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Plans to force London’s minicab drivers to pass written English tests would put up to 33,000 of them out of business, the booking app Uber has said.

On the first day of a high court battle with Transport for London, lawyers for the ride-hailing app said the test would threaten the livelihoods of tens of thousands of drivers.

TfL has proposed a package of requirements for private-hire vehicle drivers in the capital including tests in reading and writing basic English.

It also wants drivers to have private hire insurance when vehicles are not being used to carry passengers and for firms like Uber to set up call centres open 24 hours a day.

Uber London Ltd, which has a private-hire vehicle (PHV) operator's licence, has launched a legal challenge with three individually licensed drivers - Hungarian national Sandor Balogh, Bulgarian national Nikolay Dimitrov and Imran Khan from Parkistan.

Tom de le Mare QC, Uber’s lawyer, told the High Court in London that the transport body’s estimates suggest 33,000 minicab drivers (28 per cent) would either fail the test or be put off from attempting to renew their licence over a period of three years.

There are over 110,000 private hire drivers in the capital.

The new rules, including having to provide new call centre facilities and meet unjustified insurance demands, were also likely to lead to additional costs for PHV operators running into millions of pounds, said Mr de la Mare.

TfL has argued that the requirements, including the test which involves writing a short essay, are necessary for customer safety and public protection.

Uber claims the standard of reading and writing needed to pass the test is too high.

Mr de la Mare also said that there was no evidence that restricted abilities to read and write English had led to problems and that a drivers’ ability to understand road signs and basic directional instructions was already sufficiently tested by a topographical test.

He said Mr Balogh and Mr Dimitrov had completed more than 2,000 trips as registered drivers "and never once in that time been requested to communicate (by reading and writing)".

The High Court is due to hear the case until Thursday although it might be some weeks before a ruling.

A Transport for London spokeswoman said: “The changes to regulation of the private hire industry being challenged in this case are vital, to ensure passenger safety and to raise standards.

"We continue to robustly defend this claim.”