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Ronald Philpot, R (on the application of) v The Commissioner of Police of the Metropolis

[2023] EWCA Civ 66
A police officer was banned from contacting his wife, who accused him of domestic abuse. The ban was initially wrong, but the court said it was okay because it was needed to protect the wife and make sure the investigation into the officer was fair. The court said the officer could still see his kids.

Key Facts

  • PC Ronald Philpot, a Metropolitan Police officer, challenges a restriction on contacting his wife, Kim Philpot, imposed following allegations of domestic violence and abuse.
  • The restriction prohibits direct or indirect contact unless required by the family court or for childcare via a third party.
  • The restriction was initially imposed under Regulation 11 of the Police (Conduct) Regulations 2020, but this was deemed unlawful.
  • The restriction was upheld as lawful under Regulation 6 of the Police Regulations 2003, as designed to secure the proper exercise of the functions of a constable.
  • Kim Philpot is the main witness in the ongoing misconduct investigation against PC Philpot.
  • No non-molestation order or injunction has been sought by Kim Philpot.
  • The issue of PC Philpot's contact with his children has been resolved.

Legal Principles

Regulation 11 of the Police (Conduct) Regulations 2020 does not allow prohibition on contacting witnesses.

Police (Conduct) Regulations 2020

Regulation 6(2) of the Police Regulations 2003 permits restrictions on police officers' private lives if 'designed to secure the proper exercise of the functions of a constable'.

Police Regulations 2003

Chief officers have a general power to direct and control their force, and to enforce Standards of Professional Behaviour.

Police Reform and Social Responsibility Act 2011, section 4(3); Police (Conduct) Regulations 2020, Schedule 2

Article 8 ECHR (right to respect for private and family life) is a qualified right, allowing interference if in accordance with the law and proportionate.

ECHR Article 8

Outcomes

Appeal dismissed.

The restriction on contacting his wife was proportionate to protect the complainant and the integrity of the misconduct proceedings. The impact on Philpot's private life was deemed minimal, and alternative arrangements for childcare were in place.

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