Contempt by publication under the Contempt of

Court Act 1981: Is the legislation still valid in the

modern digital age?
Amanda Rose
University of Portsmouth
School of Social, Historical and Literary
Studies
March 2012
Dissertation submitted in part-fulfilment
for the requirements of
the BA (Hons) Journalism and Media Studies
degree

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Abstract
This study was designed to investigate the relationship between contempt by
publication law, under section two of the Contempt of Court Act 1981, and the
internet. As a law that was passed more than three decades ago, this paper
explores whether the existing legislation can remain effective in the age of online
publishing.
Through the discussion of case law, literature and judges rulings, and a content
analysis of a number of relevant cases, this study examines whether contempt by
publication law is still valid with the existence of online media platforms. Online
news archives, social media, web forums and comment boards have been reviewed
and analysed to determine the suitability of existing legislation. The challenges
facing the courts in directing jurors are also discussed to highlight the mounting risk
of prejudice to fair trials.
This study has discovered that due to internet archives, social media and other
forms of instant communication, to some extent contempt by publication law
requires amendment. The level of information readily available online that could be
accessed by jurors and witnesses throughout a criminal case jeopardises the validity
of contempt law. Therefore it is necessary to consider a revision of the legislation to
accommodate for the evolving nature of the internet.

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Acknowledgements
Firstly I would like to say a special thank you to my dissertation tutor, Bernie
Saunders for his support and guidance through the duration of this work. His
encouragement and contribution has made the dissertation process an enjoyable
one.
Secondly I would like to thank my family and Will for their continual love, support
and patience during my time at university. I truly doubt I would have reached this
stage without them.

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Contents

Introduction..1
Chapter One: Literature Review.5
Chapter Two: Case Review..15
Chapter Three: Case Analysis27
Conclusion.37
Appendices41
Reference List..68
Bibliography84

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Introduction

From earliest legal history the courts have assumed power to coerce those who
obstruct the administration of justice (Eady & Smith, 2005, p.1). However, the rise
of the uninhibited culture of the internet has created challenges for the courts, as
using the web to report or comment on legal proceedings is escalating and
becoming increasingly harder to control (Crook, 2010, p.56). Open justice requires
that the media should be able to attend and report upon court proceedings so
justice is seen to be done (Eady & Smith, 2005, p.303). Nonetheless, balancing the
administration of justice and the need for openness in the courts remains an area of
controversy (Smartt, 2006, p.116) within the digital age as, unlike the newspapers
of the past, the internet enables today's news to be available worldwide in seconds
(Colquhoun, 2011, para. 9). The Contempt of Court Act 1981 is the current
legislation that protects the integrity of a fair trial (Grieve, 2012, para. 2) and of
most importance to the media is the notion of strict liability (Quinn & Lamble, 2008,
p.136).
This study aims to explain the development and operation of contempt by
publication law under section two of the Contempt of Court Act 1981, also known
as the strict liability rule. Through discussion of literature and the review and
analysis of a number of recent and pending cases, the key question is whether
contemporary contempt laws can remain effective in the internet age. The impacts
of social media, online newspaper archives, internet forums and user generated

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content on the fair trial process will be examined to determine the suitability of
existing legislation.
Contempt of Court is the law that enables the integrity of justice to be preserved
(Banks & Hanna, 2009, p.273) and this law, in England and Wales, is founded on a
mix of ancient custom and judge made law known as common law (Crone,
Alberstat, Cassels & Overs, 2002, p.1). The emergence of the Contempt of Court Act
1981 began when Lord Hailsham L.C. appointed a committee under the
Chairmanship of Lord Justice Phillimore, in June 1971, to consider whether any
changes were needed in the law relating to contempt of court (Eady & Smith, 2005,
p.27). While the committee was deliberating, contempt at common law case
Attorney General v Times Newspaper Ltd (see appendix one) arose in 1973
(Williams, 1973, p.177). This case illustrated the dangers when covering high profile
civil cases (Smartt, 2006, p.116).
As a result, in 1974 the House of Lords discussed contempt in depth for the first
time and decided that any publication which pre-judged the issues in pending
proceedings was a contempt (Eady & Smith, 2005, p.28). The Phillimore committee
however rejected the notion of pre-judgement and agreed it should be replaced
with a requirement that, to qualify as contempt, a publication would have to create
a risk of serious prejudice to the course of justice (Eady & Smith, 2005, p.28). The
committee then produced a report containing a wide range of recommendations
(Young, 1981, p.243) which contributed towards the design of the Act. Three
recommendations are significant to the media and represent the notion of strict
liability:

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Recommendation six: Proceedings should continue to be capable of being

dealt with as contempt of court, but only if the proceedings in question have
started and have not yet been fully settled or concluded.

Recommendation seven: A publication described in the following
recommendation should be subject to the law of contempt if it creates a risk
of serious prejudice (whether intentionally or not).

Recommendation twelve: Strict liability for publications should cease to
operate when a verdict has been returned and sentence pronounced, or
judgement given.
(Eady & Smith, 2005, p.1354)
The time at which the strict liability rule applied was unclear prior to the Act as the
proceedings had to be pending or imminent (Young, 1981, p.247). However, a
combination of these recommendations and an attempt to bring consistency in the
law of contempt led to the Contempt of Court Act coming into effect in August 1981
(Eady & Smith, 2005, p.37). Banks and Hanna agree that the Act replaced some
aspects of common law contempt to provide greater certainty about what
constitutes a contempt offence (2009, p.274). This legislation remains as the
apparatus of conducting fair trials (Eady & Smith, 2005, p.49) and this study aims to
establish whether contempt by publication, under section two of the Act, can keep
pace with constant online growth (Eady & Smith, 2005, p.49).
The next chapter explains the notion of strict liability in more depth and discusses
the growth of new media. It also refers to contempt cases involving the web to

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highlight the dangers associated with online reporting of criminal trials. This chapter
also looks at the idea of the fade factor and the use of social media in court.
Chapter two reviews and debates evidence from online research into four cases
involving contempt law. The recent cases of Levi Bellfield, Joanne Fraill and
Theodora Dallas are discussed as well as the pending trial of John Terry. Social
networking, online archives, forums, news articles and comment boards are
compared using a content analysis method.
Chapter three analyses the evidence reviewed in chapter two. The consequences of
the cases and issues they raise help to establish whether contemporary legislation
can continue to work effectively alongside the uninhibited nature of the internet. It
also examines the role of the jury and the direction they receive in court.
The conclusion summarises the findings identified throughout this study. The
outcome of this will determine the degree of risk associated with contempt by
publication and the internet, and concludes whether the legislation can still operate
successfully in todays digital environment.

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Chapter One
Literature Review
British contempt by publication law under the Contempt of Court Act 1981 is
currently colliding against boundaries and obstacles due to the seamless nature of
the internet (Foust, 2005, p.216). Within this technological age, contempt law has
been stretched and pulled by the media (Rozenburg, 2011) as the internet, as a
global publishing platform, is one of the biggest sources of news delivery (Gunter,
2003, p.1). However, the growth of new media means many laws are now
unsuitable for modern cyberspace and these issues are in dire need of amendment
(Gunter, 2003, p.120). This chapter discusses contempt by publication law under
the Contempt of Court Act 1981 and also addresses the challenges associated with
the internet, including the archiving of information online, social media and online
tools such as blogs and forums. It will also discuss the impact these online facilities
can have on the fair trial process and whether an amendment in the law is needed
to cater for the internet age.
The law of contempt is based on the broadest of principles, namely
that the courts cannot and will not permit interference with the due
administration of justice. Its application is universal (Carey, Armstrong,
Lamont, Quartermaine, 2010, p.158).
The Contempt of Court Act 1981 is the legislation that establishes parameters to
regulate how far the media can go in commenting on on-going legal proceedings
(Spilsbury, 2000, p.351), and to

preserve the integrity of the legal process,

particularly in criminal trials (Smartt, 2006, p.121). Section two of the Act, contempt
by publication, also known as the strict liability rule (see appendix two), is a

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fundamental area of concern for the media as it states a contempt offence occurs if
material is published which creates a substantial risk of serious prejudice or
impediment to particular legal proceedings which are active, regardless of intent
(Banks & Hanna, 2009, p.274). This rule is the means by which the legal system can
ensure that information likely to prejudice a trial is not circulated and the persons
involved are not on trial by the media (Carey et al, 2010, p.159). Any published
information must not unduly influence jurors or witnesses (Thomas, 2010, p.5). This
rule is described by Lord Hailsham as the most important provision of the Act
(Young, 1981, p.245). The rule also concerns the interference in particular legal
proceedings, not general (Eady & Smith, 2005, p.226).
Substantial risk means that the course of justice is put at risk; publication of
material that could affect the outcome of a trial for example (Spilsbury, 2000,
p.354). It is intended to exclude a risk that is remote or trivial (Eady & Smith, 2005,
p.241). Seriously prejudicial information would consist of reference to any previous
convictions, direct linking of the accused to the crime, suggestions of guilt or
suggestions the accused is dishonest or of bad character (Banks & Hanna, 2009,
p.276). Robertson and Nicol state that published content that produces a preconceived idea of a person or insinuates blame can interfere with the course of
justice (2002, p.349). Nevertheless, the strict liability test can only apply to a
publication when court proceedings are active (Smartt, 2006, p.125) and this
period begins when a person becomes identified with alleged criminal activities
(Young, 1981, p.247). A criminal case is active when a person is either arrested, a
warrant for their arrest has been issued, a summons has been issued or a person

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has been charged orally (Banks & Hanna, 2009, p.276). Only once a verdict or
decision puts an end to proceedings does the strict liability rule cease to apply (Eady
& Smith, 2005, p.278). The rule applies to publications; any act that can be classified
as a communication falls within this bracket (Eady & Smith, 2005, p.232) and must
be addressed to the public at large (Smartt, 2006, p.124). The fade factor is the
belief that the further away media reports are from the trial, the less likely they are
to create a substantial risk of serious prejudice because they are considered to have
faded from jurors memories (Thomas, 2010, p.41).
The Attorney General, Dominic Grieve, the governments senior law officer is the
appropriate officer to safeguard the public interest and he has considerable
discretion as to when it may be appropriate to initiate proceedings for contempt by
publication (Eady & Smith, 2005, p.133). The power to punish for contempt may be
justified by reference to the European Convention of Human Rights. Article six
provides that:
In the determination of his civil rights and obligations or of any criminal
charge against him, everyone is entitled to a fair and public hearing
within a reasonable time by an independent and impartial tribunal
established by law (Roberson & Nicol, 2002, p.346).
The seemingly insatiable appetite for crime news remains as significant today as it
has ever been (Fleming, Hemmingway, Moore & Welford, 2006, p.141) and in
recent years contempt by publication law has struggled to deal with such reporting
through online means of communication. The range of communication methods
such as social media and blogging create a hazardous landscape with regard to
contempt law (Gunter, 2003, p.136). In cyberspace, any individual can now
contribute to news stories and comment on future trials and the inability to control
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access to the web means prejudicial material could reach the eyes of any juror or
witness (Eady & Smith, 2005, p.61). This poses the question of whether contempt
by publication law can continue to work effectively alongside the anonymous and
uninhibited culture of the internet (Crook, 2010, p.56).
The internet creates opportunities for more people to become
publishers of material. This opens up the possibility for widespread
production and dissemination of contemptuous material (Gunter, 2003,
p.131).
It is argued that the internet is impossible to control although it is not a lawless
virtual landscape (Crook, 2010, p.50). The enormity of global publishing has
increased the risk of pre-trial prejudice and contempt of court (Overs, 2002, p.76).
The legislation is in place to prevent publications that might realistically jeopardise a
trial or tilt the balance of its procedures unfairly (Robertson & Nicol, 2002, p.346).
However within this internet age, competition is fierce with regard to news
provision (Gant, 2007, p.6) and this can have dangerous consequences for media
publishers, social networkers and citizen journalists due to the capabilities of the
internet. The web has had a profound effect on the availability of information to the
public (Ludlam, 2002, p.98); they have the power to access, manipulate and share
material instantly (Meikle & Redden, 2011, p.3). For example, established news
providers such as The BBC, The Guardian and Sky News are vast digitised hubs
(McNair, 2011, p.38) that publish material that can be easily accessed online
through archives. Online tools such as social networks, forums, blogs and user
generated content also facilitate instant retrieval of information. Although Dominic
Grieve believes contempt legislation is effective in catering for these online

