Buzzard‑Quashie v Northamptonshire Police: Contempt Sanctions for Chief Constables and the Non‑Optional Nature of Court Orders

1. Introduction

This commentary examines the Court of Appeal’s sanctions judgment in Buzzard‑Quashie v Northamptonshire Police [2025] EWCA Civ 1502, following the earlier substantive appeal judgment in [2025] EWCA Civ 1397.

The case arises out of the arrest of Ms Buzzard‑Quashie in September 2021 and the subsequent civil proceedings in which Northamptonshire Police:

• failed over a very extended period to comply with disclosure orders for video evidence of the arrest;
• adopted and persisted in a factual position later revealed to be false;
• breached both County Court and Court of Appeal orders, culminating in a finding of contempt.

The sanctions judgment deals with the appropriate punishment for the Chief Constable, who stood as defendant in his official capacity. The Court had to decide:

• whether the Chief Constable should be committed to prison for contempt;
• whether a fine or other sanction should be imposed; and
• how to treat contempt committed by a senior public office‑holder, compared to a private individual.

In doing so, the Court elaborates important principles on:

• the non‑optional nature of compliance with Court of Appeal orders;
• the sanctioning of public authorities and their heads for contempt of court;
• the limited — but real — scope for committal of Chief Constables acting in an official capacity;
• the appropriateness of a substantial fine against a police force, despite the impact on public funds.

The Court ultimately imposed a £50,000 fine on the Chief Constable, rejecting both the argument that mere declaration of contempt was sufficient and the argument that imprisonment was appropriate on these facts.

2. Factual and Procedural Background (in Outline)

The sanctions judgment expressly relies on the earlier substantive judgment ([2025] EWCA Civ 1397, sections B–C at [13]–[42]) for the full factual background, which is not reproduced here. From the sanctions judgment itself, the key points are:

2.1 The April 23 Order and Non‑Disclosure of Video

On 25 April 2023, Deputy District Judge (DDJ) Leong made an order (the “April 23 Order”), including a requirement (paragraph 3) to disclose certain video footage. That order remained uncomplied with for a prolonged period:

• By the time of the Chief Constable’s second statement (19 November 2025), he accepted he was still in breach of paragraph 3 of the April 23 Order and that this was a continuing breach with no excuse ([15]).
• Only on 19 November 2025 was the April 23 Order finally said to have been complied with, although the appellant’s counsel still raised arguable points of non‑compliance ([9(1)]).

Critically, the second statement accepts that five video clips that clearly existed were never disclosed until October 2025 or after the appeal hearing on 22 October 2025 ([14]):

• McKitton 2
• McKitton 4 (almost 3 minutes)
• Rideout 1
• Rideout 2 (6 minutes)
• Virtue 2 (20 minutes)

These late‑disclosed clips were not trivial; at least one of them entirely vindicated Ms Buzzard‑Quashie’s factual account of aspects of her arrest ([9(4)]). The audit log showed that:

• at least one deponent viewed the relevant video; yet
• that same person later swore a witness statement asserting that the video did not exist.

This goes well beyond mere administrative oversight and underpins the gravity of the contempt.

2.2 The Court of Appeal’s Order of 22 October 2025

On 22 October 2025, after allowing the substantive appeal, the Court of Appeal made a detailed order, including ([3]) a requirement for witness statements to be lodged by 4pm on 5 November 2025. The order:

• set a clearly discussed and agreed deadline;
• specified exactly what the statements had to cover; and
• was sealed on 28 October 2025.

The draft substantive judgment, circulated to the parties before that deadline, contained an explicit warning at paragraph [38]:

“Compliance with those orders by the Chief Constable is not, for the avoidance of doubt, in any way optional.”

