Harassment

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Protection from Harassment Act 1997

The Protection from Harassment Act 1997 introduces four new criminal offences: (Archbold 2002: 19-277a)

  • harassment (section 2): summarily only, six months' imprisonment and/or a level 5 fine;
  • fear of violence (section 4); either way, five years' imprisonment and/or a fine on indictment; as above summarily;
  • breach of civil injunction section 3(6); either way, same penalty as Section 4 offence;
  • breach of restraining order section 5(5); either way, same penalty as Section 4.

A new civil tort of harassment is created by Section 3.

All criminal offences are arrestable under Section 24 PACE 1984 as amended by Section 110 Serious Organised Crime and Police Act 2005.

Under section 5, the Crown Court and the magistrates' court can make a restraining order on conviction, prohibiting the defendant from doing anything described in the order, for the purpose of protecting the victim from further harassment or fear of violence. This is one of the major benefits of the Act; See Restraining Orders

To harass as defined in the Concise Oxford Dictionary, Tenth Edition, is to "torment by subjecting to constant interference or intimidation". The conduct must be unacceptable to a degree which would sustain criminal liability and also must be oppressive. We respectfully agree with the analysis of Lord Phillips MR, with whom Jonathan Parker LJ and Lord Mustill agreed, in Thomas v News Group Newspapers Ltd [2001] EWCA Civ 1233 (18 July 2001) :

"[29] Section 7 of the 1997 Act does not purport to provide a comprehensive definition of harassment. There are many actions that foreseeably alarm or cause a person distress that could not possibly be described as harassment. It seems to me that section 7 is dealing with that element of the offence which is constituted by the effect of the conduct rather than with the types of conduct that produce that effect.
[30] The Act does not attempt to define the type of conduct that is capable of constituting harassment. "Harassment" is, however, a word which has a meaning which is generally understood. It describes conduct targeted at an individual which is calculated to produce the consequences described in
section 7 and which is oppressive and unreasonable. The practice of stalking is a prime example of such conduct."
Variation or discharge of a restraining order

Shaw v Director of Public Prosecutions [2005] EWHC 1215 (Admin) (12 April 2005) This was an appeal by way of case stated against a decision of District Judge not to order the discharge of a restraining order which had been made against the appellant pursuant to section 5(1) of the Protection from Harassment Act 1997. The court made it clear that there had to be a good reason in the form of some change of circumstances to justify the variation of an order under section 5(4). Laws LJ said this, at paragraph 14 of his judgment:

"It is common ground that, absent an appeal, a restraining order remains good and valid according to its terms, including a term which extends it until further order."

In a concurring judgment David Steel J. said:

"It seems to me that it follows that on an application or further application to discharge the applicant must show that something has changed so that the continuance of the order is no longer necessary or appropriate."
There is no power of entry to arrest or search for a section 2 Harassment offence. See: List of summary offences which no longer attract trigger powers. See also PACE “Trigger Powers”.
For police powers of seizure when lawfully on premises see: Police powers of seizure

Elements of Offences

Offence of Harassment - Section 2

(Archbold 2002:19-277b)

The elements of the section 2 offences are:

  • a course of conduct;
  • which amounts to harassment of another;
  • which the defendant knows, or ought to know amounts to harassment of another.

The defendant ought to know if his course of conduct amounts to harassment if a reasonable person in possession of the same information would think the course of conduct amounted to harassment of the other.

Section 7 (Archbold 2002: 19-277g) defines a course of conduct as involving conduct on at least two occasions. Harassment is not defined, but includes causing alarm or distress, and conduct is defined as including speech.

Section 7(3)A provides that:

Conduct by one person shall also be taken to be conduct by another if that other has aided, abetted, counselled or procured the conduct.

The knowledge and purpose of the person who aids, abets, counsels or procures conduct are what was contemplated or reasonably foreseeable at the time of the aiding, abetting, counselling or procuring and not when the conduct occurs.

The amendment at (a) above makes it clear that a campaign of collective harassment by 2 or more people can amount to a “course of conduct”. It also confirms that one person can pursue a course of conduct by committing one act personally and arranging for another person to commit another act.

