Fatima Abukar

Dear Mr Irvine,  

Re: The Inquest Touching the Death of Fatima Abukar  
A Regulation 28 Report – Action to Prevent Future Deaths 

In response to your report dated 14 December 2022 (the “Report”), please find below our written response in 
accordance with paragraph 7(2) of Schedule 5 to The Coroners and Justice Act 2009. 

Thank you for sharing with us your Report and for bringing to our attention your findings and concerns. We are 
greatly  saddened  to  hear  about  the  death  of  Fatima  Abukar  and  we  extend  our  deepest  condolences  to  her 
family.  

At Amazon we work hard to earn and maintain customer trust, meaning that safety is a top priority for us. Last 
year,  we  invested  more  than $900  million  to  protect  our  stores  and  our  customers, building  robust  safety  and 
compliance  programs,  which  includes  the  continual  review  of  our  controls  to  ensure  appropriate  product 
information is displayed. While we note that there is no suggestion that any product purchased on any Amazon 
store was involved in Ms. Abukar’s death, we are willing to explain our processes in relation to the sale of e-
scooters. Specifically: 

-  we include a warning on product pages for e-scooters which makes clear that they are prohibited from 

use in any public road or space in the UK;  

-  we  make  this  warning  prominent  by  ensuring  it  appears  in  the  “About  this  Item”  section  and  is 

highlighted for customers’ attention using the heading “Important note” in bold font;  

- 

the warning also includes a link to the latest government guidance;  

-  when  we  identify  that  an  e-scooter  advertisement  may  suggest  the  product’s  use  on  public  roads  or 
streets,  we  send  our  UK  selling  partners  detailed  communications  telling  them  to  remove  such 
references, including removing pictures encouraging potentially illegal use by customers; and  

-  we  publish  education  reminding  all  selling  partners  to  check  if  there  are  local  legal  restrictions  in 

relation to the use of e-mobility devices on public roads or spaces.  

We trust this is helpful and again express our sincere condolences to Ms. Abukar’s family for their tragic loss. 
Please do let me know if you require any further information. 

Yours sincerely, 

UK Legal Director & AGC, 
Amazon 

AMAZON UK SERVICES LTD. 

REGISTERED OFFICE: 1 PRINCIPAL PLACE, WORSHIP STREET, LONDON EC2A 2FA, UNITED KINGDOM 

Registered in England and Wales • Company Registration No. 03223028 • VAT No. GB 680 737 022

From the Secretary of State 
The Rt Hon Mark Harper MP 

Great Minster House 
33 Horseferry Road 
London 
SW1P 4DR 

Web site: www.gov.uk/dft 

10 February 2023 

Mr G Irvine 
Walthamstow Coroner’s Court 
Queens Road Walthamstow 
E17 8QP 

Dear Mr Irvine, 

I was sorry to hear of Fatima Abukar’s tragic death and would like to thank 
you for your investigation and the issues you have highlighted.  

I am writing to address your concerns about the marketing practices of e-
scooter retailers and riders of hired scooters not being required to wear 
helmets. My Rt Hon colleague, the Secretary of State for the Home 
Department will write to you with regards to your concerns about the 
enforcement and seizure of privately owned e-scooters being used illegally on 
public land. 

As your report highlights, e-scooters outside of the rental trials can only be 
used on private land with the landowner’s permission and they remain illegal 
to use on public land. Your report highlights the issue of some manufacturers 
and retailers of e-scooters in England and Wales do not always provide 
prominent warnings that these private e-scooters are illegal to use on public 
land. This is an issue the Department is aware of and as a result, last 
summer the Driver and Vehicle Standards Agency (DVSA) began market 
surveillance work. To date, approximately 60 retailers have been found to be 
selling without the full and proper warnings. The DVSA has followed this up 
with warning letters to remind retailers of their obligations and we have 
already seen some changes in industry behaviour, with misleading imaging 
removed and the correct statement of the current law. Under s65 of the Road 
Traffic Act 1988, the DVSA can take further action against retailers that 
remain non-compliant which may lead to prosecution of individuals and 
businesses. Ministerial colleagues at the Department for Transport, most 
recently the Minister of State for Decarbonisation and Technology in 
December 2022, have also written to micromobility retailers reminding them 
of the law. These letters drew specific attention to the advertising concerns in 
each case.  

 
 The e-scooter trials were launched in July 2020 and are currently live in 25 
areas across England. These trials are designed to assess the safety of e-
scooters, their potential benefits and their impact on public space to help us 
consider options for future regulation of e-scooters. Cycle helmets are 
recommended for the trials but are not a requirement, as is the case for 
bicycles and electrically-assisted pedal cycles. In February 2022 we issued 
updated guidance to all local authorities and e-scooter operators that further 
encouraged them to provide helmets and incentivise their use. Whilst this 
tragic incident did not happen within the trials, I recognise this is an important 
consideration as the Government plans to bring forward legislation that will 
allow e-scooters to be regulated. As part of this, we will consult on a range of 
topics, including helmet wearing. 

Yours sincerely, 

The Rt Hon Mark Harper MP 

SECRETARY OF STATE FOR TRANSPORT

ACCESSIBLE STREETS 
EVOLVE SKATEBOARDS RESPONSE TO 
CORONER’S REPORT REGULATION 28 

 The aim of our response is to provide an outline of the actions currently 
taken as a company to minimise and alleviate incidents and accidents 
involving use of our product. In addition, we have taken this opportunity 
to put forward constructive guidelines for the Coroner’s review and 
consideration, that are in line with contemporary personal mobility 
device (PMD) guidelines globally, that address the safe use of Electric 
Skateboards within public spaces (roads and shared footpaths), and are 
enforceable, while still allowing the user to enjoy the product and be 
active within the community. 