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mediums (2012, para. 8) he stated that the internet does not provide some form of
immunity from prosecution (Grieve: Press, 2011, para. 12).
Archive news is a function by which online newspapers offer their readers flexibility
in searching for specific stories. Gunter claims that:
The courts concern rests on the risk that such archive material might
serve to prejudice juries if juries could readily look up past information
about defendants on the internet. Search engines ensure that obscure
information is easily accessed on an internet archive, whereas such
material might not be so readily accessed via a standard newspaper
archive (2003, p.137).
Background material may have been written and published legally before
proceedings become active in a case (Quinn, 2011, p.77). This can be seen by the
Scottish case HM Advocate v Beggs (see appendix three). Previous convictions and
background information had been published prior to the trial and remained online
for public scrutiny (Eady & Smith, 2005, p.275). The judge, Lord Osborne, ruled that
reporting of the trial would be restricted until after the verdict (Eady & Smith, 2005,
p.275) as potentially prejudicial material in online archives, when proceedings were
active, was as risky as publication throughout a case (Quinn, 2011, p.78). This notion
was taken no further however but the facts of the case suggest that online archives
pose a problem. In 2008, the Lord Chancellor believed that online archive material
could cause serious prejudice to criminal trials and suggested that in high profile
cases, the information should be removed (Quinn, 2011, p.78). It can be argued that
the existence of available material about accused suspects will impact upon the jury
process (Goldberg, Sutter & Walden, 2009, p.143) and this creates an overwhelming
problem for the current legislation as it attempts to cater for online functions on a
global scale. The fade factor therefore is somewhat undermined by the continuing
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availability of prejudicial information readily accessible on internet archives (Eady &

Smith, 2005, p.61). This shift in information control (Packard, 2010, p.1) suggests
that to some extent the internet is jurisdictionally borderless (Crook, 2010, p.50).
Banks believes a more proactive approach is needed to police access to coverage of
criminal trials (2012, para. 7).
Another example to illustrate the danger of material published online is a case
involving The Sun and The Daily Mail in March 2011. Both national newspapers
were found guilty of contempt by publication, by publishing a murder trial
defendant holding a gun on their websites while proceedings were active. This was
a landmark ruling for internet publishing (Halliday, 2011, para. 2) as it is believed
to be the first case involving breach of the strict liability rule by website publications
(Sun and Daily, 2011, para. 3). Lord Justice Moses said that the image of the accused
brandishing a pistol could not have failed to create an impression of a violent man
(Sun and Daily, 2011, para. 7). Although the photograph was on both sites for a
matter of hours before being ordered to remove it, the case had received
considerable publicity (Papers in, 2011, para. 9) and the photograph created a risk
of serious prejudice as reference to a criminal background could sway a jury (Eady
& Smith, 2005. P.249). Although an enquiry established no jurors had seen the
pictures, the risk was there said Dominic Grieve (Rozenburg, 2011). This shows
the level of interference online publishing can have on a fair trial and also reflects
the passing nature of the internet. Furthermore, once contemptuous material is
online it is difficult if not impossible to completely remove it (Halliday, 2011, para.
9).

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The new media landscape continues to present the law with new challenges and,
like most other countries in the world, UK law has not kept pace with technological
advances (Crone, Alberstat, Cassels, & Overs, 2002, p.1). This can be recognised
with the increasing use of social networking sites which, according to Sparrow are
virtual spaces for social thinking, instant communication and global interactivity
(2010, p.100). Social networking sites such as Facebook, Twitter and YouTube have
transformed self-communication into a mainstream phenomenon (Meikle &
Redden, 2011, p.9) and therefore have enabled news and other types of
information to circulate faster and more freely, to more people in more places, than
ever before (McNair, 2011, p.39).
The press are breaking new ground (Lambourne, 2011, para. 1) with this new
media. The Lord Chief Justice recently announced that Twitter can be used inside
the court room to report on legal proceedings, without permission (see appendix
four). This came after a lack of consistency in judges rulings as to whether Twitter
was allowed to be used in courts (Linford, 2011, para. 1). It has been argued that
using Twitter during on-going trials provides followers with a raw report of the
events (Morris, 2011, para. 2: Lambourne, 2011, para. 5). The Lord Chief Justice also
commented that it is generally unlikely to interfere with the proper administration
of justice (Carry on, 2011, para. 21) although persistent misuse could damage the
fair trial process (Twitter use, 2010, para. 2).
Furthermore, there is a fundamental difficulty in controlling Twitter (Rozenburg,
2011, para. 9); the responsibility of reporting on Twitter lies with the journalist
alone with no second pair of eyes (Morris, 2011, para. 10). During Harry Redknapps

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tax evasion trial this year, a journalist for The Guardian named a juror on Twitter
and reported evidence from a witness in the absence of the jury (Pugh, 2012, para.
1 & 2). A journalist was also arrested during the Joanna Yeates murder trial, for
posting prejudicial information on Twitter and Facebook despite the judge banning
the reporting of it until after the verdict (Bould, 2011, para. 4). These examples
highlight the dangers that come with using social media to report on criminal trials.
A witness could be informed of what is already happening in court, or legal
discussions in the absence of the jury may appear online (Pugh, 2011, para. 8).
Additionally Twitter users may respond to posts by posting or linking to prejudicial
material (Rozenburg, 2011, para. 10). Furthermore, although Grieve warned Twitter
users they were not exempt from the law (Attorney Generals, 2011, para. 4),
instant reporting without self-restraint is more likely to produce prejudicial
reporting (Rozenburg, 2011, para. 14). These cases reflect the risks of using Twitter
to report from court and how easy it could be to prejudice a trial. This perhaps
illustrates the need for a revision of contempt by publication law in order to cope
with the unrestrained nature of social media. Bowcott argues:
Judges have acknowledged their frustration at being unable to prevent
contempt of court being inflicted by the plethora of modern
communication devices and networks. Preventing juries consulting the
internet about the cases they consider is becoming more problematic
(2011, para. 9).
Moreover, there has been an explosive growth in blogging and user generated
content over the past decade. Blogging is a source of news and opinion with
hundreds of thousands of daily viewers (Gant, 2007, p.24) which enables a more
personal form of publishing, including personalised commentaries on current affairs
where your subjective view is on display (Meikle & Redden, 2011, p.9). This is
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another format of publishing that could carry prejudicial information whereby

comments and re-publications could potentially harm a trial. It can be argued that
the growing influence of legal bloggers will bring them onto the radar of potential
jurors and witnesses; the more influential a commentator, the more likely they are
to influence a jury and therefore prejudice a fair trial (Wagner, 2011, para. 20).
Dominic Grieve says that bloggers are not immune from the law (Gardener, 2011,
para. 7) but the risk is heightened by blogs instantaneous nature (Wagner, 2011,
para. 23). Additionally once material is out there in cyberspace, it is difficult to
know who will read it (Gunter, 2003, p.134). This suggests that the law governing
publication contempt is in an unsatisfactory state (Eady & Smith, 2005, p.54) to
deal with modern means of communication.
Quinn and Lamble describe the law as a ponderous machine that tends to move
slowly and cautiously while developments in internet technology and web browsers
are quick and capricious; a relationship that lawyers, courts and journalists are
struggling to come to terms with (2008, p.127). The justice secretary, Ken Clarke
stated that ideally we have no plans to legislate-we rely mainly on the responsible
behaviour of the press (Plunkett, 2011, para. 5 & 6). However it is not only
accredited journalists who have access to information during a trial; the public are
able to receive comment on on-going proceedings through social media, blogging
and archives. Furthermore, Banks believes:
Jurors go home every day now, even during deliberations, where the
resources of the internet await. Grieve is ignoring the overwhelming,
global power of Google and the way in which it delivers information
straight to the reader's eye (2011, para. 14).

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Therefore, it can be argued that perhaps contempt by publication law, which has
survived reform for three decades, is no longer appropriate for the internets
capabilities. The fact is that, while the internet and web is a treasure trove for
journalists, they are also a legal minefield (Quinn & Lamble, 2008, p.127). Lately,
debates and concerns have sparked over the current legislation suggesting that the
law lacks clarity (Hanson, 2011, para. 19) and contempt laws need to be reviewed
(Attorney General warns, 2011, para. 26). In a recent article Dominic Grieve said the
media had lost sense of constraint over contempt (Grieve: Press, 2011) and
perhaps the global shift to digital media and instant communication (Packard, 2010,
p.1) requires the revision of existing contempt legislation.
The following chapter will review and discuss in detail four cases that relate to
contempt law and the internet. The case of Levi Bellfield is looked at to exemplify
the extensive media coverage of a suspect that can be archived online during
criminal trials. The pending trial of John Terry is examined to establish how social
media and internet forums can create a risk of prejudice to a future trial by
members of the public. The cases of Theodora Dallas and Joanne Fraill are also
reviewed in order to understand the role of the jury and the impacts of jurors
conducting online research into the cases they are trying. Chapter two will use a
content analysis approach, described as the study of communication through
symbols whether verbal, textual or images that relay meaning (Riffe, Lacy & Fico,
2005, p.28), in order to help interpret any risk of prejudice involved with these
cases. This will also help to identify whether contempt legislation is still valid in the
internet age.

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Chapter Two
Case Review
The reporting of criminal trials needs to strike a balance between the competing
interests of freedom of the press and the administration of justice and right to a fair
trial (Thomas, 2010, p.5). Recently however, this balance has been challenged by
online methods of communication (Elliott, 2011, para. 1). Some cases reach an
atmosphere of online hysteria that can impede the course of justice (Christian,
2008, p.191). This chapter aims to review four recent cases that demonstrate the
problematic nature of the internet when reporting criminal trials. It highlights the
potential dangers of online archives, social media, citizen journalism and the
difficulties in controlling the conduct of members of the jury, with regard to
contempt laws. Firstly, the online archived material on Levi Bellfield, from two
publications, are discussed to determine the risks of online reporting and access to
information on the fair trial process. Secondly, the on-going case of John Terry is
discussed to represent the potential impact of social networking sites and
discussion groups on future trials. Lastly, the cases of Joanne Fraill and Theodora
Dallas are examined. These two cases highlight the importance of directing and
warning juries with regard to the internet. Online archived articles, postings from
internet forums and news sites and social media sources are the main subjects of
review. All these cases are examples of the challenges faced by the growth of online
media and have questioned the validity of contempt by publication legislation.
Too many decades of hunting terrorists and serial killers- and asking the
public for help in tracking them down- has widened involvement and
pushed back the boundaries of what can be said. If this or that detail is
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publicised, will it render a fair trial impossible? It is becoming an

impossible line to draw (Preston, 2011, para.3 & para. 5).
Levi Bellfield was convicted in February 2008 for murdering two women, Marsha
McDonnell and Amelie Delagrange and the attempted murder of Kate Sheedy. He
was sentenced to life imprisonment for these crimes. The case received national
press coverage and, following his conviction, Bellfield was linked to a number of
crimes including the unresolved murder of thirteen year old Milly Dowler, whose
body was found in September 2002. In March 2010 Bellfield was charged with the
abduction and murder of Milly Dowler, in June 2011 was found guilty, and again
sentenced to life imprisonment. Proceedings were active between these dates.
Although the suspect was already detained, Bellfields trial had to remain fair and
unprejudiced. Internet archives belonging to national and local newspaper websites
contained many reports involving the suspects previous convictions, his character
and links to other crimes, following his sentencing in 2008. References to a criminal
background including past convictions are seriously prejudicial (Eady & Smith, 2005,
p.249). This material was readily available to jurors and witnesses, who are to
remain uninfluenced throughout a trial, while proceedings are active. Articles from
The Guardian and The Suns website archives are now examined to illustrate the
potentially contemptuous material that was easily accessible during the trial.
The Guardians online archive contains fifty-two articles involving Levi Bellfield, four
of which are discussed (see appendix five). The majority of articles containing
prejudicial material were published following his conviction in 2008. An article
entitled He treated women like dogs (McVeigh, 2008) reported on his previous
conviction and described his character. Bellfield is said to have hated blondes and

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would hang around alleyways wanting to hurt women, stab them or rape them
(para. 1). With reference to victim Amelie Delagrange the article says Bellfield killed
her in a rage (para. 7). Another article entitled Bellfield cruised streets before
striking with blitz hammer attacks (McVeigh, 2008) named the suspect as a
predatory killer (para. 4), an animal who kept a stash of weapons, including
hammers and knuckledusters (para. 14). It also states that Bellfield made lewd
sexual comments to two school girls, aged 14 and 16 (para. 15). During the Milly
Dowler murder trial these comments could seriously prejudice jurors or witnesses
as there are links to previous crimes, violence and inappropriate behaviour towards
minors. Following Bellfields conviction in 2008, all The Guardians published articles
contained details of the verdict; for example Bellfield, 39 convicted of killing two
women and viciously attacking a third (McVeigh, 2008, para. 2). To have Bellfields
previous convictions so easily accessible online to anyone seeking information could
have serious implications for the integrity of a fair trial. Furthermore, The
Guardians website also reported that he was arrested and interviewed over Millys
death three years ago in 2004 (Batty, 2008, para. 7). This comment linked the
suspect to the crime a number of years before he was charged. This could
potentially influence a jurors decision.
The Suns internet archive contains one hundred and twenty two articles published
about Levi Bellfield, between 2006 and the present day. Three of these articles are
discussed (see appendix six). Reports link the suspect to a number of unresolved
crimes, as well as commenting on his character and behaviour. Bellfield is described
in one article entitled How many vics of evil Levi? (Sullivan, 2008) as a monster

