On 11 November 2025, the Court of Appeal handed down a significant judgment in the case of Nadine Buzzard-Quashie v Chief Constable of Northamptonshire [2025] EWCA Civ 1397, in Ms Buzzard-Quashie successfully appealed the refusal of the County Court at Central London to hold the Chief Constable in contempt, in spite of the force’s admitted non-compliance with a court order. Today’s judgment of Fraser LJ, with whom Coulson LJ and Asplin LJ agreed, is significant, not only because it is the first time in UK history that a Chief Constable of a UK police force has been held in Contempt of Court, but also because of the vindication it gives to Ms Buzzard Quashie who, as recognised by the Court in the Judgment, has conducted herself with great perseverance and dignity throughout.
The case is remarkable, not only for the non-compliance of the force with the County Court’s order and the subsequent consequences, but also for the last-minute revelations in front of the Court of Appeal which revealed the even greater extent of the non-compliance for a period of nearly four years and lead the Court of Appeal to the conclusion that the Chief Constable was also in Contempt for false statements given to the Court of Appeal itself.
Background & the County Court Judgment
The matter originated from a Subject Access Request (SAR) made by Ms Buzzard Quashie to Northamptonshire Police following an alleged wrongful arrest in September 2021, during which she alleges she was assaulted and her property unlawfully seized and never returned. That wrongful arrest and matters consequential to it, are the subject of separate, ongoing litigation.
Northamptonshire Police failed to comply with the SAR and were subsequently ordered by Deputy District Judge Leong, sitting at Brentford County Court on 25 April 2023, to disclose any and all video footage taken on police cameras relevant to Ms Buzzard-Quashie’s arrest and detention within 28 days, or in the alternative provide a statement from an officer of rank no lower than Inspector to explain the absence of any such footage.
Northamptonshire Police again failed to comply, and therefore Ms Buzzard Quashie, acting as a litigant in person, brought contempt proceedings against the Chief Constable. The Chief Constable defended the force on the basis that it had supplied all footage it still retained, and the explanatory statement given by a civilian data officer was sufficient – despite her not being an Officer with the rank of Inspector or above. The application was heard by HHJ Genn in Central London County Court and on 11 April 2024, Judgment was handed down in which it was confirmed that Northamptonshire Police had not complied with the order. However, HHJ Genn declined to find the Chief Constable in Contempt, as she could not be sure that the Force had not supplied all the footage and she did not think they intended to breach the Order. She therefore dismissed the Application, and ordered Ms Buzzard-Quashie to pay the Chief Constable’s costs of the Application.
Ms Buzzard-Quashie appealed this Judgment on the basis, amongst other matters, that HHJ Genn had made an error of law in concluding that the conduct causing the breach had to be “wilful, deliberate or contumelious” in order to amount to Contempt and that the Chief Constable himself could not be held in Contempt of Court. On 14 January 2025, Lewison LJ granted permission to appeal on the basis that the appeal has a “real prospect of success”.
The Chief Constable’s Admissions
Despite initially resisting the Appeal on the basis the County Court’s decision was correct in law and fact, in the week leading up to the Appeal hearing, the Chief Constable conducted a data audit which revealed the existence of further footage that ought to have been disclosed pursuant to the County Court’s Order. This meant that numerous statements given on the Chief Constable’s behalf to both the County Court and the Court of Appeal were accordingly, false. Indeed, at Paragraph 40 of the Judgment, Fraser LJ lists at least 8 occasions in which untrue statements or information was given to the Court.
Consequently, the day before the Appeal hearing, the Chief Constable conceded the appeal and admitted he was in Contempt of Court. Although the Chief Constable’s concessions were sufficient for the Court to allow the appeal, with the Court, at Paragraph 42, referring the case he had advanced as being “wholly erroneous” , Fraser LJ, in giving the lead Judgment, made a number of important observations about the law in this field, including:
- That no intent to breach an order is required for a finding of contempt;
- The Chief Constable may be responsible for acts or omissions of others and can accordingly be held in Contempt;
- The lack of a penal notice on the County Court’s Order was no barrier to a finding of Contempt;
- In circumstances where the County Court had found the Chief Constable had breached the Order, it was wrong for them to order that Ms Buzzard-Quashie be liable for the Chief Constable’s costs.
Janes Solicitors will publish a further article explaining the conclusions on these legal points.
Ms Buzzard-Quashie’s Statement
Upon receiving the Judgment, Ms Buzzard-Quashie said the following:
““This case is not only about my right to access my own data. It is about accountability, truth, and ensuring that those in positions of power are not permitted to ignore the law with impunity. The Northamptonshire Police acted in an arrogant and high-handed manner by ignoring my requests for documents, as well as the findings of the Information Commissioner’s Office and a County Court order. It is astonishing that after four years I am still battling to get a frank, open and honest response about what they did to the evidence around my wrongful arrest and why.
I am elated that justice has finally prevailed within the Lordships Judgement, not just for me, but for all of the other little people that have been silenced or obstructed by institutional power. I hope that this Judgment, and whatever sanction may follow for the Chief Constable, serve as an important demonstration that no authority is above the law.”
Statement on behalf of Marc Livingston, Solicitor at Janes Solicitors LLP, who acted for Ms Buzzard-Quashie on the Appeal.
“Contempt of Court is an extremely serious matter. It is a matter of deep regret that throughout the history of this matter, Northamptonshire Police did not appear to have appreciated the position they were in and the duties they owed to the Court and my client. It is absolutely astonishing that the scale of their non-compliance only became clear in the two weeks before the Appeal Hearing, over 4 years after the incident, 2.5 years after DDJ’s Leong’s Order and nearly 18 months after the original County Court Contempt Hearing. The Court of Appeal decision vindicates Ms Buzzard Quashie taking the draconian steps she did and is a testament to her dignified persistence. I also want to pay tribute to my instructed counsel, Charlotte Elves and James Leonard KC of Outer Temple Chambers, who were both rightly singled out for praise by the Lord Justices.
Notes
There will be a further hearing on 20 November to determine what sanction the Chief Constable should face. This hearing will be live streamed on the Court of Appeal’s YouTube Channel
Ms Nadine Buzzard Quashie was represented for this appeal by:
- James Leonard KC of Outer Temple Chambers
- Charlotte Elves of Outer Temple Chambers
- Marc Livingston of Janes Solicitors LLP
Janes Solicitors specialist Contempt of Court department provides comprehensive legal advice and representation in both the lower and higher courts. We help clients navigate this specialist area of law, ensuring their rights are protected. Over the law few years our team has built up considerable experience acting in some of the leading Contempt of Court cases in the High Court and Court of Appeal, and we are proud of our position as one of the go-to firms in London and throughout the country in this area.
Fore more information and to learn about some of our previous cases, please visit our Contempt page on our website here.