SAFE USE OF EVOLVE SKATEBOARDS 

Evolve Skateboards actively encourages and reinforces the safe and 
responsible use of our product through pre and post-sale activity. As a 
top-line summary, this includes, though is not limited to;

   The reinforcement of safe use guidelines and principles as part of 
customer service practice and after sales documentation eg user manual.

   Reference to requirements to wear a helmet when using our product as 
part of FAQ’s on our website.

   Reference to the responsibility of customer’s to ensure compliance with 
the safety and legal requirements in their jurisdiction as part of our store 
policy provided on our website.

   Founding member of a PMD safety group advising the Land Transport 
Safety and Regulation Bureau, within the Department of Transport and 
Main Roads in Queensland, Australia, culminating in the legislation for 
use of PMD’s in the state. 

In addition, Evolve Skateboards is in the process of conducting a review of 
its current practice, globally, with regard to safety and legal compliance. 
This includes the engagement of legal and industry professionals to 
provide contemporary advice to ensure adherence to standards in each 
market we operate in. We expect this to be completed and rolled out, 
globally, including in the UK, by June 30, 2023. 

 
 GUIDELINES FOR THE SAFE USE OF PMD’S 

DEVICE POWER OUTPUT 

The most effective solution for the frontline police officer to police electric 
skateboards/scooters is by way of restricted ‘Speed Limits’ for the person 
controlling the device and a ‘Size and weight’ category of the device, not 
by the ‘Power Output’ of the device. As battery and motor technology are 
changing rapidly within the PMD marketplace, they are becoming smaller, 
lighter, more discrete and more powerful year by year. Trying to police 
these rapid increases in technology will be almost impossible for law 
enforcement, especially for the police officers on the front line who are 
not trained engineers (nor should they be). 

SPEED LIMITS 

Just like motor vehicles used on our roads have 
restricted speed limits for all types of cars from the 
average family car to the super car enthusiast, 
electric skateboards/scooters should have a safe 
Speed Limit restriction that allows for safe use 
within our public spaces, yet still allows the user to 
enjoy the product. In this respect, we suggest the 
following be implemented in the UK, which has 
been adopted in the state of Queensland, Australia: 

1- A maximum speed limit of 25kph (15mph) for the person using the 
device. This speed limit is restricted to roads of 50kph (31mph) or less and 
must be ridden on the sides of roads or in cycle paths if applicable.  

2- A maximum speed limit of 15kph (9mph) on share footpaths, however 
10kph (jogging pace) in environments where there are high density 
people on the footpath or road.  This is common sense riding and would 
be applicable to busy inner city spaces. 

3- Police are able to issue ‘speeding tickets/fines’ if the user goes over set 
speed limit. 

 
 SIZE AND WEIGHT OF DEVICE 

Electric skateboards are very small in size and weight with most electric 
skateboards weighing in at less than 8kg.  As electric skateboards sit very 
low to the ground and have a maximum height of 17.5cm (most are 10cm 
in height), this makes the device very safe for all pedestrians if ever there 
was a collision compared to a normal bike, scooter or E-bike, as the device 
only reaches ankle height. However, we would suggest the following size 
and weight restrictions for electric skateboards be used on shared roads 
and footpaths; 

1- Weigh less than 25kg. 

2- Have a width less than 60cm. 

3- Have a length less than 1.5m. 

 SHARED FOOTPATHS, ROADS AND CYCLE WAYS 

The safe use of electric skateboards/scooters within the public space is 
very important, to which, we suggest the following principles be applied: 

1- Can only be used roads that have a maximum speed limit of 50kph 
(31mph) or less and to be used on the sides of the roads or cycle lanes. 

2- Can be use on shared footpaths with a speed limit of 10kph (6mph) on 
inner city footpaths, all other footpaths 15kph (9mph). 

3- The electric skateboard/scooter must be under 25kgs in weight and 
less than 1.5M in length and less than 60cm in width. 

4- Common sense and courtesy must be applied when there are 
pedestrians on the path at the same time and pedestrians always have 
right of way. 

RIDING AT NIGHT 

Riding at night will always pose a risk, especially if riding on dark roads. 
In this respect, we suggest the following: 

The electric skateboards must have front and rear safety lights installed 
and turned on if being ridden at night. 

HELMETS 

Helmets save lives, with that said we suggest that it is compulsory to wear 
a Helmet when riding an electric skateboard/scooter and the helmet must 
be rated to AS/NZS 2063:2008 

 CONCLUSION 

The above suggestions are for the Coroner’s review and consideration with 
regard to using Electric Skateboards/Scooters within shared roads and 
footpaths, and forms the complete response of Evolve Skateboards UK, to 
the Coroner’s Report Regulation 28. 

