Daiichi v Stop Huntingdon Animal Cruelty [2004] 1 WLR 1503
Whether a company could be a victim of harassment under the Protection from Harassment Act 1997
Facts
A number of unincorporated groups and their supporters (S) who campaigned for the rights of animals targeted a campaign against Daiichi UK Ltd., (H) a company which experimented on live animals. As part of that campaign S targeted the corporate customers (D) of H. D sought injunctions under section 3 of the Protection from Harassment Act 1997 (1997 Act)to prohibit the conduct of S, which D alleged amounted to harassment under section 7 of the 1997 Act.
Issues
S claimed that companies could not be victims of harassment under the 1997 Act. The issue in question was thus whether a company could be a victim of harassment under the 1997 Act.
Decision/Outcome
A company could not be a victim of harassment under the 1997 Act which applies to persons and not corporate entities. While under the Interpretation Act 1928 the word “person” is usually to be understood as including a body of persons corporate or incorporate, the legislative history of the 1997 Act indicted that the Act could only apply to natural persons and not corporations. The application was granted in part, with the applications of the corporate claimants dismissed and the applications of the non-corporate applicants granted. Injunctive relief could be granted to the non-corporate applicants and the employees of the corporate applicants who were “persons” under the 1997 Act. It was found to be necessary for the proper protection of the non-corporate applicants to restrict the rights to freedom of speech and of assembly and association of S from unlawful harassment.
Updated 19 March 2026
This case summary remains broadly accurate. Daiichi UK Ltd v Stop Huntingdon Animal Cruelty [2004] 1 WLR 1503 correctly states the law as decided: companies cannot be victims of harassment under the Protection from Harassment Act 1997, which is confined to natural persons.
One minor inaccuracy worth noting: the article refers to the Interpretation Act 1928. The correct statute is the Interpretation Act 1978, which is the Act in force and which the court considered. This appears to be a typographical error in the article but does not affect the legal principle described.
Readers should be aware that following this decision, Parliament enacted the Serious Organised Crime and Police Act 2005, which introduced specific provisions (ss. 145–149) targeting harassment campaigns against companies and their associates connected with animal research — effectively responding to the legislative gap identified in cases such as this one. The 1997 Act itself has not been amended to extend protection to corporate bodies. The core holding of Daiichi on the scope of the 1997 Act therefore remains good law, but the 2005 Act is a significant statutory development that students researching this area should consult.
