Cheltenham Borough Council carried out an Equality Impact Assessment on its SEV Policy?

I look forward to hearing from you.

Insert name and address


Kolvin, P (2010) Sex Licensing, The Institute of Licensing p.87

Patiniotis, J. & Standing, K. (2012) ‘License to cause harm? Sex entertainment venues and women’s sense of safety in inner city centres’ in Criminal Justice Matters, 88:1, 10-12




Leave a Reply

Your email address will not be published. Required fields are marked *