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Reading Festival Ltd v West Yorkshire Police Authority [2006] EWCA Civ 524

Where a music festival organiser had expressed its hope that the police would deploy officers on the festival site as they had done in previous years, but in fact the police deployed their officers mostly in the communities surrounding the festival site and the festival organiser hired private security for the site, the organiser was not liable to pay the police under s 25(1) of the Police Act 1996 because there had been no request and the services provided were not “special police services”.

12 May 2006

The appellant music festival organiser (R) appealed against judgment given in favour of the respondent police authority (W) on its claim for payment for special police services under s 25(1) of the Police Act 1996. For four years, W had provided special police services to R for the running of an annual three-day music festival. Each year a fee had been agreed and paid. The following year W was opposed to the festival taking place due in part to the escalation of violence at the event in previous years. At a meeting before the event R had expressed its desire to have W police the event as it had before, while W made clear its position that it would not be putting significant numbers of officers on the site, but the parties did not reach agreement. However, the event took place, with W changing its strategy by having fewer officers and a much lower profile on site. R hired security staff to manage the safety of the site. W provided officers based in the surrounding community who were ...

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