Ewrc Article 2 Summary

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In the case of R (Roberts) v Commissioner of Police of the Metropolis and others [2014] EWCA Civ 69 before the Court of Appeal, Ms Roberts appealed a decision of the Divisional Court [2012] EWHC 1977 (Admin), which dismissed her claim following an incident when she was stopped and searched under section 60 of the CJPOA 1994. Her case was that the powers to search without reasonable suspicion offended Articles 5 and 8 of the ECHR, which protect the right to liberty and respect for privacy. She was also seeking a declaration that the Act was in breach of Art 14 for disproportionate use of s60 against black people in London.
Article 5 refers to ‘ liberty and security of person ‘ and specifies the circumstances in which deprivation of liberty can take place of which one of the most relevant to the case is the power of the police to detain an individual …show more content…

Lord Justice (LJ) Maurice Kay suggested (paragraph(para) 11), that subjection to the s60 does not involve ‘ a deprivation of liberty at all ‘ and referred to the DC’s judgment of LJ Moses (para 6) who said ‘ the question of the arbitrary nature of the power conferred by s60 ought properly to be considered in the context of Art 8 and not Art 5…I conclude that there was no deprivation of liberty ‘ to which LJ Kay also agreed.
Article 8 protects the right of an individual to a private life. Under circumstances of the case of Roberts it can be seen as causing ‘ humiliation and embarrassment to a person searched in a public place ‘ though marginally engaging Art 8 (para 15). It was emphasised that a balancing and proportionality required by Art 8(2) pursuant to s60 of the CJPOA 1994 was ‘in accordance with the law’ and relevant to the circumstances (para 16). The Court has also considered the outcome and referred to

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