The amendment at (b) above ensures that the knowledge and purpose of the person who aids, abets, counsels or procures conduct is judged at the time that the conduct was planned and not when it is carried out. This may assist a defendant to offer a defence of reasonableness if, at the time that he commissioned a subsequent act, he was unaware that the first act had caused distress to the complainant. Such a defence would not succeed if the defendant ought to have known that the act would cause distress at the time that the subsequent act was commissioned.

This section extends the definition of “conduct” and “course of conduct” for the purposes of sections 1 to 5 of the Act. It was inserted by section 44 Criminal Justice Act 2001 and came into force on 1 August 2001.

Section 2 is summary only

Note the difference between the civil and criminal jurisdiction. In the civil jurisdiction the power to make the restraining order is immediate. Once the plaintiff has satisfied the court of the case then the restraining order can be made. In the criminal jurisdiction the power to make a restraining order only arises on conviction. Some protection can be offered to the victim by the imposition of bail conditions imposed at the time of charge. These provide for a legally enforceable set of conditions that will be very similar to the eventual restraining order.

It is important to remember that this legislation criminalises a course of conduct. Criminal investigators are more used to dealing with instant offences e.g. theft, burglary, assault. To establish an offence under Act this requires at least two instances and preferably more to show a course of conduct.

It is helpful to the court if a schedule itemising the objectionable behaviour is referred to in the charge sheet. It is also helpful to the defendant and his advisers in addressing the case that is alleged against the defendant.

The power of the legislation lies more in the ability to impose a restraining order than in the punishment for errant behaviour.

Section 12 Domestic Violence, Crime and Victims Act 2004 will allow a restraining order to be made on acquittal. See: section 12 commentary This strange and counter-intuitive provision came into force on 1 July 2007.

Putting people in fear of violence: Section 4

The elements of the section 4 offence are:

  • a course of conduct which causes another to fear on at least two occasions, that violence will be used against him;
  • and which the defendant knows, or ought to know that his course of conduct would cause the other to fear on each of those occassions.

The offence is an either way offence. In the Crown Court the maximum sentence is 5 years. The penalty in the Magistrates court is 6 months or a fine not exceeding the statutory maximum or both.

If a jury acquit of an offence under section 4 they may convict of an offence under section 2

Limitation period

See also: Magistrates court: Laying of information: limitation of time

If the Defendant is charged under Section 2 Protection from Harassment Act 1997 can allegations more than 6 months old form part of the prosecution case?

Under section 127 Magistrates' Court Act 1980, a Magistrates' Court shall not try an information alleging a summary offence or hear a complaint unless the information was laid or the complaint made within six months from the time when the offence was committed or the matter of complaint arose. The issue for the court that arises in those circumstances, put shortly, is identifying the correct approach to be adopted by the justices to the events and incidents that fall outside of the six month limitation period.

The offence of harassment, created by the 1997 Act, is in the following terms:

Section 1(1) "A person must not pursue a course of conduct --

(a) which amounts to harassment of another, and
(b) which he knows or ought to know amounts to harassment of the other."

Section 2(1) "A person who pursues a course of conduct in breach of section 1 is guilty of an offence."

Two further relevant sections are:

Section 7(2) "References to harassing a person include alarming the person or causing the person distress."

and

Section 7(3) A “course of conduct” must involve conduct on at least two occasions.

Case law

Curtis v R (09 February 2010)

Curtis v R [2010] EWCA Crim 123 (09 February 2010)
The appellant was convicted of putting a person in fear of violence by harassment contrary to section 4(1) of the Protection from Harassment Act 1997 (count 1) and of causing danger to road users contrary to section 22A(1) of the Road Traffic Act 1988 (count 2). He was sentenced on count 1 to a 12 month community service order with an unpaid work requirement of 120 hours. A similar order was imposed on count 2 with an unpaid work requirement of 60 hours, to run consecutively to count 1. He appealed against conviction. The appellant's submissions are, first, that the evidence for the prosecution did not amount to what in law was an offence under section 4(1) of the 1997 Act. Secondly, had the case been stopped on count 1, it would have been necessary to discharge the jury on count 2 because they had heard a very considerable amount of evidence unrelated to that count which may have unfairly prejudiced the appellant in the jury's consideration of that count. The appellant and the complainant lived together. They were both police constables. The prosecution was based on six incidents which occurred while the appellant and complainant were living together. Held: The jury would have been entitled, if they saw fit, to conclude that, over the course of the relationship, the appellant's conduct was deplorable and worse than that of the complainant. The incidents were far from trivial and significant force was on occasion used. However, the court could not conclude that, in this volatile relationship, the six incidents over a nine month period amounted to a course of conduct amounting to harassment within the meaning of the statute. The spontaneous outbursts of ill-temper and bad behaviour, with aggression on both sides, which are the hallmarks of the present case, interspersed as those outbursts were with considerable periods of affectionate life, cannot be described as such a course of conduct. The court did not exclude the possibility that harassment in section 1 may include harassment of a co-habitees but the appellant's conduct in this case could not properly be categorised as a course of conduct amounting to harassment within the meaning of the Act. Both convictions quashed.