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(para. 5) and the word evil could not be more appropriate (para. 1). Within the
article there is a link to a slideshow of pictures of Bellfield (para. 9) that could be
seen as prejudicial. Each picture gives negative impressions of the suspect. Captions
to these images include the words evil, barbarian, twisted, monster and
callous. The article also publishes that Bellfield is the prime suspect in 100 crimes,
many involving violent and sexual offences against women (para. 14). This material,
discussing Bellfields negative character and behaviour could have influenced the
trial if read by those who should remain unprejudiced.
Furthermore, another article entitled Killer was Jekyll and Hyde (2008) contains
seriously damaging information that could have affected Bellfields trial.
Considering Milly Dowlers age at the time she was murdered, the article reports
that the sinister 20 stone killer (para. 15) had a sexual and violent history (para. 2)
and an ex-girlfriend said he showed an unhealthy interest in one of her 13 year old
relatives (para. 12). It goes on to report that Bellfield kept a gun (para. 30), he
slashed out the faces of blonde models in magazines (para. 17) and had a
relationship with a 15 year old girl (para. 25). Bellfield was also reported to be the
prime suspect in the unsolved murder of 14 year old Patsy Morris (Peake, 2008,
para. 3). Throughout the Milly Dowler murder trial, these reports about Bellfield
were archived online with the potential for jurors or witnesses to access and this
could have seriously interfered with his right to a fair trial.
It is impossible to know for sure the level of prior knowledge individual jury
members had on Levi Bellfield and what they were told during the trial. However, a
jury is required to try the case solely on the evidence presented in court (Banks &

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Hanna, 2009, p.84) and if a jury member was to perform online research into a
defendant, the archived material on Bellfield could create serious prejudice that
may cloud a jurors judgement. Material of this nature could also deter witnesses
from coming forward or affect a witnesss evidence by what they have seen or read
(Eady & Smith, 2005, p.265). Although jurors are directed by judges not to use the
internet while trying a suspect, there is evidence that some disobey this rule.
Although Bellfield was found guilty of Milly Dowlers murder, another count of the
attempted abduction of Rachel Cowles was aborted due to the publishing of hugely
prejudicial material by the press (see appendix seven) (Hough, 2011, para 6). This
case highlights the impact of pre-trial publicity and addresses the issue of contempt
by publication by media organisations. However, there was no evidence to suggest
concern over the amount of prejudicial material already online, in newspaper
archives. This case demonstrates one of the key problems with contemporary
contempt law, as there is little or no attempt to regulate the internet and online
archives. This issue will be examined further in the following chapter.
The pending trial of John Terry is an interesting case that demonstrates the
potential impact of the internet on contempt by publication laws. During a Premier
League football match between Chelsea and Queen Park Rangers on 23rd October
2011, footballer John Terry is alleged to have shouted a racist remark at opposing
defender Anton Ferdinand. After an investigation, Terry was charged with a racially
aggravated public order offence on 1st February 2012 and subsequently stripped of
his England captaincy by the Football Association. As a summary offence under the
Crime and Disorder Act, it will be fully heard in a magistrates' court on 9th July

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2012. This means his case will be heard by a district judge and not a jury, which will
arguably reduce the risk of prejudice from online coverage, as district judges are
regarded as harder to sway than a jury (Banks, 2012, para. 2). However witnesses
are still at risk of being prejudiced. Proceedings are active between these dates and
it is important to analyse any information that is published online that could affect
his right to a fair trial. Following Terrys charge Alison Saunders, Chief Crown
prosecutor for London said:
He is now summoned with a criminal offence and has the right to a fair
trial. It is extremely important that nothing should be reported which
could prejudice his trial (John Terry, 2011, para. 8).
As the former captain of the national football team, many people will already have
preconceived ideas of the suspect, and the internet is a platform to voice these
views.
An article published on The Suns website entitled Cop probe into John Terry race
row (OShea, 2011) carried twenty-seven posts from the public that insinuate guilt
and judge his character, comments that could potentially affect a future trial.
Although the article and posts were published when proceedings were inactive, the
material is still online and easily accessible now that proceedings are active.
Negative comments supporting the story include I would love to see Terry jailed
(tiseye, 2011), he has no attributes as a player or as a person (mufcoo7, 2011) and
anyone else actually see the video evidence? Its blatant (saf_legend, 2011).
Positive posts include I dont think for a minute hes a racist (Gordyboy, 2011) and
opinions of effective punishment such as a fine and a caution should be sufficient
(tintinsdog, 2011), JT should be banned for life (mufcoo7, 2011) and even a fine

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would be quite harsh (mikey-bizzle, 2011). Most comments suggest Terry is guilty
of the alleged crime. Another article entitled Anton Ferdinand: John Terry is wrong
(Jiggins, 2011) carries forty-seven posts debating Terrys guilt and character.
Comments continue to suggest methods of punishment such as JT is guilty, ban him
for life (johnd1234, 2011) and time to teach him a lesson and set a mark for zero
tolerance for this sort of behaviour (manutdreddevils, 2011). Others describe Terry
as a thug (pedster, 2011) and a clown with no brain, class or morals (panksinator,
2011).
The forum footballforumuk.com also demonstrates how the public can contribute
their views about a case. Within the thread John Terry charged over alleged racist
Ferdinand comments, posts include John Terry is going down (GeniusGerrard,
2011) and hopefully this will see the end of Terry as captain. The man is a cretin
and deserves everything that comes his way (Wolsta, 2011). Another post said that
the FAs decision to strip Terrys captaincy implies Terry is guilty (J Mo, 2012) and
in response another said what happened to innocent till proven guilty? (Elmo,
2012).
On 3rd February 2012 while proceedings were active a possible contempt issue was
raised. Joey Barton, a teammate of Anton Ferdinand uploaded a series of comments
on the social networking site Twitter, with regard to John Terry and the racial
allegation made against him. The most prejudicial comments directly link Terry to
the alleged crime and suggest he is guilty. Quotes include we all know what he
said, racism needs to be stamped out, not having the b**locks to take
responsibility for your actions? Id rather be a man and go to jail and Id rather be

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executed in public for my mistakes than hide from justice (Joey Barton, 2012). The
comment that links them with John Terry is The one I feel for is Anton (Joey
Barton, 2012). Barton then goes on to describe Terry as a coward who should of
thrown his hands up and admitted his grave error (Joey Barton, 2012). These
remarks suggest Terry is guilty of making a racial remark. As Terry awaits trial these
comments could reach those in the trial process who should remain impartial.
Additionally, Joey Barton has a total of 1,220,200 followers on Twitter; therefore
arguably the risk of prejudice is substantial. Bartons response to concerns over
contempt was what about the media coverage up to this point? Is that considered
contempt of court? Countless replays etc, etc? (Joey Barton, 2012). Since the
alleged remark television news has played the footage of Terry with his mouth
pixelated. However, the footage online is not. The video footage of the alleged
racist comment was uploaded to YouTube shortly after the game. The original
footage has since been viewed 181,698 times. This excludes the footage that has
been reposted and edited by YouTube users. The footage also remains on The
Guardians website with no pixilation. This creates a substantial risk of serious
prejudice as the video footage is available to millions of viewers both by social
media and a newspaper website. There seems to be no attempt to reduce the risk
of prejudice online compared to broadcast media. It could be argued that online
methods of instant communication can create hype around a case that encourages
members of the public, and in this case, public figures to flirt with potential
prejudice. However with regard to Joey Bartons comments, Dominic Grieve said he
was satisfied the trial would not be compromised and he did not consider Mr

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Bartons tweets had created a risk of prejudice in Mr Terrys trial (Joey Barton,
2012, para. 3 & 7). This suggests that the Attorney General does not believe
Bartons comments have caused a serious impediment to the case by influencing a
witness (Banks, 2012, para. 2). The concerns over social networking will be
discussed further in the following chapter.
Another issue with regard to contempt by publication is the direction of juries and
the problems with controlling their use of the internet. The cases of Joanna Fraill
and Theodora Dallas are examples of how jurors use of the web can interfere with
the course of justice. Firstly, whilst as a member of the jury in a drugs trial in August
2010, Joanna Frail contacted a defendant Jamie Sewart over Facebook and did
internet research on the co-defendant Gary Knox while the jury were still
deliberating. Sewarts solicitor informed the court that his client and Fraill had been
in touch through Facebook and although Sewart had already been acquitted, other
defendants were still on trial. As a result the judge decided to discharge the jury and
the trial collapsed (Juror admits, 2011, para. 3). Within the conversation the two
women discuss the case, the sentencing of the remaining defendant and on-going
jury deliberations. From a transcript published on The Guardians website Facebook
contempt of court case: transcript of the online chat (2011) (see appendix eight)
some comments by Fraill include cant get anyone to go either, no one budging,
please dont say anything cause Jamie they could call miss trial (para. 19) I know
[defendant] from somewhere (para. 4), I was crying cos they held onto yours
because one couldnt make her mind up (para. 54) dont worry about that charge
(para. 28) and all that note taking was just killing time (para. 34). Sewart responds

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with I have deleted all the messages, I wouldnt do that to you dont worry (para.
20) and asks whats happening with the other charge? (para. 14). Fraill also
researched defendant Gary Knox online despite the judges warning of no internet
use. The case was brought by Dominic Grieve and, in the first case of its kind in the
UK involving the internet (Juror admits, 2011, para. 1), Fraill was found guilty of
contempt of court and jailed for eight months. The high court was told that contact
and discussion were in direct breach of the judges repeated directions to the jury
(Juror admits, 2011, para.28). Lord Judge who heard the case, ruled that:
Her conduct in visiting the internet repeatedly was directly contrary to
her oath as a juror, and her contact with the acquitted defendant, as
well as her repeated searches on the internet, constituted flagrant
breaches of the orders made by the judge for the proper conduct of the
trial (Juror admits, 2011, para. 9).
This case is significant in establishing the effect internet use by jurors can have on a
criminal trial. Although arguably in this case, the present contempt laws worked as
Joanne Fraill was convicted, it forced a re-trial and raised issues regarding the ability
of current legislation to deal with the internet.
The case of Theodora Dallas also reflects the challenges facing contempt by
publication law. During a trial at Luton Crown Court in July 2011 for a grievous
bodily harm offence, jury member Dr Theodora Dallas carried out internet research
on defendant Barry Medlock while jurors were deliberating their verdict (Bedford
uni, 2012, para. 4). The trial judge had warned the jury to base their decisions on
the evidence presented and to not use the internet (Bedford uni, 2012, para. 12).
Subsequently Dallas revealed to the other jury members that the defendant had
previously been accused and acquitted of rape (Juror Theodora, 2012, para. 27),

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information that would breach the strict liability rule if published while proceedings
were active (Robertson & Nicol, 2002, p.351). However, in this case it was published
following a previous trial while proceedings were inactive. Nonetheless it was
readily available within an online archive during the trial. As a result, the jury knew
of the defendants previous acquittal and the risk of prejudice was substantial. The
trial was therefore aborted. The defendant was later re-tried, convicted and jailed
(Bedford uni, 2012, para. 14). However, contempt proceedings were launched by
the Attorney General (Bowcott, 2012, para. 6) and three High Court judges
sentenced Theodora Dallas to six months in prison (Juror Theodora, 2012, para. 4).
This case demonstrates the ease with which information can be found in online
archives. Online publications retain articles and images that are easily accessed by
search engines. For example, Doctor Dallas checked the meaning of grievous bodily
harm on the internet and added the word Luton and this brought to light the rape
accusation from a local newspapers website (Bedford uni, 2012, para. 16). By
telling the jurors of what she had learned online, Lord Judge said that she did not
merely risk prejudice to the due administration of justice, but she caused prejudice
to it (Juror Theodora, 2012, para. 22). Furthermore, Dominic Grieve stated that:
Ms Dallas halted a trial which was near completion and aside from the
financial implications, her actions resulted in the victim in the case being
forced to return to court and give evidence for a second time (Bowcott,
2012, para. 17).
Although jurors are responsible for following judges directions, to some extent
these cases reflect the growing problem courts face in ensuring internet research is
not conducted, due to social media and archives. It seems to be becoming an
increasingly natural instinct (Bowcott, 2012, para. 3). The Lord Chief Justice agrees
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that the integrity of the jury system is under challenge from temptations to trawl
the internet for information (Bowcott, 2011, para. 1).
The cases discussed exemplify the challenges facing contempt by publication law in
the internet age. It is evident that archived material online can pose a significant
problem in attempting to conduct a fair trial. The availability of social networks,
blogs and forums allow members of the public and public figures to post and repost
potentially contemptuous material that could interfere with on-going deliberations.
It is also apparent that the role of the jury is to some extent jeopardised by the
power of the internet and the revolution in methods of communication (Attorney
General, 2011, para. 68). The next chapter analyses the consequences of these
cases and discusses the concerns surrounding the validity of contempt legislation,
with reference to archived material, social media and user-generated content.

