It's an interesting photo. Is the rider modelling the new raincoat ? It can't be earlier than 1942 and yet the bike is still fitted with an MT1130 and the padlocks don't seem to have been part of the equipment lists after the HT immobilisers were introduced - certainly 1941 onwards.
The exhasust system has been refinished in matt black and no panniers have been fitted.
Could this have been in some out of the way 'establishment' ? Is there any captioning to the photo ?
Ah yes, those were the photos from the clothing test series. The second photo is in the Birch IWM book and dated August 1941 - Would motorcyclists' clothing have been tested at MEE ? If so then quite possibly they had unreturned pre-war test machines on the fleet and as they were a test establishment these would not have been subject to ACIs or DME circulars.