British Sky Broadcasting Ltd & Ors, R (on the application of) v Chelmsford Crown Court

British Sky Broadcasting Ltd & Ors, R (on the application of) v Chelmsford Crown Court

The production orders were quashed because there was no cogent evidence that the journalistic material sought was likely to be of substantial value to the police investigation, the judge failed to conduct a proper balancing exercise under Article 10 ECHR, and the applicants were denied a fair opportunity to contest the necessity and proportionality of the orders due to inadequate disclosure by the police.

Parties
Claimant: British Sky Broadcasting Ltd; Claimant: Independent Television News Ltd; Claimant: British Broadcasting Corporation; Claimant: Hardcash Productions Ltd; Claimant: Jason Neil Parkinson; Defendant: Chelmsford Crown Court; Interested Party: Essex Police
Jurisdiction
England and Wales
Judgment Date
17 May 2012
Procedural Posture
Judicial Review / Judgment on Application to Quash Production Orders
Outcome
Production orders quashed
Legal Topics
Production Orders, Journalistic Material, Article 10 ECHR, Police and Criminal Evidence Act, Proportionality, Judicial Discretion

Case Brief

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Parties

British Sky Broadcasting Ltd

Claimant

Independent Television News Ltd

Claimant

British Broadcasting Corporation

Claimant

Hardcash Productions Ltd

Claimant

Jason Neil Parkinson

Claimant

Chelmsford Crown Court

Defendant

Essex Police

Interested Party

Procedural Posture

Judicial Review / Judgment on Application to Quash Production Orders

  1. 1 Whether the production orders against media organisations for journalistic material were lawful under Schedule 1 to PACE
  2. 2 Whether the orders constituted a disproportionate interference with Article 10 ECHR rights
  3. 3 Whether the applicants were denied a fair hearing

Ratio Decidendi

The production orders were quashed because there was no cogent evidence that the journalistic material sought was likely to be of substantial value to the police investigation, the judge failed to conduct a proper balancing exercise under Article 10 ECHR, and the applicants were denied a fair opportunity to contest the necessity and proportionality of the orders due to inadequate disclosure by the police.

Court Disposition

Production orders quashed

Orders

  • The production orders made against the Claimants are quashed.