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Chapter Three
Case Analysis
The cases discussed in chapter two demonstrate the growth of modern
communication and the availability of information online, and reflect the difficulties
faced by the courts in trying to ensure a fair trial. The law of contempt continues to
be a burning issue of media law which needs scrutiny (Hanson, 2011, para. 21) and
this chapter analyses the evidence presented in chapter two, to determine the
strength and legitimacy of contempt by publication law within the internet age.
Online archives, social media, user-generated content and the conduct of jurors are
relevant topics that are examined throughout this chapter.
The Contempt of Court Act 1981 is part of the apparatus that protects
this right, by writing what can be published about a case while it is live,
so that allegations that are not relevant or not tested in court do not
form part of a jurors consideration (Grieve, 2012, para. 12).
However, this legislation is arguably challenged by the publication of allegations
that are not relevant in court, outside the active period. Internet archives provide
the risk of ceaseless contempt (Crook, 2010, p.52) as prior information about a
defendant or trial could be held in online newspaper databases from the date of
publication. Throughout the Milly Dowler murder trial for example, hundreds of
articles containing prejudicial material about Levi Bellfield were easily accessible in
online archives. Described as a predatory killer (McVeigh, 2008, para. 4) with
references to his sexual and violent past, explicit accounts of past crimes and
previous convictions, the risk of prejudice would have been considerable if a juror
came across this information, as material about a suspects bad character is highly

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prejudicial (Young, 1981, p.248). Although jurors are directed by the courts to avoid
internet use in high profile cases, almost three quarters of all jurors will be aware
of some media coverage of their case (Thomas, 2010, p.44). In addition, the risks of
prejudicing a fair trial lie in the use of search engines that ensure obscure
information can be easily accessed on an internet archive (Gunter, 2003, p.137).
Nevertheless, Levi Bellfield was found guilty of murdering Milly Dowler without
contempt proceedings being launched; but if a juror was to research online the risk
was there. Cheryl Thomas said, in the study Are Juries Fair? that more jurors are
likely to come across media coverage of a trial on the internet rather than
deliberately go looking for it (2010, p.43). This suggests that the sheer number of
prior reports in online archives could create a serious interference with the
administration of justice if they were accessed by jurors. It could be argued that the
fade factor, the length of time between media reports and the trial (Thomas, 2010,
p.41), should be considered in cases such as Levi Bellfield. However, it has become
more difficult to dismiss the effect of prejudicial material after the lapse of time
following the original publication, due to online archives (Eady & Smith, 2005,
p.275). This exemplifies the effect of archived material on contempt by publication
law.
Dominic Grieve however believes that contempt laws work perfectly well as they
currently are (Joey Barton, 2012, para. 4). The Court of Appeal also said that:
It would be ludicrous if heinous crimes could not be tried because of
the extensive publicity they inevitably engendered: all that is required is
that the trial judge takes particular care to warn the jury to try the case
only on the evidence (Robertson & Nicol, 2002, p.347).

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Although it is argued that judges must put greater emphasis on directions to the
jury (Rozenburg, 2011, para. 16) the nature of the internet needs to be
acknowledged because if the law does not apply equally to all then it is in danger of
falling into disrepute (Banks, 2011, para. 18). To archive material online provides a
risk of prejudicing a fair trial. Although Levi Bellfields case was uninfluenced, the
concept of harbouring information online that jurors could potentially access,
questions the ability of current legislation to deal with the power of the internet.
Social media connects with the lives of people unknown to us but to whom we are
superficially exposed (McCartney, 2011, para. 5) and this creates difficulties with
regard to maintaining the integrity of criminal trials. What is published online has
the ability to go viral within hours (Grieve, 2012, para. 4) and many users of social
media are unaware of the responsibility they hold when publishing prejudicial
viewpoints (Hyde, 2012, para. 7). The comments made by Joey Barton on Twitter
referring to John Terry, for example caused Dominic Grieve to review potential
contempt in the first case of its kind. Although Barton strayed into dangerous
territory (Hyde, 2012, para. 3) Grieve decided the comments were mere
unpleasantness (Joey Barton tweet, 2012, para. 13) and were not at risk of
prejudicing Terrys trial. This may be because the trial will be heard by a district
judge instead of a jury. Due to their legal and professional experiences, judges are
unlikely to be influenced by prejudicial matter (Eady & Smith, 2005, p.260). If a jury
was to try Terrys case, perhaps there would be a different outcome. Nevertheless,
Bartons tweets showed he had no knowledge of contempt law (Banks, 2012, para.
4) and this demonstrates that the risk could easily be repeated. Contempt by

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publication law was designed with newspapers and broadcasters in mind and in this
modern era of social media websites are merely forums for the editorial of their
members (Branch, 2012, para. 7). Banks believes this latest example should sound
alarm bells at the Ministry of Justice because the Attorney General faces serious
challenges to cater for this online platform as it is only a matter of time before a
crown court trial will collapse due to an ill-informed social networker (2012, para.
3). Twitter is a network that has millions of online contributors and any further
misuse could seriously challenge the validity of contempt law. Dominic Grieve
stated that:
The inhabitants of the internet often feel themselves to be
unconstrained by the laws of the land. There is a certain belief that so
long as something is published in cyberspace there is no need to respect
the laws of contempt or libel. This is mistaken (Grieve, 2012, para. 5).
Therefore, arguably something more needs to be done to exercise control of the
internet and the fair trial process. Although the Contempt of Court Act 1981 was
designed to balance the right of freedom of expression and the right of an individual
to receive a fair trial (Bartons tweets, 2012) one mistake or bad comment on
Twitter with possibly millions of followers could jeopardise an entire trial (Branch,
2012, para. 5). Yet, Grieve believes that contempt law is a sound piece of legislation
for the modern age (2012, para. 8) despite the evident challenges. Banks believes
that despite recent prosecutions of newspapers, a more proactive approach is
needed; the Ministry of Justice cannot police Twitter and other social media, but
what it can do is make the public more aware of the right to a fair trial and how that
can be put in jeopardy (2012, para. 7). This suggests that contempt law is still valid
in relation to social media but increased awareness is required. Additionally, the

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issue of contempt by publication on the internet is to be reviewed by the Law

Commission in 2014. However, with a report date of 2016, it is thought that any
proposals will come too late to prevent a perversion of justice coming sooner
(Branch, 2012, para. 9). Although it is argued that there was no risk of prejudice
from Joey Bartons tweets, it is an example of the internets instantaneous nature.
The freedom of media platforms to comment on pending or on-going trials could
easily carry prejudicial information to huge audiences. This may well prompt the
Ministry of Justice into a swift review of the law (Branch, 2012, para. 5).
We have seen in recent years not only the rise of social media but the blog and the
citizen journalist (Grieve, 2011, para. 82). This is reflected in the example of the
pending John Terry trial, whereby news sites and discussion forums carry comments
by the public. Although John Terry is a public figure and will inevitably have critics,
he is entitled to a fair trial. The comments left following the articles from The Sun
and on the sports forum insinuate blame and suggest various methods of
punishment. These comments have the potential to sway a jurors judgement;
however the case will be heard by a district judge who is unlikely to be influenced
by media reports (Eady & Smith, 2005, p.77). Nevertheless, this example highlights
the difficulty in controlling these online communities (Online growth, 2008, para.
6) and the means by which internet users can cause potential prejudice.
The lines distinguishing professional journalists from other people who
disseminate information, ideas and opinions to a wide audience have
been blurred, perhaps beyond recognition (Gant, 2007, p.3)
The capabilities of web communication are a significant factor in the rise of user
generated content. Forums, discussion groups, news sites, blogs and social media

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mean that anyone can profess to be a journalist (Rozenburg, 2011, para. 12), but
most have limited knowledge of the legal implications comments on these
platforms can have (Hyde, 2012, para. 7). Most media organisations websites have
the facility to allow user generated content in response to news and comment
pieces (The law, 2008, para. 18) and in some cases these are regulated. Media
organisations such as The BBC and The Guardian monitor message boards and
comments from the public and regularly disarm the facility for legal reasons. Screen
names are also used by contributors to hide their identities and this makes the
process harder to monitor. It is necessary to understand that freedom of
expression is not absolute (Smartt, 2006, p.116) and the internet does not provide
a form of immunity from prosecution (Grieve: Press, 2011, para. 12). A recent case
reflects the severity of allowing contributions from online users. The Lancashire
Evening Post was forced to suspend comments on their website due to malicious
posts by online readers (Bould, 2011, para. 2). The newspaper was forced to take
legal steps with one user and reminded other users that we are all bound by the
same laws of libel, decency and prejudice online as in print (Bould, 2011, para. 5 &
6). This demonstrates that the opportunity to contribute to online message boards
can pose risks to the fair trial process.
McCartney believes that too many of us have forgotten when to stop
communicating and this is why legal risks are frequently occurring through online
avenues (2011, para. 8). In 2010 a network of regional newspaper sites attempted
to reduce these risks by introducing pre-registration for user comments. This allows
users to comment on articles, only with a registered account and verified email

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address (New comments, 2010, para. 6). The Leicester Mercury editor Keith Perch
explained: We hope that forcing people to register will discourage them from
posting negative material (New comments, 2010, para. 9). The system also enables
users to request the removal of comments via a report abuse button that alerts
the websites operators (New comments, 2010, para. 7). This shows an attempt to
control online publishing by users and demonstrates the complex problem in
regulating online communities.
It remains to be seen whether Terrys trial will be at risk of any serious prejudice,
but with regard to user generated content there ought to be more rigorous
enforcement of contempt law as it is vital to avoid a situation where people are
unjustly convicted, due to online influences (Christian, 2008, p.191). This therefore
suggests that material published on forums and comment boards should be
monitored with more authority, as some jurors ignore judges directions to not use
the internet and this could affect a fair trial (Rozenburg, 2011, para. 10). Perhaps
then a revision of the law to cope with the growth of user generated content is
required.
It is also apparent that courts are increasingly battling the problem of jurors
conducting online research (Bailin, 2011, para. 2). With reference to the Joanne
Fraill and Theodora Dallas cases it seems todays twenty four hour internet news on
demand has presented new challenges to the jury system (Thomas, 2010, p.6).
Following Joanne Fraills conviction for contempt of court, which Lord Chief Justice
described as a most serious irregularity by a juror (Deans, 2011, para. 15),
concerns were raised over whether the integrity of a criminal trial can remain intact

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within the internet age. It is contempt for a juror knowingly to hold improper
communications with any party to the proceedings (Eady & Smith, 2005, p.752).
Also, if Fraill was taking notes to kill time she cannot have been concentrating on
the evidence in court (Rozenburg, 2011, para. 7). Lord Chief Justice said that just
because it is easy to contact people online, it is unacceptable to do so where it
interferes with justice (Casciani, 2011, para. 5), and if this case fails to stop jurors
communicating and researching online it may be time to look again at our strict
contempt of court laws (Coleman, 2011, para. 5). However, the court that dealt
with this case stressed that the problem was the activities of jurors, not the internet
(Bailin, 2011, para. 4).
This may be right to an extent; however the case of Theodora Dallas demonstrates
how easy it is to access information from online archives. Although Dallas said she
had no intention of influencing the jury, the information she gathered was seriously
prejudicial to the trial and could have swayed the minds of fellow jurors (Eady &
Smith, 2005, p.752). Jurors ability to understand legal directions is a crucial
element in the proper functioning of the jury decision making process (Thomas,
2010, p.3) and two out of three jurors do not fully understand these directions
(Bowcott, 2012, para. 19). However the other jurors who were told the prejudicial
information reported Dallas. One jury member said I think it was wrong what she
said as it could cloud peoples judgement (Rozenburg, 2012, para. 4). Lord Chief
Justice also commented:
The other jurors were obviously concerned to ensure that their
responsibilities as jurors were properly discharged. It also demonstrates
that they had fully understood the prohibition against use of internet
(Bowcott, 2012, para. 10: Rozenburg, 2012, para. 7).
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Dominic Grieve believes that of course a jury can be trusted not to research a case
on the internet as directed (Bailin, 2011, para. 11). This suggests that a risk of
contempt is minimal among most jurors. Nevertheless, both jurors prejudiced their
respective criminal trials and raised concerns about the strength of contempt law
against the methods of researching information online. Perhaps the judiciary
should consider giving a revised direction on media coverage and internet use
(Thomas, 2010, p.50) as a way of reducing the risk of contempt. Sequestering jurors
is expensive and inconvenient (Banks, 2011, para. 19) and Lord MacDonald QC, the
former director of public prosecutions said that policing the access to information
on the internet is an unmanageable task (Bailin, 2011, para. 10). It is a serious
challenge for the courts in the face of modern communications and it can be argued
that judges need to put greater emphasis on directing jurors against internet use
(Rozenburg, 2011, para. 16), otherwise, the sanctity of the jury room cannot be
maintained (Coleman, 2011, para. 6). Information on the web can soon reach far
beyond its initial limited audience (Grieve, 2011, para. 83) and although jurors
themselves have a responsibility to conduct proceedings fairly, these cases highlight
the power of the internet to influence jurors. Perhaps jury trial is no longer suited
to the modern age (Rozenburg, 2011, para. 13) and the scale of this problem ought
to be recognised (Bailin, 2011, para. 12).
In an effort to reduce the risks of seriously prejudicing criminal trials Dominic
Grieve has brought more contempt of court cases than were brought in the
previous ten years since he was appointed (Pugh, 2012, para. 7). These have mostly
involved print media and it can be argued that the internet, including social media

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and online newspaper archives, have created doubts in the clarity of contempt law
(Hanson, 2011, para. 19). Online archives pose a risk of obstructing justice as jurors
are becoming increasingly harder to direct. The case of Joey Barton has
demonstrated the ease with which an innocent social networker can risk substantial
damage to a fair trial. The capabilities of the internet seem to create challenges for
contempt by publication law, and it could be argued that there is need for
amendment to keep up with the growth of new media. In the coming years there
will inevitably be an increase in the power and role of the internet in reporting both
the courts and events across the globe (Attorney General, 2011, para. 81) and the
justice system cannot continue to ignore the risks of what is so easily accessible
online (Banks, 2011, para. 18).

