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 police how they felt that the festival needed to be policed, the organiser was not to be put in an all or nothing position. Though the section did not speak of a contract, some agreement from the organiser would normally be required before he could be made liable. There was insufficent evidence of a request from the organisers for the services provided.
Scott Baker LJ said that section 25: ‘is an enabling section. That is, it enables the police to do that which the common law already said they could do. For my part, I do not think section 15 (1) added anything to or altered the common law position except possibly to clarify that the police authority has the last word on the scale of charges.’
The Hon Mr Justice Neuberger The Honourable Mr Justice Jacob Lord Justice Scott Baker
Times 15-May-2006, [2006] EWCA Civ 524, [2006] 1 WLR 2005
Bailii
Police Act 1996 25
England and Wales
Citing:
Cited – Harris 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 . .
Cited – Glasbrook 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 . .
Cited by:
Cited – 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.
Cited – Greater 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.
Updated: 22 August 2021; Ref: scu.241444