James v Crown Prosecution Service (4 November 2009)

James v Crown Prosecution Service, DC, 4 November 2009. A series of 3 telephone calls, over a short period of time, was sufficient to amount to a course of conduct for the purposes of the Protection from Harassment Act 1997. "12. The fact that the appellant did not initiate the particular calls is irrelevant. There are two answers to that point. The first is that the court found (although this was not specifically recorded in the statement of case) that the appellant knew when he rang [Manager] that she would be obliged to return his call if she were not immediately available. The second and more important point is that, in any event, it matters not whether he directly initiated the telephone calls or not. If I am continually abusive to someone who comes within my vicinity, that may still be capable of constituting a course of conduct, even if the victim chooses to come within my vicinity. The fact that he or she chooses to do so might arguably be relevant to the question of whether there is harassment, but not to the question of whether there is a course of conduct."

Crawford v Crown Prosecution Service (04 February 2008)

Crawford v Crown Prosecution Service [2008] EWHC 148 (Admin) (04 February 2008)

Buckley & Anor v Director of Public Prosecutions (14 January 2008)

Buckley & Anor v Director of Public Prosecutions [2008] EWHC 136 (Admin) (14 January 2008) This is an appeal by way of case stated from the decision of a Deputy District Judge by which he convicted the two appellants of offences of harassment, contrary to section 2(1) and (2) of the Protection from Harassment Act 1997.

Hatch v Thames Valley Police Authority & Anor (02 November 2005)

Hatch v Thames Valley Police Authority & Anor [2005] EWCA Civ 1447 (02 November 2005) This was a renewed application for permission to appeal by way of an oral hearing. The applicant (the claimant in proceedings), sought to appeal a decision of the Court . The judge by his order dismissed the applicant's claim for damages under the Protection from Harassment Act 1997. The nature of the claim by the applicant was that his former wife, the defendant to the claim and respondent to this application, pursued a course of conduct between 1998 and 2000 which amounted to harassment for the purpose of the 1997 Act.

Director of Public Prosecutions v Hall (05 October 2005)

Director of Public Prosecutions v Hall [2005] EWHC 2612 (Admin) (05 October 2005) This was an appeal by way of case stated from a decision of the Youth Magistrates' Court. The issue was the true construction of section 5(4) of the Protection from Harassment Act 1997.

Director of Public Prosecutions v Baker (02 November 2004)

In Director of Public Prosecutions v Baker [2004] EWHC 2782 (Admin) (02 November 2004) The Court Held:

“so long as at least one of the incidents relied on occurred within the limitation period, I consider the provisions of section 127 Magistrates' Court Act 1980 were not violated: the offence was committed within the relevant six month period, because the last incident relied on to prove it occurred within that period. The offence as framed by the prosecution spanned two years and eight months, and was only complete when the last act was committed. Of course, the offence might have been drafted so as to cover a different (and shorter) timeframe, but as charged it subsisted until the final event relied on. In my view, this purposive interpretation of the section meets the overall justice of the situation, in that it ensures that an offence committed over a long period of time can be tried as readily as one in which all of the relevant facts occur within a six month period. Moreover, generally this approach should avoid prejudice to defendants, not least because in the result they will often be charged with one, rather than a number of offences.”
Lau v Director of Public Prosecutions (22 February 2000)

It was contended by the Appellant that in order for there to be a 'course of conduct' for the purposes of the Act, there had to be nexus between the incidents relied upon by the Crown. Lau v Director of Public Prosecutions [2000] EWHC QB 182 (22 February 2000)