We believe it is very important to have a set of guidelines that are 
enforceable and not going to go out of date within a couple of years.  
Common sense always must remain the responsibility of the user, just the 
same way people use cars with speed limit restrictions.  If the measures are 
not followed, then law enforcement has the right to issue fines accordingly. 
Personal mobility devices will become more and more popular in the future 
due to climate change and our communities’ expectations of Government 
to provide legislative frameworks for electric vehicle and device use. As 
governments focus more on smartening up their cities, they are looking for 
viable transportation solutions that can decrease traffic congestion while 
also creating a cleaner environment for the entire community. Personal 
mobility devices are part of this solution therefore, creating a safe 
environment to use personal mobility devices in a shared space is 
increasingly important. 

eMOBILITY CHANGES IN THE UK WITH ELECTROHEADS 

https://www.youtube.com/watch?v=fF2yFeXX-Eo 

PMD QUEENSLAND (AUSTRALIA) ROAD RULES 

https://www.qld.gov.au/transport/news/features/new-rules-for-personal-mobility-devices 

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Halfords Group 
plc 

Icknield Street 
Drive 
Washford West 
Redditch 
Worcestershire 
B98 0DE 

Telephone: 
01527 517601 

Web: 
Halfords.com 

Facsimile: 
01527 513201 

Mr Graeme Irvine  
His Majesty’s Senior Coroner  
Walthamstow Coroner’s Court  
Queen’s Road  
Walthamstow  
E17 8QP  

      26th January 2023  

Dear Mr Irvine,  

Report Pursuant to Regulation 28 of The Coroners (Investigations) Regulations 2013  

Further to the Report you issued in your capacity as the Coroner who presided over the inquest into the 
tragic death of Fatima Abukar and which you sent to Halfords and other major retailers of e-scooters on 
15 December, we make the following comments in reply. 

You  asked  for  information  on  the  actions  that  have  either  been  taken,  or  are  proposed  to  be  taken, 
regarding the warnings about the illegal use of e-scooters.  

As you may be aware, Halfords Group Plc, is the UK’s largest retailer of motoring and cycling products 
and services and we agree that such warnings are vital for the safety of riders.  

We can confirm that we advise potential buyers about the current legal position in regard to the use of 
e-scooters  (which  is  that  e-scooters  can  only  be  used  on  private  land  and  even  then,  only  with  the 
owner’s consent). We provide this advice at every stage of the sales process, both in store and online.  

The steps we take also include:  

•  Prominent signage next to e-scooters in stores, clearly explaining the law, including that they are 

not to be used on public roads; 

•  A clear legal statement on all e-scooter price tickets;  

•  A clear legal statement on all e-scooter warranties;  

Registered Office: 
Icknield Street Drive 
Washford West 
Redditch 
B98 0DE 
Registered in England & Wales No. 04457314 

 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 • 

• 

the training we provide to our sales colleagues to outline explicitly the legal position when the 
customer considers buying an e-scooter (this includes drawing attention to the signage, as well 
as advising them that,  if they  fail to adhere to these  rules,  they would face  a criminal offence 
and possible prosecution); 

that  our  colleagues  are  tutored  in  this  process  and  made  aware  of  this  as  it  is  the  very  first 
agenda point when they undertake the e-learning e-scooter module of their training; 

•  having till rolls and cash registers which also have pop-up warnings to remind our colleagues to 

again inform customers of the law at the point of sale; 

• 

• 

that  the  headers on  all e-scooter  product  detail  pages  state  that  it  is  illegal  to use  them on  a 
public road, pavement or cycle lane; and, 

that wherever an e-scooter is referenced in a blog we add our standard wording about the how 
e-scooter may be used legally.  

We  started  selling  e-scooters  in  April  2019,  and  have  always  recognised  the  need  for  clear  advice 
regarding  the  law  which  applies  to  the  use  of  e-scooters.  For  example,  after  Government  Ministers 
brought  forward  the  introduction  of  trial  hire  schemes  in  2020,  which  led  to  increased  interest  in  e-
scooters, we made sure that the detailed guidance we provided (i.e. as set out above) was updated.   

As a result, Halfords has previously been recognised as a responsible retailer of e-scooters by the then 
Secretary of State for Business1 and a Police and Crime Commissioner2. The steps we take are intended 
to ensure that throughout their purchasing journey every customer is fully aware of the law that applies 
in this area, and we consider that this shows how seriously we take our responsibilities in this regard. 
We  work  hard  to  maintain  our  reputation  as  a  responsible  retailer  of  these  products.  This  is  why  we 
constantly review the way we inform customers about the law; why we have updated, and will continue 
to update, our signage and why we adapt our processes extremely quickly if we identify improvements 
that  can  be  made.  We  have,  for  example,  just  recently  sent  a  communication  to  our  digital  teams  to 
make sure they maintain the prominence of messages about the current law, in our on-line and social 
media platforms, and we have asked them to see if they can find ways of to make this even clearer.  

We  have  also  advised  the  Government  that  if there  is  to  be  a  Transport  Bill  which  might  address  the 
wider legalisation e-scooters, any change in the law should be introduced in a measured and controlled 
manner.  For  instance,  we  have  advocated  for  a  maximum  speed  limit  of  15.5mph,  as  this  would 
harmonise  e-scooters  with  e-bikes  and  thus  avoid  a  higher  speed  differential  that  could  prove 
dangerous. Another example is in regard to lights and reflectors. We believe that any rules introduced 
should  be  consistent  with  those  required  of  cyclists,  and  we  note  that  the  Highway  Code  for  cyclists 
says: ‘At night your cycle must have white front and red rear lights lit. It must also be fitted with a red 
rear reflector.’  

1 Q239 https://committees.parliament.uk/oralevidence/10158/pdf/  
2 See blue highlighted comment by Kent PCC Matthew Scott https://www.thesun.co.uk/news/15683358/gunmen-
e-scooters-ride-by-shootings/  

 
 
 
 
 
 
 
 
 
 
 Finally, we note that the Chief Coroner might wish to publish this response in a completed, redacted or 
summarised form and that you and/or the Chief Coroner might also wish to send this response to any 
person to whom it might be useful or of interest. We think it could be beneficial for this response to be 
circulated, especially if doing so progresses and informs the debate in this area, and so we do not object 
to that occurring in these circumstances.  

