Transport for London v Persons Unknown & Ors

Transport for London v Persons Unknown & Ors

The 27 March 2025 statement by Just Stop Oil constituted a material change of circumstances, but the short period since the statement and ongoing evidence of risk meant it was premature to discharge the injunctions. The injunctions should remain in force for up to six more months, with an earlier review in November 2025 to assess whether the risk of road-blocking protests had truly dissipated.

Parties
Claimant: Transport for London; Defendant: Persons Unknown; Defendant: Mr Alexander Rodger and 137 Others; Defendant: Ms Alyson Lee and 167 Others; Defendant: Matthew Parry
Jurisdiction
England and Wales
Judgment Date
24 November 2025
Procedural Posture
Civil / Second Annual Review Hearing of Final Injunctions
Outcome
Final injunctions to remain in force until an earlier review hearing in November 2025; costs order amended under slip rule by agreement.
Legal Topics
Injunctions, Protest Law, Freedom of Assembly, Civil Disobedience, Review of Injunctions
Civil Procedure Public Order Human Rights Injunctions Protest Law Freedom of Assembly Civil Disobedience Review of Injunctions

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
Sign in to unlock

Parties

Transport for London

Claimant

Persons Unknown

Defendant

Mr Alexander Rodger and 137 Others

Defendant

Ms Alyson Lee and 167 Others

Defendant

Matthew Parry

Defendant

Procedural Posture

Civil / 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 the 27 March 2025 statement by Just Stop Oil indicating cessation of disruptive protests.
  2. 2 Whether the costs order made in favour of TfL should be amended under the slip rule.

Ratio Decidendi

The 27 March 2025 statement by Just Stop Oil constituted a material change of circumstances, but the short period since the statement and ongoing evidence of risk meant it was premature to discharge the injunctions. The injunctions should remain in force for up to six more months, with an earlier review in November 2025 to assess whether the risk of road-blocking protests had truly dissipated.

Court Disposition

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

Orders

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