Section 172A(1) of the Licensing Act 2003 gives a licensing authority the power to make an ‘early morning alcohol restriction order’ if it considers it ‘appropriate’ for the promotion of the licensing objectives1. However, early morning alcohol restriction orders made under these provisions are subject to the 2003 Act’s existing provisions (under Section 172) which allow the Secretary of State to make a licensing hours order relaxing opening hours for special occasions2. The 2003 Act defines an