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Conclusion
When the Contempt of Court Act 1981 was designed it did not make provision for
modern means of communication and is yet to be amended to deal with the global
nature of the internet (Eady & Smith, 2005, p.283). This reflects the concerns with
online means of reporting legal proceedings which interfere with the fair trial
process. Although Dominic Grieve has successfully prosecuted a number of media
organisations in recent years for unfair pre-trial publicity (Pugh, 2012, para. 7), it is
evident from this study that the problems facing contempt by publication law are
the use of social media, the access to online archives and the difficulty in regulating
public contributions online. If the legislation is left unaltered these problems may
escalate and the internet will continue to create contempt issues.
This study has defined contempt by publication law under the Contempt of Court
Act 1981, as well as reviewing and analysing relevant cases involving the internet in
order to determine the validity of existing legislation. Arguably, contempt by
publication law cannot continue to function effectively in the modern digital age, as
access to online archives and instant communication are risks too broad to ignore
(Banks, 2011, para. 8). With regard to the internet, the danger to justice lies in the
facts it makes available as if, at the click of a mouse, we are able to uncover not just
gossip but criminal records, then impartiality becomes almost impossible for jurors
(Colquhoun, 2011, para. 10)
The difficulties with the use of Twitter in courts to comment on on-going
proceedings are apparent throughout this paper. The case of Joey Barton highlights

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the dangers of commenting on proceedings online with no prior knowledge of

contempt law (Hyde, 2012, para. 3). Using social media in court, although an
exciting method of reporting (Lambourne, 2011, para. 1) has created interference in
a trial process on a number of occasions due to prejudicial information being
uploaded. This form of instant reporting could easily jeopardise a trial (Rozenburg,
2011, para. 14) and the existing contempt laws cannot mitigate the risks associated
with this media platform.
It can also be said that a distinction should be drawn between publishing, as such,
and the archiving of material on the internet (Eady & Smith, 2005, p.230) as access
to information online risks constant contempt (Crook, 2010, p.52). Websites are
also not easily susceptible to control (Eady & Smith, 2005, p.275) and tools enabling
contributions from the public are becoming increasingly difficult to police (Grieve,
2011, para. 68). These online systems are likely to evolve and the increase in
accessibility results in the increase in risk to a fair trial. From the cases discussed
throughout this paper, it is apparent that jurors are readily susceptible to prejudicial
comment (Young, 1981, p.246) as two thirds of a jury are said to not fully
comprehend the directions imposed by trial judges (Thomas, 2010, p.36).
It is argued therefore that judges need to provide a revised direction, to jurors, on
internet use (Thomas, 2010, p.50) suggesting that the problem of jurors conducting
online research is not yet beyond the resolution of the courts (Eady & Smith, 2005,
p.54). Dominic Grieve however acknowledges that legal difficulties have arisen due
to the internets influence; he agreed that he had to consider whether the powers

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we have under the Contempt of Court Act to deal with this sort of problem are
sufficient (Rozenburg, 2011).
Additionally, it must be recognised that instant online communication requires
effective protection for the integrity of a criminal trial (Halliday, 2011, para. 9 & 10)
and yet there has been no amendment to contempt law to deal with this. The
evidence suggests that awareness of the law needs to be promoted to the public to
reduce potential risk, and the availability of websites and social media need to be
monitored. Lord Justice Moses showed concern for what potential jurors may read
online:
The criminal courts have been troubled by dangers to the integrity and
fairness of a criminal trial, where juries can obtain such easy access to
the internet and to other forms of instant communication (Halliday,
2011, para. 8).
Furthermore, the entire jury system is based upon the assumption that the jury will
follow instructions they receive from the trial judge (Eady & Smith, 2005, p.259) and
as this paper has determined, the internet provides a wealth of comment and
information readily available for jurors to research. Although the matter of
contempt by publication is to be reviewed by the Law Commission in 2014, the
issue needs immediate consideration (Branch, 2012, para. 9).
It is evident from this study that the internet can have a profound effect on the fair
trial process, through means of social media, online archives and user generated
content. Due to the existence of these online tools, contempt legislation requires
amendment to cater for their impact. The courts should be allowed to try cases
without a pre-trial rehearsal of the issues (Young, 1981, p.247) and within the age

Page | 43

of instant communication, this is becoming increasingly difficult. From this paper it

can be concluded that contempt by publication law under the Contempt of Court
Act 1981 may no longer be valid in the modern digital age. The issue needs
thorough investigation into whether the law requires amendment to function
successfully in todays society.

Word Count- 10,923

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Appendices
Appendix One: Attorney General v Times Newspaper Ltd42
Appendix Two: The strict liability rule.43
Appendix Three: HM Advocate v Beggs (No.2).44
Appendix Four: Interim Practice Guidance- Twitter in Courts.45
Appendix Five: The Guardian- online articles.48
Appendix Six: The Sun- online articles.56
Appendix Seven: Attorney General v Associated Newspaper Ltd63
Appendix Eight: The Guardian- Transcript of online conversation.65

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Appendix One
Attorney General v Times Newspapers Ltd
House of Lords
25 July 1973
Case Analysis
Where Reported
[1974] A.C. 273; [1973] 3 W.L.R. 298; [1973] 3 All E.R. 54; (1973) 117 S.J. 617
Subject: Civil procedure
Keywords: Contempt of court; Injunctions; Press; Public interest
Summary: Contempt; newspaper articles; public interest
Abstract: The House of Lords has held that the publication of articles by the Sunday
Times about facts relating to the plight of thalidomide children would be a
contempt of court whilst litigation in the matter is pending. Per Lord Reid: As a
general rule where the only matter to be considered is pressure put on a litigant,
fair and temperate criticism is legitimate, but anything that goes beyond that may
well involve contempt of court. But in a case involving witnesses, jury or
magistrates, other considerations are involved: there, even fair and temperate
criticism might be likely to affect the minds of some of them so as to involve
contempt. The Distillers Company manufactured and marketed a drug containing
thalidomide for pregnant mothers, which caused gross deformities in their children.
For some ten years various actions were begun and compromised, further actions
were begun, and negotiations for compromises were begun, discontinued and
recommenced. The Sunday Times published the first in a series of articles drawing
the attention of the public to the plight of the children concerned. The Distillers
Company complained that the article was a contempt, because certain actions were
still pending. The Attorney General moved for an injunction in the Divisional Court
restraining publication of a further article about the testing, manufacture and
marketing of the drug, which was granted. Subsequently, there was a national
campaign in the Press and elsewhere, which resulted in an increased offer from
Distillers. The Court of Appeal then discharged the injunction. The Attorney General
appealed to the House of Lords.
Held, publication would amount to a contempt of court, and the injunction was
rightly granted. (Decision of C.A. reversed; R. v Hargreaves Ex p. Dill (No.2) [1954]
Judge: Lord Reid; Lord Morris of Borth-y-Gest; Lord Diplock

Retrieved February 25, 2012, from: Westlaw.

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Appendix Two
The strict liability rule
Substantial Risk- Factors
If a prejudicial report was published during the progress of a trial then the risk
would be high (Eady & Smith, 2005, 241). The type of court hearing the case, the
circulation of the publication in question and the time delay to a trial are also
factors to determine a substantial risk. Crown Court is the most likely venue at risk
of contamination by media publication as all criminal trials are by jury (Carey et al,
2010, p.162). One of the factors taken into account in assessing the risk of prejudice
is the locality in which the case is to be heard (Eady & Smith, 2005, p.99). This
suggests that if the prejudicial material is covered by a publication a distance from
the trial it is less likely to interfere. However the availability of information online
challenges this idea. The lapse of time between the published article and the court
case, also known as the fade factor and the scale of the distribution of the relevant
publication, all contribute towards the degree of risk (Barendt, Hitchens, 2000,
p.429). A national newspaper website for example may have more views than that
of a local website.
Serious prejudice
Is the potential harm the published material itself might cause. The seriousness of
the material might cause the discharge of a jury for example (Eady & Smith, 2005,
p.254). In cyberspace, any individual can now contribute to news stories and
comment on future trials and the inability to control access to the web means
prejudicial material could reach the eyes of any juror or witness (Eady & Smith,
2005, p.61).
Intent
In addition to this, within the Contempt of Court Act, intention is not a relevant
consideration (Crook, 2010, p.449). The strict liability rule applies only in relation to
publications. Any act that can be classified as a communication falls within this
bracket (Eady & Smith, 2005, p.232) and must be a

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Appendix Three
HM Advocate v Beggs (No.2)
High Court of Justiciary
21 September 2001
Case Analysis
Where Reported
2002 S.L.T. 139; 2001 S.C.C.R. 879; 2001 G.W.D. 34-1327
Subject: Administration of justice
Keywords: Competence; Contempt of court; Publications; Scotland; Time; Websites
Summary: contempt of court; publications; appearance on website; accessibility;
Scotland
Abstract: B, on trial in September 2001 on a charge of assault, sodomy and murder,
moved for the "publishers" of material found in the archive sections of certain web
sites to be ordained to appear before the court, arguing that the material
constituted a prima facie contempt of court. The Crown argued inter alia that the
"time of the publication" in the Contempt of Court Act 1981 s.2(3) referred to the
moment the material first appeared on the web sites.
Held, refusing the motion, that (1) "publication" in s.2(1) signified a work of some
kind that had been published rather than the action of making something publicly
known, or issuing or offering something to the public, and the material contained
on these web sites had to be regarded as "publications" within the definition in
s.2(1); (2) the "time of the publication" referred to the whole period during which
the material was accessible to the public, and (3) the material had not been shown
to create a substantial risk that the course of justice would be seriously impeded or
prejudiced in terms of s.2(2) and a prima facie case of contempt had not been
established. The material was originally published in December 1999, was only
accessible as part of an archive and was unlikely to be accessible by random search
under B's name, and there was no reason to suppose the jury would not follow the
direction of the trial judge to base their decision on the evidence they heard in the
present proceedings and not on any extraneous material.
Judge: Lord Osborne
Counsel: For HM Advocate: Turnbull Q.C., AD and AA Edwards. For B: D Findlay Q.C.,
VJ Young and DAC Young.
Solicitor: For HM Advocate: AC Normand CB, Crown Agent. For B: Keegan Smith,
SSC (Livingston).
Retrieved March 02, 20120, from: Westlaw