Despite this:

• The 5 November 2025 deadline was not complied with.
• A few minutes before the deadline, an email was sent to the appellant’s solicitors seeking an extension, but crucially:
• no application was made to the Court of Appeal itself; and
• no communication at all was sent to the Court ([5]).
• Both mandated witness statements — including one by the Chief Constable — were served hours late.
• The second Hillery statement (“Hillery 2”), dealing with steps taken regarding each video clip, was found to be inadequate ([5]).
• The important letter of apology by the Chief Constable, previously given to his solicitor, was never sent to the Court ([5]).

The cumulative picture was one of ongoing disregard for court orders, even after the contempt had already been acknowledged.

2.3 Escalation and Change of Representation

After the appellant’s solicitors wrote on 7 November 2025 to flag the various deficiencies, the Chief Constable’s new solicitor, Mr Turner (Head of Legal Services, East Midlands Police Legal Services), wrote to the Court on 13 November 2025 stating that the Chief Constable was:

“not in a position to rely upon the two witness statements … [Hillery 1 and Hillery 2]. I do not feel able to explain the reason for this (which is fundamental) but would wish to say that the [Chief Constable] and his lawyers fully appreciate, and profoundly regret, that this puts him in further breach”

of both the Court of Appeal’s order of 28 October 2025 and paragraph 3 of DDJ Leong’s order of 25 April 2023 ([6]).

The Court then:

• ordered a sanctions hearing for 20 November 2025 ([7]);
• indicated that breaches of the Court of Appeal’s order would be considered and taken into account when determining sanction for contempt; and
• notified the parties both by email and by an order dated 11 November 2025.

On 19 November 2025 — the day before the sanctions hearing — a large volume of new material was served, including:

• a second witness statement from the Chief Constable (with a fuller apology and narrative);
• a witness statement from the Deputy Chief Constable, Mr Ashley Tuckley; and
• further witness statements from:
  • Mr Gray (Crime and Incident Registrar);
  • Chief Inspector Britton (Custody operations);
  • Police Sergeant Gill (Chief Driving Instructor, dealing with dashcam footage).

These statements came too late to be addressed in the appellant’s skeleton argument ([8]), though counsel dealt with them orally.

2.4 Referral to the IOPC and Personal Apology

Recognising the seriousness of what had occurred, the Chief Constable:

• referred the entirety of the matter — including events after the first Court of Appeal hearing — to the Independent Office for Police Conduct (IOPC) ([9(6)]); and
• appeared in person at the sanctions hearing, apologising to:
  • Ms Buzzard‑Quashie;
  • the County Court; and
  • the Court of Appeal ([10], [16]).

Nonetheless, the Court emphasised that:

• there had already been a “litany” of breaches of court orders, forming the basis for the contempt;
• it was “extraordinary” that similar conduct continued even after a finding of contempt ([11]); and
• the impact on the successful appellant had been “profound” in personal, emotional and financial terms ([13]).

3. Summary of the Sanctions Judgment

The Court of Appeal (with Lord Justice Coulson and Lady Justice Asplin agreeing at [25]–[26]) reaches the following key conclusions:

1. Imprisonment (committal) of the Chief Constable is not appropriate in this case.
   • If a private individual had breached court orders in this way, a term of imprisonment for contempt would “undoubtedly” have been justified ([22]).
   • However, the Chief Constable is sued and held liable in his official capacity; most failings were committed by others acting on his behalf; and so, on these facts:
     • imprisonment is considered “both unavailable as a matter of principle” and
     • “unnecessary” ([22]).
   • The Court notes that imprisonment of a Chief Constable for contempt in an official capacity would be “highly exceptional, and very unusual and difficult” ([19]).
2. At the same time, a mere finding of contempt is insufficient.
   • The extensive and prolonged breaches of court orders — both in the County Court and Court of Appeal — justify a further sanction beyond the declaration of contempt ([23]).
   • Aggravating factors include:
     • the very long duration of non‑compliance;
     • repetition of inaccurate and incorrect statements by multiple personnel;
     • failure to change approach even after the contempt was admitted on 22 October 2025 ([21], [23]).
3. A substantial fine of £50,000 is imposed on the Chief Constable.
   • The Court recognises that police forces are publicly funded and that fines draw money away from front‑line policing ([23]).
   • However, it regards a significant fine as necessary to:
     • mark the seriousness of the contempt; and
     • vindicate the rule of law, particularly given the police’s role in upholding it.
   • £50,000 is said to “properly reflect the gravity of the situation” while recognising the impact on the Northamptonshire Police budget ([24]).
4. The Court rejects two specific analogies advanced for leniency.
   • The analogy with M v Home Office — treating the Chief Constable as equivalent to a Minister of the Crown — is not fully accepted ([19], [22]).
   • The analogy with R (Bempoa) v London Borough of Southwark, where a finding of contempt alone was held to be sufficient, is held to be inapposite ([21]).