I fully understand the seriousness of this tragic case and the concerns raised and so I hope this response 
meets your requirements. If you need further information, please do not hesitate to contact me.  

Yours sincerely,  

Chief Executive Officer  
Halfords Group PLC

Mr Graeme Irvine, Senior Coroner 
Walthamstow Coroner's Court 
Queens Road 
Walthamstow 
E17 SQP 

6th February 2023 

Dear Mr Irvine, 

RE: REGULATION 28 REPORT TO PREVENT FUTURE DEATHS - Inquest 
into the death of Fatima Abukar 

We write further to your Regulation 28 report dated 14th December 2022. 

Firstly, please may we extend our sincerest condolences to the family and loved 
ones of Fatima Abukar, and all others who have tragically lost their lives whilst 
using an E-Scooter. 

We are saddened to learn the truly concerning statistics advised under section 5 
of your report and remain committed to doing what we can as a business to 
ensure the safety and wellbeing of all of our customers.  

At the time of writing, customers are advised at the point of sale that E-Scooters 
purchased from Harrods are not suitable for road use and text is added to their 
sales receipts to reflect this. Furthermore, we routinely recommend to customers 
that they purchase helmets for use with their E-Scooters. Helmets are available 
for sale in the Technology department and are displayed alongside the E-
Scooters. We are also implementing age verification checks at the point of sale to 
ensure that E-Scooters are not sold to persons under the age of 18. 

Further to the above, we are now taking steps to prepare notices to be displayed 
in the Technology department and on our online retail website, harrods.com. 
Such notices will make clear that it is illegal to use an E-Scooter on a public road 
and in spaces that are set aside for use by pedestrians, cyclists and horse-riders 

 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 (including the pavement and cycle lanes). We enclose a copy of the notice in the 
Schedule to this letter. 

The notices will be prominently displayed (i) in the area(s) containing E-Scooters 
within the Technology department in Harrods’ Knightsbridge store, and (ii) on 
product pages for E-Scooters on harrods.com. Furthermore, customers 
purchasing an E-Scooter in store will be directed to read the content of the notice 
before completing any purchase. We anticipate these notices will be on display 
and clearly visible for customers by 10th February 2023. 

We trust that the above clearly sets out the actions that we have taken and will be 
taking in the near future (along with our anticipated timeline for implementing the 
same). However,  please do not hesitate to contact us if we can assist any 
further.   

Yours sincerely, 

Harrods Limited 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 SCHEDULE - E-Scooter Notice 

NOTICE/DISCLAIMER 

Electric ‘E’ Scooters are powered transporters. Given how powered transporters 
are motorised and designed, they fall within the legal definition of a “motor 
vehicle” under UK legislation. Therefore, the laws that apply to motor vehicles 
apply to powered transporters. 

In the UK, other than specific, approved Electric ‘E’ Scooter rental schemes, it is 
currently illegal to use a powered transporter: 

•  on a public road without complying with the legal requirements for the use of 

• 

motor vehicles on public roads; and 
in spaces that are set aside for use by pedestrians, cyclists, and horse-riders - 
this includes on the pavement and in cycle lanes. 

Any person who uses a powered transporter on a public road or other prohibited 
space in breach of applicable laws is committing a criminal offence and can be 
prosecuted. Save where the legal requirements for the use of motor vehicles on 
public roads are complied with, it is otherwise currently only legal to use a 
powered transporter on private land with the permission of the landowner. It is the 
Customer’s complete responsibility to ensure that their Electric ‘E’ Scooter is used 
in accordance with all domestic legislation applicable in the country of use. 

Using an Electric ‘E’ Scooter can be a challenging activity and carries with it risks, 
including the risk of personal injury. Customers must act reasonably and sensibly 
at all times and follow all safety warnings and instructions. It is strongly advised 
and recommended that all Customers wear protective equipment (including a 
helmet) when using an Electric ‘E’ Scooter. Use of Electric ‘E’ Scooters remains 
at all times at the Customer’s own risk. When purchasing through Harrods 
Limited, the Customer fully accepts and assumes all risk and liability associated 
with the use of an Electric ‘E’ Scooter. 

The Customer further accepts full responsibility and waives all and any rights it 
may have against Harrods Limited in relation to any liability arising out of or in 
connection with, directly or indirectly, their use of an Electric ‘E’ Scooter (save in 
the event of negligence of the company or a defective product). 

For further guidance in relation to the use of powered transporters, please see: 
https://www.gov.uk/government/publications/powered-transporters/information-
sheet-guidance-on-powered-transporters

PROFESSIONALISM HQ 

Mr G Irvine 
HM Senior Coroner 
East London 
Walthamstow Coroner’s Court 
Queens Road                                                             
Walthamstow   
London   
E17 8QP 

Deputy Assistant Commissioner 
New Scotland Yard 
Victoria Embankment 
London    
SW1A 2JL 

Date: 03.02.2023 

I  am  the  Deputy  Assistant  Commissioner  for  the  Directorate  of  Professionalism  in  the 
Metropolitan  Police  Service  (MPS).  I  write  to  provide  the  response  on  behalf  of  the 
Commissioner of Police of the Metropolis to the matters of concern addressed to the MPS in 
the Report to Prevent Future Deaths dated 14th December 2022. 

