Trinity Mirror & Ors, R (on the application of) v Croydon Crown Court

Trinity Mirror & Ors, R (on the application of) v Croydon Crown Court

The Crown Court lacked jurisdiction to make the order restraining media identification of the defendant and his convictions for the protection of his children, as such an order was not incidental to its jurisdiction and not supported by s.11 Contempt of Court Act 1981 or s.45(4) Supreme Court Act 1981. The proper court for such an order is the High Court.

Parties
Appellant: Trinity Mirror plc; Appellant: Times Newspapers Ltd; Appellant: News Group Newspapers Ltd; Appellant: Newsquest Ltd; Respondent: Crown Prosecution Service; Intervener: A and B (Minors, acting by the Official Solicitor to the Supreme Court)
Jurisdiction
England and Wales
Judgment Date
01 February 2008
Procedural Posture
Criminal Appeal / Appeal Against Crown Court Order Under S.159 Criminal Justice Act 1988
Outcome
appeal allowed
Legal Topics
Reporting Restrictions, Open Justice, Protection of Children, Jurisdiction of Crown Court, Injunctions, Balancing Article 8 and Article 10 Rights

Case Brief

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Parties

Trinity Mirror plc

Appellant

Times Newspapers Ltd

Appellant

News Group Newspapers Ltd

Appellant

Newsquest Ltd

Appellant

Crown Prosecution Service

Respondent

A and B (Minors, acting by the Official Solicitor to the Supreme Court)

Intervener

Procedural Posture

Criminal Appeal / Appeal Against Crown Court Order Under S.159 Criminal Justice Act 1988

  1. 1 Did the Crown Court have jurisdiction to make an order restraining media identification of the defendant and his convictions to protect his children?
  2. 2 Was the order under s.11 Contempt of Court Act 1981 or s.45(4) Supreme Court Act 1981 valid?
  3. 3 Should the balance between Article 8 (children's rights) and Article 10 (media freedom) be resolved in favour of the children?

Ratio Decidendi

The Crown Court lacked jurisdiction to make the order restraining media identification of the defendant and his convictions for the protection of his children, as such an order was not incidental to its jurisdiction and not supported by s.11 Contempt of Court Act 1981 or s.45(4) Supreme Court Act 1981. The proper court for such an order is the High Court.

Court Disposition

appeal allowed

Orders

  • Judge's order restraining media identification discharged
  • No reporting restriction remains in force