Security Industry Authority v Bryson [2024] NICA 23 (10 April 2024)

Delegation of statutory functions by the Authority was valid, Board ratification remedied any defect, delegation survived departmental restructuring and territorial extension, and statements made to employees acting in the course of their employment are statements to the Authority for the purposes of section 22 offences.

Citation: [2024] NICA 23
Parties: Complainant/appellant: Security Industry Authority; Defendant/respondent: Jamie Bryson
Jurisdiction: Northern Ireland
Judgment Date: 10 April 2024
Procedural Posture: Appeal by Way of Case Stated / Court of Appeal Judgment
Outcome: Case remitted for rehearing before a different District Judge
Legal Topics: Delegation of Statutory Powers, Regulatory Offences, Interpretation of Statutory Provisions, Territorial Extension of Statutory Bodies

Administrative Law Criminal Law Delegation of Statutory Powers Regulatory Offences Interpretation of Statutory Provisions Territorial Extension of Statutory Bodies

Case Brief

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Downloadable case file Legal principles 5 Authorities cited 12 Party arguments 2

Parties

Security Industry Authority

Complainant/appellant

Jamie Bryson

Defendant/respondent

Procedural Posture

Appeal by Way of Case Stated / Court of Appeal Judgment

Legal Issues

1 Validity of delegation of statutory functions
2 Effect of Board ratification on delegation
3 Impact of departmental restructuring on delegation

Ratio Decidendi

Court Disposition

Case remitted for rehearing before a different District Judge

Orders

Remit the case for rehearing before a different District Judge under section 38(1)(f)