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Appendix Four
INTERIM PRACTICE GUIDANCE: THE USE OF LIVE TEXT-BASED FORMS OF
COMMUNICATION (INCLUDING TWITTER) FROM COURT FOR THE PURPOSES OF
FAIR AND ACCURATE REPORTING
1.
This interim guidance applies to court proceedings which are open to the
public and to those parts of the proceedings which are not subject to reporting
restrictions.
2.
There is a degree of uncertainty about the use which may be made of live
textbased communications, such as mobile email, social media (including Twitter)
and internet enabled laptops in and from courts throughout the jurisdiction.
For the purposes of this interim guidance these means of communication are
referred to, compendiously, as live, text-based communications.
3.
A consultation relating to the use of live, text-based communications will
be conducted shortly. Those who will be consulted include the Judiciary, the
Secretary of State for Justice, the Attorney General, the Director of Public
Prosecutions, the Bar Council, the Law Society, the Press Complaints Commission,
and the Society of Editors in addition to interested members of the public via the
Judiciary website.
4.
Pending the outcome of the consultation, this interim guidance should be
considered by courts, litigants, their legal representatives and the media if and
when any application is made to the court to permit the use of live, text-based
communications. If any difficulties arise in respect of the use of such
communications, or the outcome of the consultation becomes known, it may
become necessary to issue a formal Practice Direction.
5.
This interim guidance is intended to be consistent with, and has been
drafted in light of, the legislative structure which:
a.
prohibits,
i.
the taking of photographs in court (section 41 of the Criminal Justice Act
1925); and,
ii.
the use of sound recording equipment in court unless the leave of the
judge has first been obtained (section 9 of the Contempt of Court Act 1981).
b.
Requires compliance with the strict prohibition rules created by sections 1,
2 and 4 of the Contempt of Court Act 1981 in relation to the reporting of court
proceedings.
It has immediate effect.
General Principles
6.
The judge has an overriding responsibility to ensure that proceedings are
conducted consistently with the proper administration of justice, and so as to avoid
any improper interference with its processes.
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7.
A fundamental aspect of the proper administration of justice is the
principle of open justice. Fair and accurate reporting of court proceedings forms
part of that principle. The principle is however subject to well-known statutory and
discretionary exceptions. Two such exceptions are the prohibitions on photography
in court and on making sound recordings of court proceedings.
8.
The statutory prohibition on photography in court, by any means, is
absolute. There is no judicial discretion to suspend or dispense with it. Any
equipment which has photographic capability must not have that function
activated.
9.
Sound recordings are also prohibited unless, in the exercise of its
discretion, the court permits such equipment to be used. In criminal proceedings,
some of the factors relevant to the exercise of that discretion are contained in
Page 2 of 4 Paragraph I.2.2 of the Consolidated Criminal Practice Direction. The
same factors are likely to be relevant when consideration is being given to the
exercise of this discretion in civil or family proceedings. The use of live, textbased
communications from court should be approached in the same way.
10. There is no statutory prohibition on the use of live text-based communications
in open court. But before such use is permitted, the court must be satisfied that its
use does not pose a danger of interference to the proper administration of justice in
the individual case.
11. Subject to this consideration, the use of an unobtrusive, hand held, virtually
silent piece of modern equipment for the purposes of simultaneous reporting of
proceedings to the outside world as they unfold in court is generally unlikely to
interfere with the proper administration of justice.
Use of Live, Text-based Communications: General Considerations
12. The normal, indeed almost invariable, rule has been that mobile phones must
be turned off in court. An application, whether formally or informally made (for
instance by communicating a request to the judge through court staff) can be made
by an individual in court to activate and use a mobile phone, small laptop or similar
piece of equipment, solely in order to make live text-based communications of the
proceedings.
13. When considering, either on its own motion, or following a formal application or
informal request, whether to permit live text-based communications, and if so by
whom, the paramount question will be whether the application may interfere with
the proper administration of Justice. The most obvious purpose of permitting the
use of live, text-based communications would be to enable the media to produce
fair and accurate reports of the proceedings.
14. Without being exhaustive, the danger to the administration of justice is likely

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to be at its most acute in the context of criminal trials e.g., where witnesses who are
out of court may be informed of what has already happened in court and so
coached or briefed before they then give evidence, or where information posted
on, for instance, Twitter about inadmissible evidence may influence members of a
jury. However, the danger is not confined to criminal proceedings; in civil and
sometimes family proceedings, simultaneous reporting from the courtroom may
create pressure on witnesses, distracting or worrying them.
15. Two further considerations are material:
a.
if, having given permission for such use, the court proceedings are
adversely affected, permission may be withdrawn; and,
b.
it may be necessary for the judge to limit live, text-based communications
to representatives of the media for journalistic purposes but to disallow its use by
the wider public in court. That may arise if it is necessary, for example, to limit the
number of mobile electronic devices in use at any given time because of the
potential for electronic interference with the courts own sound recording
equipment, or because the widespread use of such devices in court may cause a
distraction in the proceedings.
16. The operation of this interim guidance will be monitored and inform the
consultation process referred to above.
Lord Judge The Lord Chief Justice of England and Wales 20 December 2010
Retrieved February 28, 2012, from
http://www.judiciary.gov.uk/Resources/JCO/Documents/Guidance/lcj-guidancelive-text-based-communications-20122010.pdf

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Appendix Five
Levi Bellfield articles- Retrieved from The Guardian online archive

Article One
'He treated women like dogs'
Karen McVeigh
guardian.co.uk, Monday 25 February 2008 15.31 GMT
Article history
A Metropolitan Police handout of Levi Bellfield. Photograph: PA
In evidence ruled inadmissible by the judge at the trial of Levi Bellfield, a former
girlfriend told how he admitted he hated blondes and would hang around alleyways
"wanting to hurt women, stab them or rape them".
She found magazine pictures in which the faces of blonde models had been slashed,
she said. Bellfield's cellmate, Paul Jarvis, said the former bouncer "treated women
like dogs".
Born in Isleworth, west London, on May 17 1968, Bellfield never strayed far from his
old home. His attacks on at least five women, carried out between 2001 and 2004,
took place in an area of west London south of the M4 corridor, just east of the M25.
During this time, Bellfield, of West Drayton, west London, ran a wheelclamping firm
under a number of aliases.
He admitted using up to 42, including Lee Johnson and David Bennett, but claimed
they were for "tax reasons" and to avoid people whose cars were clamped seeking
revenge.
Bellfield, who has 11 children by five different mothers, was described as a "ladies'
man" by friends. But while he liked to play the charmer, he had a low regard for
women, seeing them as sexual objects. According to the prosecution, he would turn
violent when rejected.
Police believe he initially propositioned the French student Amelie Delagrange on
the night of August 19 2004 and, when rebuffed, killed her in a rage.
Separate CCTV images showed his white Ford Courier van and Delagrange, on foot,
both slowing down as they approached Twickenham Green, appearing to fit this
theory.
Giving evidence during his Old Bailey trial, Bellfield cut a strange figure as he
attempted to charm the jury, portraying himself as an ordinary man who could not
understand why he was there.

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He admitted a range of previous offences, from stealing vehicles to assaulting a

police officer, telling the jury in his high-pitched voice: "I'm no angel, but I'm not a
killer."
The first sign he was a danger to women came three years before he killed
Delagrange when he allegedly tried to abduct Anna Maria Rennie from a bus stop in
Twickenham on October 15 2001.
When she refused his offer of a lift, the trial heard that Bellfield picked her up,
placed a hand over her mouth and tried to drag her into the car. When she escaped,
he shouted after her: "You're a whore, a slut."
Rennie, who now lives in Spain, identified him in a video ID parade in 2005 as her
case was reinvestigated following his arrest. She said he had destroyed her
confidence for a long time.
In court, Bellfield insisted she was mistaken and tried to claim that two witnesses
had given evidence against him because they "wanted their day at the Old Bailey".
Bellfield's next alleged victim was Irma Dragoshi, a 33-year-old hairdresser who
worked in Slough. On December 16 2003, she was standing at a bus stop in
Longfield Village, near Heathrow. She woke in hospital with no memory of what had
happened.
But Sunil Gharu, who worked with Bellfield, told police he had seen the attack. He
said Bellfield suddenly pulled over on the opposite side of the road and told him:
"Watch this."
Gharu said he then ran up to Dragoshi, spun her round and smashed her to the
ground. He ran back, got in the car and drove off, laughing. Bellfield admitted he
had been present during the attack, but tried to claim Gharu had been responsible.
Bellfield's conviction does not bring police interest in him to a close, with detectives
analysing a string of unsolved attacks for evidence of his possible involvement.
Ends.

Article Two
Bellfield cruised streets before striking with 'blitz' hammer attacks
Karen McVeigh
guardian.co.uk, Monday 25 February 2008 15.32 GMT
Article history
CCTV footage of Amelie Delagrange boarding the 267 bus at 21:39 on Thursday
August 19 2004, the night of her murder. Photograph: PA

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On an August night in 2004, Amelie Delagrange was making her way home after a
night out drinking with friends.
A little tipsy, the 22-year-old had missed her usual bus stop and was walking
towards Twickenham Green.
The student, from Amiens, France, had been in London for only four months, and
had discussed with her friends whether Twickenham was a safe area before setting
off alone. They agreed it was.
But on that night, August 19, a predatory killer was cruising the streets in his white
Ford Courier van. CCTV footage shows the van with distinctive markings, several
times around the green.
Its location, combined with footage of Delagrange's last movements, suggests it
would have passed her at some stage as she headed home, alone and vulnerable.
Within minutes of seeing her, the killer parked up and viciously attacked her. She
had no time to defend herself as he struck her three times over her head with a
blunt instrument, fracturing her skull and leaving her dying on the ground before
making his escape.
That man, a jury concluded today, was Levi Bellfield - also known as Lee - a 39-yearold former nightclub doorman and wheel clamper from West Drayton. It was not
the first time he had killed.
He was found guilty of a campaign of violence, spanning three years, which left two
women dead, two with serious injuries and a third, who managed to escape with
her confidence in tatters.
Bellfield murdered Marsha McDonnell, a 19-year-old gap year student, in the same
way he killed Delagrange, battering her over the head as she walked from a bus
stop, leaving her lying face down in a pool of blood yards from her home. She died
two days later.
All three of the women he attacked between February 2003 and August 2004 were
aged between 17 and 22. All were fair-haired and slim.
The attacks all took place in an area of west London south of the M4 corridor and
just east of the M25 - an area Bellfield knew well, having lived and worked there
most of his life.
Emma Mills, a former girlfriend and the mother of three of his children, who was an
important witness for the prosecution, lived close to Twickenham Green,
equidistant to where Delagrange and Bellfield's first alleged victim, Anna Maria
Rennie, were attacked.
The court heard how his modus operandi was to drive around west London late at
night, following buses to stalk vulnerable young women.

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A friend of his told how he kept a stash of weapons, including hammers and
knuckledusters, in the back of his van. What the jury did not know was that Bellfield
- described as an "animal" by a friend because of his depraved attitude to women harboured a hatred of young, slim, blonde women.
Up to the day before his arrest, Bellfield was on the lookout for women to degrade.
Under police surveillance, he approached and made lewd comments to two
schoolgirls, aged 14 and 16, at a bus stop. This too, was not heard by the jury.
Police believe he may have been behind a string of unsolved attacks, the most
serious of which is the alleged murder of the 13-year-old schoolgirl Milly Dowler on
March 21 2002.
Scotland Yard is also investigating a further dozen offences, including five rapes and
seven assaults, for which they believe he is responsible.
They include attacks on accountant Edel Harbison, 34, who survived an assault on
Twickenham Green on April 16 2004; accounts clerk Dawn Brunton who was badly
beaten in Hatton Cross in November 2003; Sonia Salvatierra, who escaped an
attempted attack on her near Twickenham Green on November 3 2002; and a 17year-old who was attacked in Strawberry Hill in January 2003. All were assaulted
within the area in which Bellfield operated.
The former bouncer, a man police described as clever, was careful not to leave
clues. His trademark "blitz" attacks - three blows to the back of the head - were
vicious, quick and left no forensic evidence behind that could link him to his victims.
During each attack, with the exception of that on Delagrange, he had his mobile
phone switched off so his whereabouts could not be traced. Vehicles that could be
linked to the attacks were quickly sold on or otherwise disposed of. Some have
never been traced.
Vehicles played an important part in his crimes, but they also played a role in
bringing him to justice.
No one witnessed his attack on McDonnell in Hampton, west London, on February 4
2003, just as no one was to witness the murder of Delagrange.
But a silver Vauxhall Corsa was picked up on CCTV moving oddly near the 111 bus in
which McDonnell was preparing to alight. The car slowed down and stopped as the
bus approached.
The behaviour of the driver was "identical" to that of the motorist in the people
carrier that was to run over another victim, 18-year-old Kate Sheedy, after she got
off a bus. After the murder of Marsha McDonnell, Bellfield sold a silver Corsa for
1,500 - 4,500 less than he paid for it.
Sheedy, a former convent head schoolgirl who was returning home from end of
term celebrations, saw a white Previa people carrier with blacked out windows that
she felt was "sinister", and crossed the road.
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It was the prosecution's case that this move thwarted his intentions towards her.
Bellfield then drove at her at speed, knocking her flat, before driving over her twice.
The attack lasted less than a minute, but left her with internal injuries so severe she
was in hospital for three weeks.
Once again, Bellfield sold the vehicle a few weeks later.
Ends.

Article Three
Bus stop killer told he will never leave jail
Karen McVeigh
The Guardian, Wednesday 27 February 2008
Article history
Levi Bellfield, the bus stop killer, will stay in prison for the rest of his life after
reducing three families to "unimagined grief", a judge said yesterday.
Bellfield, 39, convicted of killing two women and viciously attacking a third, was
yesterday branded a coward by the families of those he murdered, Amelie
Delagrange, 22, and Marsha McDonnell, 19, and by the surviving victim, Kate
Sheedy, 21, for his decision not to attend court to hear his sentence.
His action was a final act of defiance in a four-month murder trial during which he
displayed no remorse and, in extraordinary scenes in court, verbally taunted
relatives of his victims as they sat close to him.
His barrister, William Boyce QC, said Bellfield was not in court because of the
"explosion of bad publicity" and a "welter of accusations of other crimes by him".
It was revealed yesterday that the former nightclub bouncer, who is the prime
suspect for the murder of 13-year-old Milly Dowler, who disappeared in 2002, also
faced eight charges of rape and four of assault on three women, which will lie on
file.
Yesterday, an emotional statement from Delagrange's mother, Dominique, was
read in court, leaving many in tears. It charted the short life of an "absolutely
adorable" daughter and the devastating impact of her death. "It will always hurt us
not to know what would have become of Amelie had her life not been severed ...
She wanted to marry, have children, and her sister to be godmother of her first
child. So many unfulfilled hopes which are now intangible."
Addressing Bellfield as if he were present and not in the Old Bailey cells, Mrs Justice
Rafferty gave the defendant three life terms: "You will not be considered for parole
and must serve your whole life in prison."
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There were cries of "yes!" from the public gallery as the sentence was passed.
Bellfield will be one of a handful of prisoners, including Steve Wright, convicted last
week of the murders of five women in Ipswich, who will spend their life in jail.
The judge commended Detective Chief Inspector Colin Sutton, who led the
investigation, for the "thousands of hours of unglamorous and painstaking" work
that led to Bellfield's conviction.
After sentencing, families of the victims condemned Bellfield for not facing justice.
Sheedy said: "It means so much to me that he got a full life term."
Delagrange's father, Jean-Francois, said: "It's just another show of his cowardice. He
was a coward in his attacks and a coward today, the day he should pay for what he
has done."
McDonnell's uncle, Shane, said: "For a man who took pleasure in his victims ... this
latest act of cowardice comes as no surprise. We are extremely happy the law has
decreed this man will die in prison."
Ends.

