Greater Manchester Police v Wigan Athletic AFC Ltd: ChD 21 Dec 2007

The claimant sought payment under section 25 from the defendant football club for the costs of policing football matches. The defendant said that the sums were not due since the events had been over-policed, and had not been agreed or requested.
Held: The club occupied strictly onlt the stadium itself and implied rights of access. Had the police not provided certain cover, the club would have had to have provided alternative marshalling. Though there was no express request to provide policing, one could clearly be implied. There was insufficient evidence to establish any unfairness in the levels of policing required or the charges. The police were able to bring their case within the requirements for restitution set out in Rowe, and to claim on a quantum meruit according to the actual work undertaken. The court set out the basis for calculating the claim for different categories of officers.

Judges:

Mann J

Citations:

[2007] EWHC 3095 (Ch)

Links:

Bailii

Statutes:

Police Act 1996 25, Safety of Sports Grounds Act 1975

Jurisdiction:

England and Wales

Citing:

CitedGlasbrook Brothers Limited v Glamorgan County Council HL 1925
A colliery manager asked for police protection for his colliery during a strike. He wanted police officers to be billeted on the premises. The senior police officer for the area was willing to provide protection by a mobile force, but he refused to . .
CitedHarris v Sheffield United Football Club Ltd CA 1987
The court was asked whether services provided by the police at Sheffield United Football Club for the club’s home fixtures were ‘special police services’ so that, if they were provided at the club’s request, the police could charge for them. Up . .
CitedReading Festival Ltd v West Yorkshire Police Authority CA 3-May-2006
The organisers of a music festival in Leeds appealed a decision that they were liable to pay in full a bill from the police for additional services in policing the festival.
Held: The organisers appeal succeeded. Whilst it was a matter for the . .
CitedRowe, Regina (on the Application of) v Vale of White Horse District Council Admn 7-Mar-2003
The local council sought to claim payment for sewerage services enjoyed by a householder.
Held: Where a supplier has supplied services to another and there is no contractual relationship in existence, the law may afford to the supplier . .
Distinguished on the factsBookmakers’ Afternoon Greyhound Services Ltd v Wilf Gilbert (Staffordshire) Ltd 1994
The bookmaker defendant received a broadcast information service for which he was prepared to pay. That service carried another information service (‘BAGS’) for which the second provider also sought payment. The bookmaker was not prepared to pay for . .

Cited by:

Appeal fromGreater Manchester Police v Wigan Athletic AFC Ltd CA 19-Dec-2008
The parties disputed the amounts payable by a football club to the police for the attendance of police officers at matches. The defendant appealed against a finding that it had requested the services for which charges had been made under section 25 . .
Lists of cited by and citing cases may be incomplete.

Police, Contract, Equity

Updated: 28 July 2022; Ref: scu.262961