Para 15. "I fully accept that the incidents which need to be proved in relation to harassment need not exceed two incidents, but, as it seems to me, the fewer the occasions and the wider they are spread the less likely it would be that a finding of harassment can reasonably be made. One can conceive of circumstances where incidents, as far apart as a year, could constitute a course of conduct and harassment. In argument Mr Laddie put the context of racial harassment taking place outside a synagogue on a religious holiday, such as the day of atonement, and being repeated each year as the day of atonement came round. Another example might be a threat to do something once a year on a person's birthday. Nonetheless the broad position must be that if one is left with only two incidents you have to see whether what happened on those two occasions can be described as a course of conduct." Conviction quashed.
Majrowski v. Guy's and St. Thomas' NHS Trust (12 July 2006)

Majrowski v. Guy's and St. Thomas' NHS Trust [2006] UKHL 34 (12 July 2006)

Section 6 of the Protection from Harassment Act 1997 contains the provision about limitation that was thought appropriate for England and Wales. It provides simply that in section 11 of the Limitation Act 1980 there was to be inserted a new subsection (1A) to the effect that that section was not to apply to any action brought for damages under section 3 of the 1997 Act. The effect of that provision is that an action brought under section 3 of the 1997 in England and Wales is subject to a six year time limit. It is unnecessary for this purpose to decide whether the action is to be classified as founded on tort and or is for a sum recoverable by statute, as the time limit in both of these cases is the same: sections 2 and section 9 of the 1980 Act. Mr Turner submitted that the right to claim damages in section 3 of the 1997 did not create a new tort. In my opinion it did, just as the equivalent remedy which it created for Scotland is properly classified as a delictual one.

At paragraph 18 Lord Nicholls of Birkenhead stated :

“18. I turn to the material provisions of the 1997 Act. The purpose of this statute is to protect victims of harassment, whatever form the harassment takes, wherever it occurs and whatever its motivation. The Act seeks to provide protection against stalkers, racial abusers, disruptive neighbours, bullying at work and so forth.”

At paragraph 30, Lord Nicholls added:

"30. Courts are well able to separate the wheat from the chaff at an early stage of the proceedings. They should be astute to do so. In most cases courts should have little difficulty in applying the "close connection" test. Where the claim meets that requirement, and the quality of the conduct said to constitute harassment is being examined, courts will have in mind that irritations, annoyances, even a measure of upset, arise at times in everybody's day-today dealings with other people. Courts are well able to recognise the boundary between conduct which is unattractive, even unreasonable, and conduct which is oppressive and unacceptable. To cross the boundary from the regrettable to the unacceptable the gravity of the misconduct must be of an order which would sustained criminal liability under section 2."
Buckley & Anor v Director of Public Prosecutions (14 January 2008)

Buckley & Anor v Director of Public Prosecutions [2008] EWHC 136 (Admin) (14 January 2008)

The Deputy District Judge found the following facts, which are set out in the case stated:

"[1] That on an unspecified date, outside the period of the charge, Sylvia Buckley had followed Angela Garrod in her car as Angela Garrod drove to visit a relative.

[2] On the 20th May 2005 as Angela Garrod approached the 'Silver Oyster' public house where she worked as a barmaid she was approached in the car park by Lisa Smith who told her that Sylvia Buckley had taken an overdose and if it was proven to be her fault she would have the mafia after her, causing Angela Garrod to become nervous and upset.

[3] On the 10th June 2005 Sylvia Buckley drove her car alongside Angela Garrod's car, but I was not sure that, whilst stationary at the traffic lights, she had said to Angela Garrod 'you're fucking dead'. [We note that the Deputy District Judge, therefore, did not find a piece of conduct constituting harassment against Sylvia Buckley on 10th June.]

[4] That on the 15th November 2005, the anniversary of Stephen Ballard's birthday, both Complainants and a number of prosecution witnesses had attended the cemetery where Stephen Ballard was buried. As Angela and Ryan Garrod approached the graveside, where both Complainants were already present, Lisa Smith made an intimidating comment to Angela Garrod with reference to a near collision between their respective cars, this comment being sufficient to cause Angela Garrod to turn about and return to her car. Lisa Smith said words to the effect of 'your mother's dead' to Ryan Garrod causing him to cry.