Article Four
Bellfield named as prime suspect in Dowler murder
David Batty and agencies
guardian.co.uk, Monday 25 February 2008 15.54 GMT
Article history
Murdered teenager Milly Dowler. Photograph: Surrey police/PA
Detectives investigating the abduction and murder of schoolgirl Milly Dowler six
years ago today named Levi Bellfield as the prime suspect in the case.
The revelation came after Bellfield was found guilty at the Old Bailey of the murder
of two young women - French student Amelie Delagrange, 22, and Marsha
McDonnell, 19 - and the attempted murder of a third, Kate Sheedy, 18.
Amanda Dowler, known as Milly, vanished while walking home from school in
Walton-on-Thames, Surrey, on March 21 2002.
The 13-year-old's skeletal remains were found six months later by mushroom
pickers on Yateley Heath, Hampshire, 30 miles from her home.
Surrey police have been building their own case against Bellfield since he was
arrested by the Metropolitan police in November 2004.

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Detectives hope the conclusion of the Old Bailey trial will lead to a breakthrough in
the Dowling investigation, codenamed Operation Ruby.
Bellfield could not be linked publicly to the investigation while he faced other
charges. But police revealed today he was arrested and interviewed over Milly's
death three years ago.
Officers believe they have compelling circumstantial evidence linking him to the
crime and will soon interview him again.
Milly vanished on the afternoon of March 21. After leaving a cafe where she had
been with friends, she began walking to her home a mile away in Walton, Surrey.
When she failed to return, a huge hunt was launched and police concluded that she
was taken by an opportunist abductor.
Five people have been previously detained in connection with the murder. The last
was a 57-year-old registered sex offender from London, who was released in late
2005. In June of the same year a 52-year-old prisoner was arrested and questioned.
The previous month police arrested a 36-year-old man in Chertsey, three miles from
Milly's home, but he was released the next day.
Milly's parents Bob and Sally Dowler said today they would not find peace until her
killer is brought to justice.
"Six years ago our beautiful daughter Milly was callously murdered and still no one
has been brought to justice," they said. "How can we find peace? How can we ever
understand who could commit such an evil act and why?"
"Imagine not knowing how your daughter died, or where or when and by whose
hand, and imagine how we as a family live. If you know anything that could help
answer these questions, please find it in your heart to let us know."
In their first statement on the case since 2005, the couple urged anyone with
information to come forward. "We are pleading for anyone who knows anything to
have the courage to speak up," they said.
"Nothing will ever bring Milly back, but even six years on you can still help start
easing our pain by letting us know, finally, what happened on our daughter's final
days.
"We grieve and always will for what happened to Milly, for the damage done to us
as a family and to the future we have all lost."
Detectives investigating the case have collected a database of more than 11,000
people, including several suspects - of whom the prime suspect is Bellfield.
Surrey police have relaunched an appeal to help trace a red Daewoo Nexia captured
on CCTV in Walton-on-Thames minutes after Milly disappeared.
It can now be reported that a car of the same colour and model was owned by
Bellfield's then-girlfriend Emma Mills.
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The Daewoo, an old banger worth no more than 500, was reported stolen several
days after Milly disappeared and has never been found. Police fear it was crushed.
Detectives have released the vehicle registration, N503 GLT, and chassis number,
KLATF68V1SB554108, of the Daewoo in a new bid to locate it.
It has not been seen since Mills reported it stolen from a Hounslow pub car park
several days after Milly disappeared.
Detectives cannot account for Bellfield's movements on the day Milly disappeared.
His mobile phone was switched off. But they know he was familiar with Walton-onThames, and Milly's final resting place on Yateley Heath.
They hope the end of the Old Bailey trial will encourage people to come forward
with new information. The police source said: "We are looking for Levi Bellfield's
girlfriend's car and have been for some time.
"We are appealing to people who may have been scared in the past and now, for
whatever reason, are not. Or people who had allegiances in the past which may no
longer exist.
"We are appealing to Bellfield's criminal associates and we think they may have a
change of heart now."
The car was captured at the junction of Copenhagen Way and Station Avenue by a
CCTV camera on the roof of the Unilever building at 4.33pm. Forensic experts
believed the rear of the car appeared to be lower than normal, suggesting it was
carrying a heavy load.
Despite sending the CCTV to the FBI for state-of-the-art analysis, police were unable
to identify how many people were in the car or any further details. The incident,
written off by Surrey police as a "non-crime", was not initially linked to the Milly
investigation.
Bellfield was arrested while on remand in July 2005 and questioned by detectives
investigating Milly's disappearance. But he made no comment about the case.
Despite their suspicions, officers admit the method of Milly's abduction was very
different from the offences dealt with by the Metropolitan police inquiry.
Careful analysis of Milly's bones, scattered by animal activity, revealed no injuries.
This is inconsistent with the explosive violence shown in the hammer attacks on
Delagrange and Marsha McDonnell.
None of Milly's clothing or possessions were recovered from the woodland. Officers
found only bones and a small amount of hair.
Police are still trying to trace her Heathside school uniform jacket, Nokia mobile
phone and distinctive white purse with an ace of hearts logo on it.
The police source added: "We have not given up on Milly. It is a current
investigation and we have to keep plugging away until we get the break we want
and the family get the justice they deserve." Ends
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Appendix Six
Levi Bellfield articles- Retrieved from The Suns online archive

Article One
How many vics of evil Levi?
MIKE SULLIVAN
Last Updated: 12 Jan 2011
LEVI Bellfield's first name is an anagram of EVIL which police said "could not be
more appropriate".
Kate Sheedy who survived one of his sickening attacks said outside court after
the verdicts: "I will never forget what happened to me. The fact that Bellfield has
been found guilty means more to me than I can possibly say."
Video: Bus Stop Killer Guilty Of Murder
Wheel clamper Levi Bellfield has been found guilty
The law student, 21, added: "I've waited for nearly four years for this day. The road
to recovery has been long and hard and there have been times I thought I wouldn't
get better."
Kate, who was deliberately run over by Bellfield TWICE, was cheered as she
emerged from the Old Bailey.
She said she would not want the death penalty for the monster, adding: "I don't
believe in the death penalty that's the easy way out.
"I don't want to sink to his level. Execution is an easy option. He should be in a cell
for the rest of his life for what he has done."
Kate said meeting the families of Bellfield's murder victims had been "a powerful
reminder of what could have been".
She added: "I hope that this verdict brings some comfort to all those families that
have been affected by the despicable actions of just one man."
See more pictures of evil Bellfield by clicking the block below.
Those relatives treated with utter contempt by the monster said yesterday he
had only hate in his heart.
They spoke after video footage was released of the hammer killer following his
arrest in November 2004. It shows him callously turning his back on detectives as he
was being quizzed about Amelie Delagrange's murder.
One cop involved in the case said yesterday: "Levi is an anagram for evil and in this
case is highly apt.
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"He has never shown an ounce of remorse for what he has done."
Incredibly, it was also revealed Bellfield is the prime suspect in 100 crimes many
involving violent and sexual offences against women.
Murdered ... Marsha McDonnell was attacked near home
Shane McDonnell, uncle of 19-year-old murder victim Marsha, yesterday begged
those who have been close to the barbarian to help cops close files.
He said Marsha was "a girl with only love in her heart, brutally slain by a man who
only had hate in his".
Shane, brother of Marsha's father Phil, added: "For her family, life will never be the
same again. The pain and hurt we carry will always be there. It is a sentence with no
remission."
Shane, 45, told how the McDonnell family was mystified by Marsha's death.
He added: "Nobody could make sense of it. The answer only became apparent after
Amelie died. It finally gave us the picture that Marsha's death was one of a series of
random attacks."
Murdered ... visiting French student Amelie Delagrange
The traumatised father of French student Amelie, architect Jean-Francois
Delagrange, had a heart attack the year after Bellfield slaughtered the 22-year-old.
He and his wife Dominique spelt out their agony in an impact statement given to
the Old Bailey.
They said: "It will always hurt us not to know what would have become of Amelie
had her life not been severed in such a way. She wanted to marry, have children
and have her sister be the godmother of her first child. So many unfulfilled hopes."
The parents added: "We are so reluctant to accept the death of Amelie that her
grave is in reality a little garden always covered with flowers and grass.
"And contrary to our French culture, a stone will never be placed on it in the secret
hope that Amelie will remain in our hearts the playful being, full of laughter, love
and resting in the midst of crocuses she loved to pick in spring.
"Her loss is an open wound that will never heal. We will never get over it."
Woman-hater Bellfield prowled the streets of South West London, mainly targeting
thin young blondes at bus stops.
The 20-stone wheel clamper and club bouncer murdered gap-year student Marsha
in the early hours of February 5 2003, just after she got off a bus in Hampton.
Marsha was just 14 doors away from her home when she was bludgeoned over the
head with a weapon like a lump hammer.
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She died three days later in hospital surrounded by her family.

The next year Bellfield mowed down 18-year-old convent school head girl Kate after
she got off a late-night bus in Whitton.
She had been out with chums celebrating their last day at school before they took
their A-levels. Kate spotted Bellfield's white Toyota Previa people carrier parked
with its lights off and engine running.
When she crossed the road Bellfield deliberately ran her over. Then he reversed
across her body, causing massive injuries including punctured lungs, a split liver and
broken back.
Three months after Bellfield tried to kill Kate, he murdered Amelie after stalking her
from a bus in Twickenham.
The student had missed her stop and was walking back across Twickenham Green
when the beast smashed her over the head from behind near the cricket pitch.
Bellfield was finally caught after the Kate and Amelie cases were linked by police
following an earlier blunder. Kate was attacked at 12.30am on May 28 2004, but
cops wrongly scanned bus and pub CCTV from the early hours of May 27.
Detectives probing Amelie's death later spotted the error and found Bellfield's
Toyota on frames.
A resemblance between Marsha and Amelie, and their injuries, also rang alarm
bells. And links between the murders were examined.
Appeals were made to trace a white Ford Courier van seen on CCTV by Twickenham
Green when Amelie died. The tactic worked. Officers received 129 calls from
women naming husbands or ex-partners as possible suspects.
One was from Bellfield's ex Johanna Collings, who mentioned he was a wheel
clamper. Det Chief Insp Colin Sutton said: "One of the team said he had checked out
a Courier sold to two clampers."
It turned out that a mobile number used by one of the buyers had been used to call
a police antiterrorist hotline.
In an act of spite against his Italian neighbours Bellfield then living in West
Drayton, near Heathrow had claimed they were al-Qaeda terrorists.
Bellfield, from a family of travellers, was put under surveillance. And three months
after Amelie's murder, he was seized while hiding naked in his loft. A few days later
he tried to hang himself with a tie.
Ends.

