Transport for London v Persons Unknown & Ors [2025] EWHC 3005 (KB) (17 November 2025)

Transport for London v Persons Unknown & Ors [2025] EWHC 3005 (KB) (17 November 2025)

The 27 March 2025 statement by JSO constituted a material change of circumstances, but the short period since that statement and ongoing evidence of protest risk justified continuation of the final injunctions for a further limited period, pending an earlier review in November 2025.

Citation
[2025] EWHC 3005 (KB)
Parties
Claimant: Transport for London; Defendant: Persons Unknown; Defendants: Mr Alexander Rodger and 137 Others; Defendants: Ms Alyson Lee and 167 Others; Defendants: 37 Named Defendants in the TfL IB Claims (the Represented Defendants); Defendant: Matthew Parry (Named Defendant 143 in the TfL JSO Claim)
Jurisdiction
England and Wales
Judgment Date
17 November 2025
Procedural Posture
Civil Injunction Proceedings / Second Annual Review Hearing of Final Injunctions
Outcome
Final injunctions to remain in force pending an additional earlier review hearing in November 2025; costs order amended under slip rule by agreement.
Legal Topics
Injunctions, Protest Law, Civil Disobedience, Review of Injunctions, Persons Unknown, Slip Rule, Costs Orders
Civil Procedure Public Order Human Rights Injunctions Protest Law Civil Disobedience Review of Injunctions Persons Unknown +2 more

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 2 Authorities cited 3 Party arguments 2 Amounts and remedies 4
Sign in to unlock

Parties

Transport for London

Claimant

Persons Unknown

Defendant

Mr Alexander Rodger and 137 Others

Defendants

Ms Alyson Lee and 167 Others

Defendants

37 Named Defendants in the TfL IB Claims (the Represented Defendants)

Defendants

Matthew Parry (Named Defendant 143 in the TfL JSO Claim)

Defendant

Procedural Posture

Civil Injunction Proceedings / Second Annual Review Hearing of Final Injunctions

Legal Issues

  1. 1 Whether final injunctions preventing road-blocking protests should be continued or discharged in light of changed circumstances, specifically JSO's public statement to cease disruptive protests
  2. 2 Whether the costs order should be amended under the slip rule

Ratio Decidendi

The 27 March 2025 statement by JSO constituted a material change of circumstances, but the short period since that statement and ongoing evidence of protest risk justified continuation of the final injunctions for a further limited period, pending an earlier review in November 2025.

Court Disposition

Final injunctions to remain in force pending an additional earlier review hearing in November 2025; costs order amended under slip rule by agreement.

Orders

  • Final injunctions continued for up to 6 months, with review hearing scheduled for November 2025.
  • Costs order amended under slip rule pursuant to agreed terms.