Terence Robert Maguire [2019] EWCA Crim 1193

The appellant pleaded guilty to two offences of assault occasioning accrual bodily harm and one of controlling or coercive behaviour and was sentenced to a total of 4 years imprisonment. He appealed against the imposition of a criminal behaviour order requiring him to notify his local police station of the name of any new partner within 14 days of commencing an intimate relationship. He conceded that a clause requiring him to inform the police where he was living was necessary and proportionate in the context of the history of domestic abuse.

Held: the terms of the clause were not sufficiently clear, what is meant by ‘relationship’, when is one formed such as to trigger an obligation?  A new formulation was settled, and the appellant must “inform the local police of the name and address of any female (excluding family members) with whom he resides for a period of 14 days or more (consecutive or otherwise)”. The length of the order, 15 years, was reasonable given the risk he posed having displayed very concerning behaviour towards women.