On behalf of the MPS may I first of all express my sincere condolences to Ms Abukar’s family.  
Our thoughts and sympathies are very much with them. 

Matter of Concern 1 

Evidence in this inquest confirmed that since 2019 here have been 8 recorded fatalities 
involving e-scooters in London and 31 in the country at large. At the time of her death 
Ms  Abukar  was  riding  a  privately  owned  e-scooter  on  a  public  highway.  Despite  the 
ubiquity of such devices on London's streets, riding them on public roads is unlawful. 

Whereas approximately 4000 unlawfully used scooters were seized by the Metropolitan 
Police Service in 2021, only 1100 were confiscated in 2022. The reduction is attributable 
to a change in policy introduced in November 2021. 

MPS Response 

The MPS is aware of the use of illegal e-scooters on London’s roads and we continue to take 
a proportionate policing response to their use.  In 2021, the MPS published information on the 
MPS  public  website 
(https://www.met.police.uk/advice/advice-and-information/rs/road-
safety/advice-escooters/) titled ‘Advice on using e-scooters’.  This article clearly states that ‘it 
is  not  currently  possible  to  get  insurance  for  privately  owned  e-scooters,  which  means  it's 
illegal to use them on the road or in public spaces. If you're using a private e-scooter you risk 
the vehicle being seized under S.165 Road Traffic Act 1988 for no insurance’.  This messaging 
was  also  re-enforced  on  numerous  occasions  by  the  MPS  Roads  and  Transport  Policing 
Command (RTPC) in their communication with members of the public via their MPS Twitter 
account. In addition, other Basic Command Units have used social media to communicate the 
law and to demonstrate how they have seized a number of e-scooters. 

 
 
 
  
 
 
                        
                                                     
 
 
 
 
 
 
 
 
 
 
 
             
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                          
 
 
  
   
                                                                                      
 
 
 
 
 
 
 
 
 
 
 The  MPS  updated  their  policy  titled  “Seizure  of  vehicles  for  No  Licence  and  Insurance 
Standard  Operating  Procedure”  which  covers  the  seizure  and  enforcement  of  offences 
connected with the use of illegal e-scooters, in September 2021. There was no specific update 
to the policy concerning the seizure of E-scooters at this time.  An element of discretion has 
applied in relation to the seizure of e-scooters and other non-standard mechanically propelled 
vehicles for a number of years prior to this by way of the following paragraph:     

“Discretion is required when policing personal transporters, particularly when dealing 
with  juveniles.  It  should  take  an  educational,  advisory,  and  non-confrontational 
approach when  enforcing  this  legislation.  Guidance  should  be  given  to users  about 
where they can and cannot use these devices and to ride responsibly.” 

In 2021, the MPS had an existing policy for dealing with illegal e-scooter use, called Operation 
Hornet.  This policy, issued on the MPS internal website some years earlier, already directed 
a proportionate response to dealing with the illegal use of these devices.  In November 2021, 
due to ever increasing seizures and reporting of offences relating to these devices in London, 
the MPS Roads and Transport Policing Command issued direction re-emphasising the need 
for a graduated and proportionate response balancing the need to protect the public whilst not 
unnecessarily criminalising the public in a complex area of roads policing legislation (private 
e-scooters were illegal at this time but council approved ones on a trial were routinely on the 
roads causing confusion  with the  public  at  large). This  direction,  in line with other  areas  of 
policing, confirmed that each offence should be dealt with on a case by case basis, and where 
appropriate officers should seek to engage, explain and encourage anyone using an E-scooter 
in  public  to  discontinue  riding  the  device  immediately  (the  engage,  explain  and  encourage 
approach was borrowed from  the  national  and  widely  publicised  policing stance on  COVID 
enforcement).  Where the person stopped was  however committing other offences or putting 
the public in danger, then this would then be robustly enforced, including seizure of the device, 
issuing a TOR (Traffic Offence Report) or arresting the rider.    

In June 2022, the policy was further amended to re-inforce this direction as follows: 

“6.5.  It  is  important  to  remind  users  that  it  is  unlawful  to  use  these  vehicles  on 
pavements and public roads. 

juveniles. 

6.6.  Discretion  is  required  when  policing  personal  transporters,  particularly  when 
dealing  with 
take  an  educational,  advisory,  and  non- 
confrontational  approach  when  enforcing  this  legislation.  Guidance  should  be 
given  to  users  about  where  they  can  and  cannot  use  these  devices  and  to  ride 
responsibly. 

It  should 

6.7 If this guidance is ignored, the vehicle is involved in criminality, behaviour that put 
the wider public at risk, or the user has committed any offences other than Sec 164/165 
Road  Traffic  Act,  officers  have  the  power  to  seize  devices  and  report  users  for 
prosecution in line with the ‘e-scooter flowchart’. If seized, they can be taken to a car 
pound using the station van. 

6.8. If the offender is a juvenile, consideration should be made about contacting the 
adult  responsible  for  the  juvenile  and  considering  any  offences  of  allowing  or 
permitting the use of the personal transporter. 

