Murphy v Media Protection Services Ltd

Murphy v Media Protection Services Ltd

Section 297(1) CDPA does not require the broadcasting service to be based in the UK for the offence to be committed. The programme received by Ms Murphy originated from the UK, and the requisite intent to avoid payment is satisfied by knowingly circumventing the exclusive UK broadcaster's charge, even if payment is made to a foreign broadcaster.

Parties
Appellant/defendant: Karen Murphy; Respondent/informant: Media Protection Services Limited
Jurisdiction
England and Wales
Judgment Date
21 December 2007
Procedural Posture
Criminal Appeal by Way of Case Stated / Appeal From Crown Court Decision to High Court
Outcome
Appeal dismissed
Legal Topics
Copyright Infringement, Fraudulent Reception of Transmissions, Conditional Access Technology, Broadcasting Rights

Case Brief

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Parties

Karen Murphy

Appellant/defendant

Media Protection Services Limited

Respondent/informant

Procedural Posture

Criminal Appeal by Way of Case Stated / Appeal From Crown Court Decision to High Court

  1. 1 Whether s.297(1) CDPA requires the broadcasting service to be provided from the UK
  2. 2 Identification of broadcaster and broadcasting service under s.297(1) CDPA
  3. 3 Definition of 'programme' and 'broadcast' under CDPA

Ratio Decidendi

Section 297(1) CDPA does not require the broadcasting service to be based in the UK for the offence to be committed. The programme received by Ms Murphy originated from the UK, and the requisite intent to avoid payment is satisfied by knowingly circumventing the exclusive UK broadcaster's charge, even if payment is made to a foreign broadcaster.

Court Disposition

Appeal dismissed