Maxey & Anor v R. [2025] EWCA Crim 472 (16 April 2025)

Maxey & Anor v R. [2025] EWCA Crim 472 (16 April 2025)

The offence of conspiracy to cause public nuisance is complete upon agreement to pursue a course of conduct intended to cause the public nuisance, and the prosecution need only prove that, if carried out as intended, the conduct would necessarily amount to the offence. The actions of authorities responding to the protest do not break the chain of causation. The trial judge's management of the change in the prosecution's case did not cause unfairness or injustice to the appellants.

Citation
[2025] EWCA Crim 472
Parties
First Appellant: Larch Maxey; Second Appellant: Julian Roger Hallam; Respondent: Rex
Jurisdiction
England and Wales
Judgment Date
16 April 2025
Procedural Posture
Criminal Appeal / Appeal Against Conviction
Outcome
Appeal dismissed; convictions upheld.
Legal Topics
Conspiracy, Public Nuisance, Protest Law, Criminal Procedure
Criminal Law Conspiracy Public Nuisance Protest Law Criminal Procedure

Case Brief

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Parties

Larch Maxey

First Appellant

Julian Roger Hallam

Second Appellant

Rex

Respondent

Procedural Posture

Criminal Appeal / Appeal Against Conviction

Legal Issues

  1. 1 Whether the evidence established an agreement to cause a public nuisance
  2. 2 Whether the trial judge misinterpreted section 1(1)(a) of the Criminal Law Act 1977
  3. 3 Whether the change in the prosecution's case after closing submissions caused unfairness

Ratio Decidendi

The offence of conspiracy to cause public nuisance is complete upon agreement to pursue a course of conduct intended to cause the public nuisance, and the prosecution need only prove that, if carried out as intended, the conduct would necessarily amount to the offence. The actions of authorities responding to the protest do not break the chain of causation. The trial judge's management of the change in the prosecution's case did not cause unfairness or injustice to the appellants.

Court Disposition

Appeal dismissed; convictions upheld.