Indeed. Far too many gaps.

To try to help just with what we have, he has two choices other than simply pleading guilty: either defend the matter in its entirety or plead guilty but put forward an argument that there are "Special Reasons" why the court should not disqualify him.

Defending the matter will not be easy. The only grounds I can see is that the officer did not have "reasonable suspicion" to require a test. Quite honestly, being stationary at traffic lights for a prolonged period (presumably after they had turned green) in the small hours and then being found to have a bottle of booze (even unopened) will see any court find that a reasonable suspicion was justified. After that it's simply a matter of showing that the refusal took place.

The "Special Reasons" argument looks also likely to fail. There cannot be a realistic chance of success if the refusal was simply that - a refusal. If the argument that the driver was not in the right frame of mind to co-operate that argument could equally be used to show that he should not have been driving at all. The court will probably take the view that he made two wrong decisions - one to drive in the first place and another to refuse the test.

The police are usually fairly lenient when it comes to roadside breath tests. Their first instinct is not usually to simply shove the driver into the back of their car and whisk him off to the nick. Similarly I suspect there may be more to this than we are hearing. I think the best thing you can do is to advise your daughter's partner to see the duty solicitor at his first court appearance. He will be able to do so as the offence is imprisonable. He can get an opinion there after he has divulged all the facts and has seen the evidence against him. However, if he wants legal advice beyond that he will have to pay unless he qualifies for Legal Aid.