[5] As Angela Garrod and her son drove away from the cemetery Lisa Smith ran forward and spat at their car. Sylvia Buckley and Lisa Smith chose to leave the cemetery in pursuit of Angela Garrod's car. Sylvia Buckley drove her car close behind Angela Garrod's vehicle in an intimidating manner and continued to do so during the journey to the 'Silver Oyster' public house.

[6] Sylvia Buckley drove into the car park of the public house following Angela Garrod. In the car park one of the Applicants removed the keys from the ignition to Angela Garrod's car whilst the other threw gravel in the direction of Angela Garrod's car. Lisa Smith said to Ryan 'you're a dead boy', causing him to become tearful."

In these circumstances, the questions of law raised by the Deputy District Judge fall to be answered as follows:

"a. Was I wrong in law to rule that my findings of fact in respect of 15th November 2005 were sufficient in themselves to constitute a 'course of conduct' involving conduct on at least two occasions?"

The answer is "no". The facts as found by the Deputy District Judge were capable of constituting conduct on two or three occasions. Secondly:

"b. Did I err in concluding that no prejudice arose to either Applicant as a result of my deciding that the events of the 15th November 2005 could be regarded as a sufficient 'course of conduct' notwithstanding that the prosecution had opened their case against each Applicant on a different basis?"

The answer again is "no". No prejudice was caused to the appellants in the pursuit of their defences, even though the prosecution had opened its case on a different basis. The course of evidence at trial would have been the same regardless. In these circumstances, the other two grounds of appeal do not arise and there is no need for us to determine them. Had it however been necessary, I would have held that the same conclusion applied to the Deputy District Judge's view of the connection between the events of 20th May and 15th November as I have held in relation to his findings about 15th November, whilst the prosecution accept and I agree that the Deputy District Judge could not have properly reached the fourth conclusion that he did.

Serious Organised Crime and Police Act 2005: Harassment

Home Office Circular 34/2005 Serious Organised Crime and Police Act 2005: Harassment

Section 125: Harassment intended to deter lawful activities

A number of companies have been granted injunctions under section 3 of the Protection from Harassment Act 1997 ("the 1997 Act") to protect their employees from harassment by animal rights protestors. Despite this, it is not clear how far the 1997 Act can be used to protect employees of a company or a company itself.

Under section 1 of the 1997 Act the term "harassment" applies to a course of conduct which harasses or alarms another or which causes that person distress. The conduct has to take place on at least two occasions. Section 2 of the 1997 Act makes it a criminal offence for a person to pursue a course of conduct which amounts to harassment of another and which that person knows amounts to harassment of the other. Section 3 provides a civil remedy which enables a victim to seek an injunction against a person who is harassing them or may be likely to do so. To secure a conviction under section 2 it needs to be proven that there is a course of conduct in which one person harassed another on at least two occasions. The courts have applied a strict interpretation of the word "another" which has confined the application of this provision to harassment of individuals and thus it is unclear how far employees of a company can benefit from this provision when they have not previously themselves been harassed even though a fellow employee has been.

Section 125 seeks to address this. Subsection (2) amends section 1 of the 1997 Act by inserting a new subsection (1A) which makes it an offence for a person to pursue a course of conduct involving the harassment of two or more persons on separate occasions which he knows or ought to know involves harassment and the purpose of which is to persuade any person (not necessarily one of the persons being harassed) not to do something he is entitled to do or to do something he is not under any obligation to do. It is not intended to catch lawful lobbying or peaceful protesting. A person distributing leaflets outside a shop about which they are protesting, for example, would not be caught unless they were to actually threaten or intimidate the person to whom they were handing out the leaflet and that person felt harassed, alarmed or distress. There would also have to be at least two separate incidents amounting to a course of conduct. The sort of behaviour which will engage the new offence is activity involving threats and intimidation which forces an individual or individuals to stop doing lawful business with another company or with another individual.

Subsection (5) inserts a new section 3A in the 1997 Act. This new section allows for an injunction to be sought where there is an actual or apprehended breach of new section 1(1A). New section 3A(2) defines who can apply to the High Court or county court for an injunction, namely the person who is the victim of the course of conduct or any person at whom the persuasion is aimed. In other words, where people who work for a particular company are being harassed in order to persuade them not to work for that company, or in order to persuade the company not to supply another company, either the employees themselves or the company in question could apply for an injunction.

