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England and Wales decisions
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The High Court dismissed the DPP’s case-stated appeal over a Qu’ran-burning protest, holding the Crown Court was entitled to find the section 5 threshold unmet.
The University has demonstrated a compelling need for protection of its property rights against repeated unlawful protest, trespass, and nuisance by persons unknown. The injunction is justified and proportionate under Articles 10 and 11 ECHR, given the availability of lawful protest mechanisms, the presumption in favour of consent under the Code, and the liberty to apply to vary or discharge. The terms, geographic scope (excluding the Music Building), and temporal limit (until 31 July 2026) are appropriate, and notification requirements have been satisfied.
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Valero Energy Ltd & Ors v Persons Unknown & Ors [2026] EWHC 397 (KB) (23 February 2026)
The High Court kept Valero’s final injunction in force after its second annual review, finding no material change in risk from protest-related trespass or disruption.
The High Court granted Birmingham City Council interim injunctive relief against unknown protesters blocking depots and waste vehicles, and allowed alternative service.
Hanson Quarry Products Europe Ltd (t/a Heidelberg Materials UK) v Davies & Ors [2026] EWHC 118 (KB) (23 January 2026)
Part-heard contempt proceedings over protests at a quarry. The court found service and knowledge established, reserved final issues for DV and DJJ, and adjourned sanction.
The University is entitled to a final injunction against persons unknown for a year over three specified sites, as there is a real and imminent risk of trespass and nuisance, no realistic private law or human rights defence, and the injunction is necessary, proportionate, clear, and leaves ample opportunity for protest elsewhere. The procedural and substantive requirements for injunctions against persons unknown are satisfied.
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Sentencing judges must consider conscientious motivation as relevant to culpability, assess proportionality of interference with ECHR rights, and impose the shortest sentence commensurate with seriousness; manifestly excessive sentences must be reduced, but immediate custody is justified given the scale, planning, and harm of the offences.
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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.
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Transport for London v Persons Unknown & Ors [2025] EWHC 3005 (KB) (17 November 2025)
The High Court continued TfL’s final injunctions against road-blocking protest groups, but only until an earlier review in November 2025. It also amended a costs order under the slip rule.
The injunction remains necessary due to a real and imminent risk of direct action at the Sites by environmental protest groups. The evidence demonstrates ongoing threats, lack of assurances from protest groups, and substantial harm if the Sites are left unprotected. The description of defendants is amended to include other environmental campaigns. No requirement for permission before contempt applications is imposed.
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