Thorpe v R. [2025] EWCA Crim 1007 (30 July 2025)

Thorpe v R. [2025] EWCA Crim 1007 (30 July 2025)

Paragraph 11 of the SHPO does not conflict with the statutory barring regime under the Safeguarding of Vulnerable Groups Act 2006, as there may be activities involving unsupervised contact with children that fall outside the definition of 'regulated activity.' Given the appellant's risk profile and the need to protect children, the inclusion of paragraph 11 was justified and proportionate.

Citation
[2025] EWCA Crim 1007
Parties
Appellant: Thomas James Thorpe; Respondent: Rex
Jurisdiction
England and Wales
Judgment Date
30 July 2025
Procedural Posture
Criminal Appeal / Judgment on Ground 3 of Appeal
Outcome
Appeal dismissed
Legal Topics
Sexual Harm Prevention Order, Safeguarding of Vulnerable Groups Act 2006, Disclosure and Barring Service, Proportionality of Orders, Conflict of Statutory Regimes
Criminal Law Sexual Harm Prevention Order Safeguarding of Vulnerable Groups Act 2006 Disclosure and Barring Service Proportionality of Orders Conflict of Statutory Regimes

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Parties

Thomas James Thorpe

Appellant

Rex

Respondent

Procedural Posture

Criminal Appeal / Judgment on Ground 3 of Appeal

Legal Issues

  1. 1 Whether paragraph 11 of the SHPO conflicts with or is rendered unnecessary by the Safeguarding of Vulnerable Groups Act 2006 regime
  2. 2 Whether the inclusion of paragraph 11 is proportionate and necessary given the statutory barring regime and other SHPO terms

Ratio Decidendi

Paragraph 11 of the SHPO does not conflict with the statutory barring regime under the Safeguarding of Vulnerable Groups Act 2006, as there may be activities involving unsupervised contact with children that fall outside the definition of 'regulated activity.' Given the appellant's risk profile and the need to protect children, the inclusion of paragraph 11 was justified and proportionate.

Court Disposition

Appeal dismissed