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Article Two
Killer was 'Jekyll and Hyde'
STAFF REPORTER
Published: 25 Feb 2008
BUS stop killer Levi Bellfield would have continued his evil murder spree if he had
not been stopped.
His attacks on young women over the last three years are thought to form only part
of his sexual and violent history as detectives believe he could be responsible for 20
attacks which were never solved.
The most serious allegation is the killing of Milly Dowler in March 2002 who was last
seen walking from Walton-on-Thames railway station after leaving her school in
Weybridge.
It emerged after the two guilty verdicts that he is to be interviewed by Surrey
detectives and is now the prime suspect in the case.
But Bellfield, who thought of himself by day as affable Lee, family man,
businessman and Jack the Lad will now be questioned about the brutal killings of
Judith Gold and Patsy Morris.
Miss Gold was hit over the head in Hampstead, north London nearly 20 years ago in
1990. And Miss Morris, a school friend of the killer, was strangled to death on
Hounslow Heath in west London at the age of 14.
In addition to a number of unsolved attacks on people in west London, Bellfield is
suspected of date-rape crimes involving young women who were plied with drugs
and sexually abused.
The former doorman, who had a devil tattoo on his shoulder, denied his Jekyll and
Hyde existence right to the end and tried to convince the jury that he was caught up
in a miscarriage of justice.
But a succession of friends and former colleagues told police a different story, of a
man who had an unhealthy interest in sex.
He was said to have 11 children, aged three to 18, by five different women but an
unofficial estimate has put the number at 13. He also had a series of blonde lovers
on the go. Sometimes, more than one was pregnant at the same time.
When he was violent towards a partner, she would seek comfort from one of the
other women. They lived in the same area and knew each other.
One said Bellfield showed an unhealthy interest in one of her 13-year-old relatives.
Over the years, he had many girlfriends in addition to his "wives" but still sought
younger girls to impress.
Page | 63

He flashed his cash and was once seen doing a "loadsamoney" impersonation with a
handful of notes.
The sinister 20-stone killer trawled the darkened streets for young runaways from
care homes getting off the last bus with nowhere to go hoping to lure them with
drink and drugs. If successful, the youngsters would find themselves in one of many
old cars and vans which had been adapted with darkened windows and carpets.
But if he picked the wrong woman and was turned down, Bellfield would explode in
a violent rage and go after them with a hammer or baseball bat.
A former partner said she found a magazine with the faces of blonde models
slashed out.
Bellfield also told her he would go to alleyways and would wait and watch blondes
passing, claiming that he wanted to "hurt them, stab them, rape them".
"He hated women. He hated blonde women," said prosecutor Brian Altman.
A former friend Peter Rodrigues suffered a life-threatening head injury in June
2004.
He told police that as he recovered consciousness, he saw Bellfield leaning over him
with a mallet in his hand.
The two men had been in dispute about a flat in West Drayton and police could not
prove he was the attacker.
Another acquaintance claimed Bellfield told him about his attitude to women.
"He was like a caveman. He treats women like dogs," the man said.
Ricky Brouillard said Bellfield had a relationship with a 15-year-old girl.
On one occasion Bellfield had sex in front of him with another teenager.
He said: "I would describe him as an animal. She was a naive little girl. He didn't
treat her with respect."
Mr Brouillard said Bellfield admitted he had sex with the teenager's younger cousin,
who was 14 or 15.
"She had long blonde hair and a ponytail. He said he had sex with her and I was
disgusted."
Police were told that Bellfield kept an array of weapons in his vehicles from which
he sold cocaine which included hammers, baseball bats, a knuckleduster, a cosh and
even a gun.
The Toyota Previa used to mow down Kate Sheedy had blacked-out windows and a
quilt in the back. There were also claims of manacles and whips kept in the back of
his van in 2004.
Page | 64

The day before his arrest in November 2004, Bellfield was under police observation
when he was seen to approach two cousins aged 14 and 16 at a bus stop.
He got out of the car, said: "Are you virgins?" and made other lewd remarks.
The 6ft tall murderer was brought up in west London by his now elderly and ailing
mother.
He began chatting up girls and had ready access to drugs when he worked as a
bouncer in pubs and clubs in the Twickenham area.
Then he hit gold with the demand for wheel clamping services for businesses with
land which could be used for car parks.
With a bunch of friends, he set out to trap motorists. If they refused to pay, some
would have their feet "accidentally" run over.
A doctor complained after this happened to him, unaware that the company he was
writing to consisted only of Bellfield.
An elderly woman also found her toes crushed after Bellfield arrived to sort out a
dispute with his men.
Bellfield summed himself up in his own words on the Friends Reunited website.
He told former school friends: "Was short at school now over six feet ha ha...i havnt
grown up still think im 18 out clubing, ibiza, tenereif. A bit flash like the labels am i
sounding a prat???? dont look my age...any single girls out there e mail me."
Ends.

Article Three
Murder 'suspect' at age of 12
ALEX PEAKE
Published: 27 Feb 2008
DETECTIVES believe Levi Bellfield's killing spree could have begun 28 years ago
when he was just TWELVE.
Cops last night revealed they would re-investigate the brutal murder of 14-year-old
Patsy Morris, after it emerged she dated the monster at school.
Patsy's family now believe the hammer killer is the prime suspect in the unsolved
case.
Her body was found hidden in undergrowth in Hounslow Heath after she vanished
from her school in Feltham, Middlesex, at lunchtime.

Page | 65

She had been strangled but was not sexually assaulted.

Last night Patsy's sister Nicola, 44, told of her shock at the link with Bellfield, 39.
She said: "We did not know him. It was a shock when we found out they knew each
other. Friends told us about it. It is horrendous the crimes he has committed and
the pain and suffering he has put on other families. We understand what they have
gone through.
"People say it heals over time but it never does."
Patsy's father George, 72, added that shortly after his daughter's murder he had
received a death threat from a young man who he now suspects was Bellfield.
He said: "The phone rang and someone said, 'I'm going to kill you'. It was a young
male voice and a local call. It was very strange.
"He is a local man which is why it could be him. It is terrifying that someone of 12 or
13 could have done it."
And George backs any new police investigation, saying: "If the police are going to
investigate it would be great. We can only hope and pray that we do get a result, it
would be a blessing.
"We have had 28 years of it, you have to deal with it the best you can. It is
something that never leaves you."
And he hinted that he wanted the death penalty for Bellfield, saying: "If he has
taken my daughter's life and countless others, there is only one thing for him."
Ends.

Page | 66

Appendix Seven
Tuesday, 22 November, 2011
ATTORNEY GENERAL v ASSOCIATED NEWSPAPER LIMITED
JUDGES: LORD JUSTICE MOOREBICK and MR JUSTICE BEAN
MR PERRY QC and MR HALL appeared on behalf of the Claimant
MR J CAPLAN QC appeared on behalf of Associated Newspaper Limited
MS K GALLIFANT appeared on behalf of MGM Limited
CASE and JUDGMENT
(Approved by the court)
1. LORD JUSTICE MOORE-BICK: This matter comes before the court by way of an
application by her Majesty's Attorney General for permission to apply for orders of
committal or other appropriate remedies against the newspaper publishers
Associated Newspapers Limited, the publisher of the Daily Mail, and MGM Limited,
the publisher of the Daily Mirror, for contempt of court. The alleged contempt
arises out of the publication of articles in the Daily Mail and the Daily Mirror on 24
June 2011, following the conviction on 23 June 2011 of Levi Bellfield of the murder
of Milly Dowler.
2. In the trial, which was presided over by Mr Justice Wilkie, Bellfield was facing a
second count of attempting to abduct another girl, Rachel Cowes. Although the jury
was able to return a verdict on 23 June in relation to the charge of murder, it was
still considering its verdict on the abduction charge at the end of that day.
3. Following the conviction of Bellfield on the murder count the Crown
Prosecution Service drew the attention of the media, including that of the intended
defendants, to the fact that the jury was still deliberating on the second charge and
advised them to take legal advice in relation to any material that they intended to
publish the next day. At the end of the afternoon, broadcasters carried various
interviews and other programs relating to the conviction. The following morning the
Daily Mail and the Daily Mirror, in common with many other sections of the press,
carried prominent stories relating to Bellfield's conviction. In the case of the Daily
Mail and the Daily Mirror, serious allegations were made about other violent
assaults and sexual offences that Bellfield was said to have committed. As a result
of the publications in general, Mr Justice Wilkie felt compelled to discharge the jury
without delivering a verdict on the abduction charge.
4. The two intended defendants have a wide circulation - something in excess of 2
million in the case of the Daily Mail, and over 1 million in the case of the Daily
Mirror. It is generally accepted that the readership is likely to have been very much
greater than the number of copies actually purchased. The trial judge referred the
matter to the Attorney General to enable him to consider whether proceedings for
contempt should be brought against the intended defendants on the ground that
Page | 67

the publications created a substantial risk of serious prejudice to Bellfield, and that
the course of justice would thereby seriously impeded or prejudiced.
5. Proceedings for contempt alleged to have been committed in connection with
criminal proceedings must be brought in the Divisional Court, and permission must
be obtained before they can be commenced. It is for that reason that the Attorney
General now seeks the court's permission to bring such proceedings against the two
intended defendants.
Retrieved February 26, 2012, from: LexisNexis Library.

Page | 68

Appendix Eight
Facebook contempt of court case: transcript of the online chat
Juror Joanna Fraill and defendant Jamie Sewart's chat during a multimillion-pound
drugs trial, which caused it to collapse
Facebook juror and defendant guilty of contempt
guardian.co.uk, Tuesday 14 June 2011 15.50 BST
Article history

Facebook chat between juror Joanna Fraill ("Jo Smilie") and defendant Jamie Sewart
on 3 August 2010:
18:31:36: Smilie to: Sewart: jamie nice one hun hope u both sort things out ]
18:31:58: Smilie to: Sewart: u should have seen his face
18:33:35: Sewart to: Smilie: i came runnin in i was listenin at the doors ha ha
18:34:26: Smilie to: Sewart: i know [defendant] from somewhere cant think wherre
18:34:27: Sewart to: Smilie: dont think we will be together he will probs go back to
the other one
18:34:40: Sewart to: Smilie: hes from [redacted]
18:34:57: Smilie to: Sewart: im blackley /moston
18:35:40: Sewart to: Smilie: no matter wat gary does i am glad he gonna come out
soon x
18:35:53: Smilie to: Sewart: awe no way sorry to hear that x cant believe they had u
on remand
18:36:46: Smilie to: Sewart: i defo know him from somehere [defendant]
18:36:56: Smilie to: Sewart: bsards
18:37:30: Smilie to: Sewart: thats prob why i been so determined
18:37:52: Sewart to: Smilie: they are bad what they do its that [redacted] who had it
in for me i lost my house and everything
18:38:11: Sewart to: Smilie: whats happenin with the other charge??
18:38:40: Smilie to: Sewart: well thats how it started u lot have had me laffin crying
omg
18:38:52: Smilie to: Sewart: which
Page | 69

18:39:08: Smilie to: Sewart: yours?

18:39:35: Sewart to: Smilie: no the class b
18:42:28: Smilie to: Sewart: cant get anywaone to go either no one budging
pleeeeeese dont say anyhting cause jamie they could call mmiss trial and i will get
4cked to0
18:43:37: Sewart to: Smilie: i know i have deleted all the messages i wudnt do that
to u dont worry xx
18:44:43: Smilie to: Sewart: i heard you doenstairs with the little un awe we were
watchin through the glass lol she a doll x
18:45:19: Smilie to: Sewart: awe fuck nos hw a didnt get caught wiv my nods and
blinks
18:46:02: Smilie to: Sewart: hand signals haha ive even been split from a juror omg
18:47:05: Sewart to: Smilie: haha i kept thinkin that it was to sumone behind me
18:48:02: Smilie to: Sewart: yeh but did u notice that my front tooth fell out the 2nd
day of the trialll hahhahahha wot do i look like
18:48:54: Smilie to: Sewart: kept forgting lmao and smiling omg frightening lol
18:49:01: Sewart to: Smilie: no ha ha i cudnt see that far ha ha my eyes are bad ha
18:49:39: Smilie to: Sewart: dont worry about that chge no way it can stay hung for
me lol th
18:49:50: Smilie to: Sewart: this is 2nd tim init
18:50:52: Smilie to: Sewart: at least then yer all home n dry
18:53:10: Sewart to: Smilie: ha ha ur mad i really appreciate everthin
18:53:34: Sewart to: Smilie: if i cud of kissed u all i would of done ha ha
18:54:01: Sewart to: Smilie: did u here me say i feel like getting naked haha
18:54:31: Smilie to: Sewart: jamie am gonna get off this lot doing me head in x it be
over tomoz fingers crossed , im not as daft as am cabbage looking hahaha alll that
note taking was just killing time lolol drew more than i wrote lol
18:56:08: Smilie to: Sewart: when we gsve that first on [redacted] i was crying cos
they held onto yours because 1 couldnt make her mind up
18:58:16: Smilie to: Sewart: it fucking wound me up like u wouldnt believe
hahahahha ah wlll nearly fucking there lol get all your property back too lol
18:59:49: Sewart to: Smilie: ha ha......
19:02:01: Sewart to: Smilie: i will be doin ha ha and trying for compo
Page | 70

19:02:19: Smilie to: Sewart: lol no doubt ill see u around tomoz dont worry xxx bout
the other x uu got time to make up wit your family xx enjoy it hun xx gl xx when
they gonna let em out then
19:02:41: Smilie to: Sewart: go girl lol
19:02:52: Sewart to: Smilie: keep in touch and i'll get u a nice pressie if i get
anything out of um x
19:03:38: Sewart to: Smilie: will find out on thursday thats when he gets sentenced
19:03:39: Smilie to: Sewart: dont be daft been a pleasure xxx lol
19:04:03: Sewart to: Smilie: thanks again (",) x
19:04:18: Smilie to: Sewart: best entertainment lol who else would have a day trip
to a fuckin lock up!
19:04:58: Smilie to: Sewart: and i will lol ill add u to me fb once it all over x
19:06:19: Sewart to: Smilie: i will do x x
19:06:50: Smilie to: Sewart: cya x
19:07:05: Sewart to: Smilie: spk to u soon x
19:07:28: Smilie to: Sewart: oh u willl lol
Ends.

Page | 71

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STATEMENT OF ORGINALITY

I confirm that to the best of my understanding this work has been prepared in
accordance with the universitys regulations and guidelines on referencing and is
substantially my own work.

Signed..................................................................

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