Transport for London v Persons Unknown & Ors [2025] EWHC 55 (KB) (16 January 2025)

Transport for London v Persons Unknown & Ors [2025] EWHC 55 (KB) (16 January 2025)

The final injunctions remain necessary and effective in deterring unlawful protest on strategic roads. There has been no material change in circumstances or law to justify discharge or variation. The existence of new criminal offences does not provide an adequate alternative to civil injunctions. Undertakings in lieu are accepted for certain defendants, but costs orders against them are not set aside as there is no jurisdiction or sufficient reason to do so.

Citation
[2025] EWHC 55 (KB)
Parties
Claimant: Transport for London; Defendant: Persons Unknown; Defendants: Mr Alexander Rodger and 137 Others; Defendants: Ms Alyson Lee and 167 Others; Defendant: Indigo Rumbelow; Defendant: Matthew Parry
Jurisdiction
England and Wales
Judgment Date
16 January 2025
Procedural Posture
Civil Injunction Proceedings / Annual Review of Final Injunctions and Costs Orders
Outcome
Final injunctions maintained in current form; undertakings in lieu accepted for specified defendants; costs orders against those defendants not set aside.
Legal Topics
Injunctions Against Protestors, Persons Unknown Injunctions, Costs Orders, Civil Rights Enforcement, Protest Law, Review of Injunctions, Undertakings in Lieu of Injunctions
Civil Procedure Human Rights Public Order Tort Injunctions Against Protestors Persons Unknown Injunctions Costs Orders Civil Rights Enforcement +3 more

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Parties

Transport for London

Claimant

Persons Unknown

Defendant

Mr Alexander Rodger and 137 Others

Defendants

Ms Alyson Lee and 167 Others

Defendants

Indigo Rumbelow

Defendant

Matthew Parry

Defendant

Procedural Posture

Civil Injunction Proceedings / Annual Review of Final Injunctions and Costs Orders

Legal Issues

  1. 1 Whether the final injunctions should be maintained, varied, or discharged on review
  2. 2 Whether undertakings in lieu of injunctions should be accepted for certain defendants
  3. 3 Whether costs orders against certain defendants should be set aside

Ratio Decidendi

The final injunctions remain necessary and effective in deterring unlawful protest on strategic roads. There has been no material change in circumstances or law to justify discharge or variation. The existence of new criminal offences does not provide an adequate alternative to civil injunctions. Undertakings in lieu are accepted for certain defendants, but costs orders against them are not set aside as there is no jurisdiction or sufficient reason to do so.

Court Disposition

Final injunctions maintained in current form; undertakings in lieu accepted for specified defendants; costs orders against those defendants not set aside.

Orders

  • Final injunctions against protest on specified roads continue for remaining defendants and persons unknown.
  • Undertakings in lieu of injunctions accepted for Lewis Applicants and relevant named defendants; injunctions discharged as against them but they remain parties for enforcement purposes.