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Birmingham City Council v Victoria Adshead

[2024] EWHC 2259 (KB)
A woman was caught street racing in Birmingham and admitted to breaking a court order against it. The judge gave her a suspended jail sentence (meaning she won't go to jail unless she breaks the law again) and made her pay a fine.

Key Facts

  • Ms Victoria Adshead admitted contempt of court for breaching an injunction against street cruising in Birmingham.
  • The injunction, granted on 27 February 2024, prohibited participation in street cruises within Birmingham's boundaries.
  • Adshead admitted driving in convoy at excessive speeds (up to 70mph) on 23 June 2024, breaching paragraph 1 of the injunction.
  • The court viewed video footage corroborating Adshead's admission.
  • Adshead's actions caused a danger to other road users and constituted a nuisance.
  • Adshead is 22 years old, of good character, and employed.

Legal Principles

Sentencing in contempt cases should follow the guidance in *Lovett v Wigan Borough Council* [2022] EWCA Civ 1631 and *Birmingham City Council v Lloyd* [2023] EWCA Civ 1355.

Lovett v Wigan Borough Council [2022] EWCA Civ 1631; Birmingham City Council v Lloyd [2023] EWCA Civ 1355

The burden of proof in contempt proceedings is on the claimant to establish the contempt beyond reasonable doubt.

Common law principle in contempt proceedings

In determining the appropriate sentence, the court considers culpability and harm caused, along with aggravating and mitigating circumstances.

Lovett v Wigan Borough Council [2022] EWCA Civ 1631; Birmingham City Council v Lloyd [2023] EWCA Civ 1355

Outcomes

Adshead was found guilty of contempt of court.

Her admission, combined with video evidence, proved beyond reasonable doubt that she breached the injunction by participating in a street cruise and driving dangerously.

Adshead received a suspended sentence of 26 days' imprisonment.

The sentence reflected the seriousness of the offence (culpability category B, harm category 2), mitigating factors (youth, good character, remorse, first offence), and the court's preference for suspension to encourage compliance with the injunction.

Adshead was ordered to pay £2,174.30 in costs to the Claimant, payable in instalments of £250 per month.

The Claimant was the successful party, and the costs were deemed proportionate.

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