6.9 Prior to July 2022 the Met exercised its discretion and waived some of the release 
conditions for production of a valid certificate of insurance and/or a valid driving licence 
when reclaiming of non-standard mechanically propelled vehicle that had been seized 
under  Sec  165A  RTA  1988  at  the  Met  car  pounds.  This  was to afford the owner  or 
registered keeper the ability to reclaim the vehicle. However, as of July 2022 the Met 

 
 
 
 
 
 
 will no longer waive these conditions and instead will require compliance with the full 
release conditions as specified in Regulation 5 of the Road Traffic Act 1988 (Retention 
and Disposal of Seized Motor Vehicles) Regulations 2005, as they do with other motor 
vehicles seized under the same powers. These requirements include the production of 
a valid certificate of insurance, a valid driving licence, payment of the statutory fees 
and they must satisfy the authorised person that they are either the registered keeper 
or owner of the vehicle”. 

A copy of the e-scooter flow chart is appended to this response. 

An  inverse  correlation  exists  between  the  rate  of  legal  enforcement  and  the  rate  of 
deaths  caused  by  e-scooters.  The  number  of  deaths  in  Q1  &  2  of  2022  is  more  than 
double that of Q1 & 2 of  2021. 

It is not accepted by the MPS that there is a correlation between the legal enforcement of e-
scooters  and  the  number  of  deaths.   It  is  not  understood  that  any  such  evidence  was 
presented to the Coroner during the inquest. 

Matter of Concern 2 

Ms Abukar died due to traumatic head injuries.  Riders of legally authorised scooters 
(those hired from licenced operators) are not required to wear head protection. 

The regulations, and parameters, regarding the use of licenced scooters in e-scooter trials, 
and the use of head protection, was a policy decision made by the Department for Transport, 
and Transport for London, for their use in London. They are best placed to comments on the 
rationale for this decision. 

The MPS support the use of protective headwear and have suggested this on many occasions 
to the DfT and TfL, as confirmed by the evidence of Chief Superintendent Ovens during the 
inquest.  

Matter of Concern 3 

Some  manufacturers  and  retailers  of  e-scooters  in  England  and  Wales  provide 
consumers  with  written  warnings  about  the  illegal  use  of  e-scooters,  others  do  not.  
Where such warnings are present, often they are not prominent. 

For the last three years on the approach to Christmas, the MPS has written a joint letter with 
Will Norman (TfL Walking and Cycling Commissioner) to e-scooter retailers asking them to 
ensure  prominent  signs  are  displayed  at  the  point  of  sale  to  remind  customers  about  the 
legality of e-scooters.  

I trust this clarifies the position the MPS took in relation to the reduction in the seizure of e-
scooters in 2022, however, please do not hesitate to contact me should you have any 
queries. 

Yours sincerely 

Deputy Assistant Commissioner

Subject: 
Date: 

Re: In the matter of Fatima Abukar (
09 February 2023 14:35:35 

 Regulation 28 (Preventing Future Deaths) report 

Dear Graeme Irvine, Senior Coroner,for the coroner area of East London 

Onboards is deeply sorry to hear what has happened to Ms Abukar in this 
unfortunately incident 

onBoards, as a company, proactively promote safety among our customers, 
electric bicycles and scooters users 

Below please find a list of measurements we have in place in order to inform 
clients and users about how to maximise safety while riding these products 

1. We have helmets displayed among our bikes and scooters in order to 
bring awareness of the use of such products 

2. We offer discount in helmets when they are bought together with bikes 
and scooters 

3. When liaising with clients in our shop we encourage the use of helmets 
and high vests clothing and try to bring awareness of the importance of 
using such safety devices 

4. All our lifestyle pictures in our website and social media have riders 
always appear wearing helmets 

5. We do not sell electric scooters to persons under 18 years old 

6. In the scooters section of our shop we have displayed a sign that explicitly 
mentions the illegality of using electric scooter that are not from rental 
companies in public roads 

7. All invoices specifically mentions the illegality of using private electric 
scooters in public roads, footpaths and cycle lanes 

8. The footer of all our web pages includes the same disclaimer 

Although no effort is enough to assure safety among rides, we are 
committed to always do as much as possible in order to bring awareness, 
inform and promote safety 

Should you consider that other measures should be in place please let us 
know as we are always willing to collaborate and improve safety 

Regards 

Director of OnBoards

Mr G Irvine, Senior Coroner, East London 

13 January 2023 

Dear Sir 

Re: Regulation 28 Report to Prevent Future Deaths  

I write in response to your letter addressed to Selfridges Group Managing Director, 

(since  departed  from  Selfridges  Group),  received  on  15  December  2022.  This 
letter,  setting  out  a  Regulation  28  (Preventing  Future  Deaths)  report,  requests  our 
response as a retailer which sells e-scooters. I write to you as General Counsel and a 
director  of  Selfridges  Retail  Limited,  which  trades  as  Selfridges  (and  which  is  part  of 
Selfridges Group). 

I  confirm  that  Selfridges  and  its  directors  fully  appreciate  the  gravity  of  the  matter 
addressed in the report and we recognise that receiving this report provides us with an 
opportunity to consider what role we, as retailers, can play in guarding against future 
unavoidable deaths in similar circumstances. An avoidable death is always a tragedy 
and all the more so where this involves the death of a child.  

Selfridges is a responsible retailer and, in particular, we recognise our responsibility to 
ensure  that  when  we  sell  e-scooters  we  should  make  it  clear  to  customers  that  an  e-
scooter may not be lawfully ridden on the public highway.  

Selfridges first received a communication on this topic in November 2020, in a joint letter 
from  the  Mayor  of  London  and  the  Metropolitan  Police  requesting  retailers  provide 
accurate  information  to  make  customers  aware  that  private  e-scooters  are  illegal  on 
public  roads,  pavements  and  other  public  places.  In  response,  Selfridges  reviewed 
where these products were sold, whether offered directly by Selfridges or via concession 
partners,  and  addressed  this  issue  to  ensure  there  was  a  clearly  visible  message  to 
customers (in stores and on the website). 