Subsection (7) amends the definition of course of conduct in section 7(3) of the 1997 Act to clarify that, in the case of conduct in relation to two or more persons, course of conduct means conduct on at least one occasion in relation to each person.

Section 126: Harassment etc of a person in his home

Section 126 Subsection (1) inserts a new section 42A in the Criminal Justice and Police Act 2001 to create a new offence of harassment etc of a person in his home.

Under, section 42 of the Criminal Justice and Police Act 2001 the police have the power to issue a direction to any person who is outside or in the vicinity of a person's home and who they reasonably believe is there to represent to the resident, or persuade the resident, that he should not do something that he is entitled to do (or should do something that he is not obliged to do) and his presence amounts to or is likely to cause the resident harassment, alarm or distress.

The new offence criminalises behaviour of broadly the same kind as that which enabled the police to issue a direction under section 42 of the Criminal Justice and Police Act 2001.

New section 42A(1) (a) to (d) sets out the four ingredients of the new offence which need to be proved. A person will commit an offence if (i) he is present outside or in the vicinity of any premises that are used as a dwelling; (ii) he is there to represent to the resident or another individual, or persuade the resident or another individual, that he should not do something he is entitled to do or should do something he is not obliged to do; (iii) the person intends his presence to amount to harassment, alarm or distress to the resident or knows or ought to know that his presence is likely to do so; and (iv) his presence amounts to or is likely to result in harassment of the resident or another individual.

New section 42A(2) defines the individuals who can be subjected to harassment by a person under subsection (1) - namely, the resident, someone in the resident's dwelling or a person in a nearby dwelling, for example a neighbour.

New section 42A(3) clarifies that a person's presence in subsections (1)(c) and (d) can be a person's presence on his own or with other people.

New section 42A(5) sets out the penalty for the offence under subsection (1).

New section 42A(7) clarifies that "dwelling" in section 42A has the same meaning as in Part 1 of the Public Order Act 1986, namely "any structure or part of a structure occupied as a person's home or as other living accommodation (whether the occupation is separate or shared with others) but does not include any part not so occupied..".

Subsection (2) provides a constable in uniform with a power to arrest anyone who he reasonably suspects is committing or has committed an offence under new section 42A. By virtue of subsection (3) this arrest power will cease to have effect on the commencement of section 110 of this Act which provides a new arrest regime for offences.

Section 127: Harassment etc: police direction to stay away from person's home

Section 127 amends section 42 of the Criminal Justice and Police Act 2001 (the "2001 Act") to make it an offence for a person, where he is subject to a direction to leave the vicinity, to return within a period of up to 3 months (the precise length of time to be specified by a constable) for the purposes of representing to or persuading a person not to do something he is entitled to do, or to do something he is not obliged to do.

It is doubtful whether a direction issued by a police officer under section 42 could lawfully direct a person to stay away from the premises for anything other than a relatively short period of time. Section 127 addresses this point.

Subsection (2) substitutes a new section 42(4) of the 2001 Act, which sets out the requirements that may be imposed by a direction. This gives a police constable the discretion to require someone either just to leave the vicinity of the premises in question, or to leave the vicinity and not to return to it within a specified period of up to 3 months.

The effect of subsections (3) and (4) of section 127 is to create different offences and penalties for non-compliance with a direction, depending on the requirements imposed by the direction.

Subsection (3) amends subsection 42(7), which is the current offence and penalty for knowingly contravening a direction given by a constable, to make it clear that the offence in 42(7) does not apply to situations where a requirement to leave the vicinity and not to return within a specified period has not been complied with.

Subsection (4) inserts new subsections (7A) to (7C) in section 42 of the 2001 Act. New subsection (7A) creates a new offence of failure to comply with a direction to leave the vicinity and not to return within a specified period for the purposes of representing to or persuading the resident that he should do something or not to do something. New subsection (7B) sets out the penalty for an offence committed under subsection (7A).

New subsection (7C) is a transitional provision which takes into account the alteration of penalties for summary offences in the Criminal Justice Act 2003. Until section 281(5) of the Criminal Justice Act 2003 comes into force, the maximum custodial penalty for the new offence will be 6 months.

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