Reading Festival Ltd v West Yorkshire Police Authority [2006] EWCA Civ 524 (03 May 2006)

Reading Festival Ltd v West Yorkshire Police Authority [2006] EWCA Civ 524 (03 May 2006)

No request, express or implied, for 'special police services' was made by Reading Festival Limited for the 2003 festival beyond traffic management. The absence of a meeting of minds and express refusal to pay for other police services precluded liability under section 25(1) of the Police Act 1996. The police services provided offsite were not 'special police services' within the statutory meaning but part of the police's ordinary public duty.

Citation
[2006] EWCA Civ 524
Parties
Appellant/defendant: Reading Festival Limited; Respondent/claimant: West Yorkshire Police Authority
Jurisdiction
England and Wales
Judgment Date
03 May 2006
Procedural Posture
Civil Appeal / Appeal From High Court (queen's Bench Division, Leeds District Registry)
Outcome
Appeal allowed. Judgment entered for Reading Festival Limited.
Legal Topics
Police Powers and Duties, Special Police Services, Public Event Policing, Implied Contract, Statutory Interpretation
Administrative Law Contract Law Public Law Police Powers and Duties Special Police Services Public Event Policing Implied Contract Statutory Interpretation

Case Brief

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Downloadable case file Legal principles 3 Authorities cited 5 Party arguments 2 Amounts and remedies 2
Sign in to unlock

Parties

Reading Festival Limited

Appellant/defendant

West Yorkshire Police Authority

Respondent/claimant

Procedural Posture

Civil Appeal / Appeal From High Court (queen's Bench Division, Leeds District Registry)

Legal Issues

  1. 1 Whether a request for 'special police services' was made by the event promoter under section 25(1) of the Police Act 1996
  2. 2 Whether the police services provided constituted 'special police services' within the meaning of the Act and were chargeable

Ratio Decidendi

No request, express or implied, for 'special police services' was made by Reading Festival Limited for the 2003 festival beyond traffic management. The absence of a meeting of minds and express refusal to pay for other police services precluded liability under section 25(1) of the Police Act 1996. The police services provided offsite were not 'special police services' within the statutory meaning but part of the police's ordinary public duty.

Court Disposition

Appeal allowed. Judgment entered for Reading Festival Limited.

Orders

  • Judgment for Reading Festival Limited. No liability for payment of police services beyond agreed traffic management.