Since 2020, and particularly in the run up to the peak trading period around Christmas, 
Selfridges  Legal  team  has  reviewed  and  reminded  stores  and  digital  trading  teams 
about this matter and the need for suitable communications to customers. 

In November 2022, Selfridges received a similar letter from the Mayor of London and the 
Metropolitan  Police,  reminding  retailers  of  the  legal  position  concerning  e-scooters, 
whilst the Government continued to consider whether to alter their legal status. Once 
again, Selfridges Legal team issued reminders and a guidance note to stores and digital 
teams to ensure that where e-scooters are sold there are suitable communications to 
customers, confirming they remain illegal to be ridden on public roads and other public 
places.  

 
     
                                        
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 In  addition,  Selfridges  Technology  team  was  asked  to  support  with  exploring  what 
systems-based solutions might be added in future, such as a flag against a product like 
this  to  remind  all  teams  dealing  with  the  product  that  customer  safety  advisory 
requirements or other restrictions exist and should be checked and/or observed.  

In early December 2022, Selfridges received a further similar letter from the Government’s 
Department for Transport addressed to Selfridges Managing Director. The above actions 
were already underway. 

Following receipt of this Regulation 28 (Preventing Future Deaths) report served by His 
Majesty’s Coroner Mr Irvine on Selfridges, the above actions have been reviewed and 
the matter has been raised, discussed and noted at a meeting of Selfridges Executive 
Committee (meeting held in January 2023).  

We hope that these steps taken by Selfridges, which are ongoing in nature, demonstrate 
the  seriousness  with  which  Selfridges  and  its  directors  take  their  commitments  as  a 
responsible retailer in relation to this matter.  

Selfridges  looks  forward  to  any  forthcoming  legislation  or  guidance  addressing  e-
scooters and their use.  

Yours sincerely,  

General Counsel  

Selfridges Retail Limited 

Copy also to:  
1.  Sir Mark Rowley – The Commissioner for Metropolitan Police Service 

2.  Andrew Lord – The Commissioner for Transport for London  

3.  Mr Sadiq Khan – the Mayor of London  

4.  The Rt Hon Mark Harper MP – the Secretary of State for Transport  

5.  The Rt Hon Suella Braverman KC MP – the Secretary of Statement for the Home Department

Mr G Irvine 
Senior Coroner, East London 
Walthamstow Coroner’s Court 
Queens Road 
Walthamstow  
E17 8QP 

8 February 2023  

Dear Mr Irvine  

Chief Customer and 
Strategy Officer  

Transport for London 
11th Floor, Zone R4 
Palestra 
197 Blackfriars Road 
London SE1 8NJ 

Regulation 28 report: Report to prevent future deaths – Fatima Abukar 

I write on behalf of Transport for London (‘TfL’) and the Mayor of London with regard to the 
Senior Coroner’s Prevention of Future Deaths (‘PFD’) report dated 14 December 2022 
following the inquest arising from the death of Fatima Abukar. 
I am personally very sorry to hear of the tragic death of Fatima Abukar and wish to express my 
sincere condolences and those of TfL to the family and friends of Fatima.   
TfL and the Mayor of London were not interested persons at the inquest and have not 
previously been contacted in relation to this tragic incident. 

The Regulation 28 report refers to three areas of concern being: 

1.  “Evidence in this inquest confirmed that since 2019, there have been 8 recorded 

fatalities involving e-scooters in London and 31 in the country at large.  At the time of 
her death Ms Abukar was riding a privately owned e-scooter on a public highway.  
Despite the ubiquity of such devices on London’s streets, riding them on public roads is 
unlawful. 

Whereas approximately 4000 unlawfully used scooters were seized by the Metropolitan 
Police Service in 2021, only 1100 were confiscated in 2022.  The reduction is 
attributable to a change in policy introduced in November 2021.   
An inverse correlation exists between the rate of legal enforcement and the rate of 
deaths caused by e-scooters.  The number of deaths in Q1 &2 of 2022 is more than 
double that of Q1 & 2 of 2021. 

2.  Ms Abukar died due to traumatic head injuries. Riders of legally authorised scooters 
(those hired from licenced operators) are not required to wear head protection. 

3.  Some manufacturers and retailers of e-scooters in England and Wales provide 

consumers with written warnings about the illegal use of e-scooters, others do not.  
Where such warnings are present, often they are not prominent.” 

This is the response from both TfL and the Mayor of London.  In London, as with other parts of 
the UK, it is illegal to use privately-owned e-scooters on public roads. 

TfL and the Mayor want to explore new, environmentally friendly forms of transport that can be 
used to reduce road congestion in London.  However, it is recognised that any alternatives 
must be safe for both users and non-users alike. 

TfL RESTRICTED 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 Since June 2021, TfL has been running a rental e-scooter trial which has been approved by 
the Department for Transport (‘DfT’) and is part of a national programme of trials intended to 
inform any legislative approach to altering the legal status of these vehicles which the 
Government may choose to pursue. Anonymised data from the rental scheme is being used to 
assess how e-scooters could make a positive contribution to transport in London. 

Rental e-scooters are the only way to legally ride an e-scooter on public roads or in other 
public places within London, and this is limited to specific boroughs.  Since the trial launched, 
it has expanded to cover ten boroughs, there are more than 500 designated parking locations 
and the total fleet is now over 4,500 e-scooters.  

