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Although failure to comply with the other rules of the Code will not, in itself, cause a person to be prosecuted, The Highway Code may be used in evidence in any court proceedings under the Traffic Acts (see The road user and the law) to establish liability. This includes rules which use advisory wording such as ‘should/should not’ or ‘do/do not’.
"https://www.gov.uk/guidance/the-highway-code/introduction#wording-of-the-highway-code
I do wish they wouldnt call them rules when they're not. Just leads to this kind of rubbish. Some of the rules are rules and some of the rules are just advice.
The way it's framed makes it sound like the rule for the front brake is equivlent to the rules on clothing when they're not. Its all just a bit of a mess really.
Why hasnt he written to all organisations with people who might drive to/from or for work? It's all the biggest over reaction I think I've ever encountered for one single (tragic) death.