Police fear a "serious crime" could take place if a major motorcycling festival in Warwickshire is granted a licence, a panel has heard.
On August 12 last year, Hell's Angel member Gerry Tobin was shot dead on the M40 after leaving the long-running Bulldog Bash.
Now a licensing committee in Stratford-upon-Avon began a hearing to decide whether to grant an annual four-day licence for the event, held in Long Marston.
Police have submitted a formal objection to the granting of the licence, which would allow boxing, dancing, live music and the supply of alcohol, covering this year’s planned August festival and lasting until 2018.
The committee heard that in 2001 a Canadian Hell's Angel survived after being shot three times in the leg after leaving the event, while in 1998 the festival faced a bomb threat.
Glyn Samuel, representing the police, outlined their objections to the granting of the licence for reasons including "public safety". He said: "We have concerns that we cannot protect public safety and that there will be serious crime as a result of holding this event."
The panel heard that police believe there to be increasing tension between the Hell's Angels, who are associated with the Bulldog Bash, and rival motorcycle group the Outlaws.
Organisers of the Outlaws’ equivalent event, the Rock and Blues Custom Show in Derbyshire, cancelled this year’s festival after police voiced concerns.
Michael Bromley-Martin QC, representing the Bulldog Bash organisers, argued that the Bash has been as "peaceful and crime-free as you could expect for any festival of this kind".
He said: "This is an established event which has passed off without any undue difficulty for 21 years."
But William Holland, Assistant Chief Constable of Warwickshire Police, said he believed the risk of violence between the rival groups to be "extremely high".
He added that the Hell's Angels website was promoting the Bulldog Bash as a "memorial event" for Mr Tobin.
Several men are due to stand trial in October for the murder of Mr Tobin, the panel were told.
Inspector David Patterson of Warwickshire Police’s operations planning unit said that to police this year’s Bulldog Bash appropriately would cost £1,940,000.
In comparison, he said, policing Warwickshire’s agricultural Royal Show would cost £75,000.
He added that such a police presence at the Bulldog Bash could "give no guarantees at all" as to ensuring safety.
In a written statement submitted to the panel, he said: "The Hell's Angels, who are indivisible from the Bulldog Bash, are an organisation involved in serious criminality."
The Bulldog Bash rally has an audience capacity of about 20,000 people per day. The hearing continues today.
* A high octane motorcycle show which attracts thousands of people over the end of May Bank Holiday has been cancelled due to security fears.
The Welsh National Motorcycle Show is a highly popular annual event which was due to take place between May 23 and 26.
Thousands flock to the picturesque mid Wales venue at the Royal Welsh Showground in Llanelwedd, Builth Wells, every year.
But with little more than a week left until the show was due to open it has been cancelled, apparently after representations from the police.
News of the cancellation was released through the Royal Welsh Agricultural Society’s website. A brief statement said: "Following representations made and information supplied by Dyfed-Powys Police regarding public safety and security in relation to the Motorcycle Show to be held on 23rd to the 26th May, it is with regret we announce that the event has had to be cancelled."
Steve Bennett, an organiser of the event, was unavailable for comment but his voice mail does say: "The Welsh National Motorcycle Show of 2008 has been cancelled by the showground committee of the Royal Welsh Agricultural Showground after information and representations from Dyfed Powys Police."
The message adds: "I am sorry there is nothing we can do about it. At the moment we do not have a public statement."
No one from Dyfed Powys Police was available to give a comment.