The DfT has provided updated guidance which allows existing trials in the UK to be extended 
to 31 May 2024, enabling local authorities to continue to test the vehicles in a safe and legal 
way.  The e-scooter rental trial is part of a wider effort by TfL, London Councils, London 
boroughs and the Government to enable people to use new and greener forms of transport. 

TfL is working closely with the relevant London borough councils and has made Traffic 
Regulation Orders to allow the use of e-scooters on TfL cycle tracks within the participating 
boroughs.  It is illegal to ride any e-scooter on the pavement however, and to do so carries the 
risk of fines and prosecution.  This could include a £300 fixed penalty notice, six penalty points 
on a rider’s driving licence for riding with no insurance, and seizure of the e-scooter.  

The current phase of the trial is expected to run until Autumn 2023.  Through the competitive 
procurement process for the new phase of London's rental e-scooter trial which is currently 
under way, operators for the second phase (to 31 May 2024) will be selected on their ability to 
meet strict safety requirements and high operating standards.  For example, rental e-scooters 
must have specific safety features installed including speeds limited to 12.5mph and lights that 
are always on throughout any rental (see further safety features below).  

Safety is TfL’s priority. The trial will help TfL to better understand how e-scooters can be used 
safely in London and how we should develop policy.  London’s learnings and data from the 
trial will help to shape national legislation in the future. TfL is taking a number of steps to 
ensure that anyone using a rental e-scooter rides safely and follows the rules of the road as 
well as guidance from the rental operator.  DfT’s national standards include requirements for 
all vehicles to be identifiable by their unique number plates vehicles, to have kick-stands, as 
well as strict parking requirements to prevent them from being trip hazards when not in use.  
TfL’s safety standards go beyond the DfT’s national standards and include: 

•  Riders must be 18 or over and hold at least a provisional driving licence 
•  The speed limit of trial e-scooters is capped at 12.5mph (as opposed to the national 
maximum of 15.5mph, which is often the speed that e-scooters available for private 
purchase can reach). They will automatically reduce speed to 8mph in 'go slow' areas. 
The trial e-scooters also come to a safe stop in 'no-go' zones to ensure they can be 
ridden safely 

•  All first-time riders must do mandatory training on how to ride safely in London 
•  The trial e-scooters are maintained to a high level and have large wheels to help 

navigate road surfaces more easily 

•  Lights at the front and rear of the vehicles are always on throughout any rental 
• 

In the procurement for the second phase of the trial, a minimum wheel size has been 
added to the vehicle specification. 

TfL and operators also provide safety guidance and tips on how to ride rental e-scooters safely 
and avoid serious injury to any road users. This includes encouraging all riders to use 
protective equipment while using e-scooters including wearing a helmet. The wearing of 
helmets is not required by DfT for the trials, however. 

TfL RESTRICTED 

 
 
 
 
 
 
 
 
 
 Reports of poor rider behaviour are taken seriously and the operators have warned or banned 
more than 200 people to date. 

In addition, in the lead up to Christmas, with the expected increase in the sale of private e-
, London’s Walking and Cycling Commissioner, and Metropolitan 
scooters, 
Police Service (‘MPS’) Commander, 
their duty to make customers aware of the law regarding the use of private e-scooters. TfL and 
the MPS have also jointly run a communications campaign to raise public awareness that 
private e-scooters are illegal.  

, jointly wrote to retailers to remind them of 

In 2022, the Government announced plans to create a new vehicle category in legislation, in 
which e-scooters would be included. TfL would welcome such legislation which has the 
potential to make important improvements to the safety of private e-scooters, which are not 
presently constructed to any regulatory standards. We hope the legislation enabling this will be 
introduced without further delay. 

TfL continues to work with the MPS, and City of London Police (‘CoLP’) to engage with users 
of privately-owned e-scooters and, where necessary, the MPS and CoLP will use their 
enforcement powers to help keep Londoners safe. 

We will continue to monitor the data from the rental e-scooter trial and support the introduction 
of legislation to ensure the safety of private e-scooters. 

Yours sincerely 

Chief Customer and Strategy Officer 

TfL RESTRICTED

From: Stephanie Clifton
To: coronerseastlondon@ukemail.icasework.com
Subject: FW: In the matter of Fatima Abukar (ref: 17666488) Regulation 28 (Preventing Future Deaths) report
From: EScooterClinic <contact@escooterclinic.co.uk>
Sent: 18 December 2022 16:52
To: Stephanie Clifton <Stephanie.Clifton@walthamforest.gov.uk>
Subject: Re: In the matter of Fatima Abukar (ref: 17666488) Regulation 28 (Preventing Future
Deaths) report
Dear Stephanie,
Thank you for reaching out. I am sad to learn about that event that I was unaware of before you
reached out to us.
The user of the vehicle was underage, recklessly driving, on the wrong side of the road, without
protection. The fact that she was using a scooter is completely irrelevant, she could have been
using a bicycle as well, or just running on her own legs.
We would advise that the government takes the important decision of legalising the scooters, to
introduce proper laws and regulations.
Protective gear should be compulsory as well as third-party insurance.
The government has been delaying the legislation at the same time allowing rented scooters on
the street. That causes a lot of confusion. The UK commuters have spoken and have expressed
interest in a new, eco-friendly, personal transport being properly introduced and legalised in the
country.
Sadly the incident is not at the fault of the vehicle but the user.
Kind regards,
Patryk Radek