Katrin Ivanova & Ors v R

Katrin Ivanova & Ors v R

The prosecution must identify a purpose for which the defendant acted, but whether that purpose is prejudicial to the safety or interests of the State is an objective question; the term 'enemy' includes states posing an active threat to UK national security, not limited to those at war or likely to be at war.

Parties
Appellant: Katrin Ivanova; Appellant: Orlin Roussev; Respondent: The King
Jurisdiction
England and Wales
Judgment Date
13 March 2025
Procedural Posture
Criminal Appeal / Interlocutory Appeal
Outcome
appeal dismissed
Legal Topics
Conspiracy, Official Secrets, Statutory Interpretation, Mens Rea, Reporting Restrictions
Criminal Law National Security Conspiracy Official Secrets Statutory Interpretation Mens Rea Reporting Restrictions

Case Brief

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Parties

Katrin Ivanova

Appellant

Orlin Roussev

Appellant

The King

Respondent

Procedural Posture

Criminal Appeal / Interlocutory Appeal

Legal Issues

  1. 1 Whether 'purpose prejudicial to the safety or interests of the State' under section 1(1) of the Official Secrets Act 1911 is a subjective or objective test
  2. 2 Whether the term 'enemy' in section 1(1)(c) of the Official Secrets Act 1911 requires proof of foreseeability of armed conflict or includes hostile states

Ratio Decidendi

The prosecution must identify a purpose for which the defendant acted, but whether that purpose is prejudicial to the safety or interests of the State is an objective question; the term 'enemy' includes states posing an active threat to UK national security, not limited to those at war or likely to be at war.

Court Disposition

appeal dismissed