R v Palmer

Court of Appeal (Crim Div), Lord Justice Simon, Mr Justice Haddon-Cave and HHJ Zeidman QC, 7; 28 July 2016

Confiscation proceedings - Engaging in unlicensed supply of private security - Private Security Industry Act 2001, section 3 - Whether "criminal conduct" within the meaning of the Proceeds of Crime Act 2002 - Whether confiscation available

The respondent offender, Palmer, operated a business which supplied private security. Among the services provided was "manned guarding" in respect of which no licence had been granted by the Security Industry Authority. Engaging in such conduct involved the commission of a summary only offence contrary to section 3 of the Private Security Industry Act 2001. Section 3 provides: "it shall be an offence for a person to engage in licensable conduct except under and in accordance with a licence".