The resulting precedent is an important one for contempt by police forces and their leaders, clarifying both the limited scope for committal and the readiness of the Court to impose substantial financial sanctions where necessary.

4. Precedents and Statutory Context

4.1 M v Home Office [1994] 1 AC 377

Counsel for the Chief Constable relied heavily on M v Home Office, a seminal House of Lords case on contempt proceedings against Ministers of the Crown. In that case:

• The Home Secretary failed to comply with a court order (and undertaking) concerning the removal and re‑admission of an asylum seeker.
• The House of Lords held that the Crown and Ministers are not above the law, and can be the subject of contempt findings.

Two passages from Lord Woolf are central to the present judgment.

At 425, Lord Woolf emphasised that:

“In addition the object of the exercise is not so much to punish an individual as to vindicate the rule of law by a finding of contempt. This can be achieved equally by a declaratory finding of the court as to the contempt against the minister as representing the department. By making the finding against the minister in his official capacity the court will be indicating that it is the department for which the minister is responsible which has been guilty of contempt. The minister himself may or may not have been personally guilty of contempt.”

At 427, he continued:

“While he was Home Secretary the order was one binding upon him personally and one for the compliance with which he as the head of the department was personally responsible. He was, therefore, under a strict liability to comply with the order. However, on the facts of this case I have little doubt that if the Court of Appeal had appreciated that they could make a finding against Mr. Baker in his official capacity this is what the court would have done. The conduct complained of in this case which justified the bringing of contempt proceedings was not that of Mr. Baker alone and he was acting on advice. His error was understandable and I accept that there is an element of unfairness in the finding against him personally.”

From M v Home Office, two key ideas emerge:

• The purpose of contempt proceedings against a Minister is primarily to vindicate the rule of law, rather than to punish personally.
• A finding of contempt against a Minister in his official capacity may be sufficient, without necessarily resorting to personal punishment such as imprisonment.

In Buzzard‑Quashie, counsel sought to analogise the position of the Chief Constable with that of a Minister of the Crown, arguing that:

• the Chief Constable is in a similar constitutional position as the head of a public authority; and
• it would be wrong in principle to commit him to prison, just as it was viewed with caution in the ministerial context.

The Court accepts part of this structural analogy — in recognising the official capacity nature of the Chief Constable’s liability and the primary aim of vindicating the rule of law — but it stops short of equating Chief Constables with Ministers for all purposes.

4.2 R (Bempoa) v London Borough of Southwark [2002] EWHC 153 (Admin)

Counsel also relied on a line of first‑instance authorities where the court held that a finding of contempt was sufficient punishment, including the judgment of Munby J (as he then was) in R (Bempoa) v Southwark LBC.

In Bempoa:

• the local authority had evicted a tenant six days after its solicitor had given a clear undertaking to the court that it would not do so;
• when the solicitor discovered the breach and advised reinstatement, the housing department refused to comply;
• despite the seriousness of the breach, Munby J concluded that the gravity of the contempt could be adequately marked by a public judgment alone, and imposed no further sanction ([20], citing [53] of Bempoa).

In Buzzard‑Quashie, the Court of Appeal rejects the analogy with Bempoa as inapposite ([21]):

• A Chief Constable occupies a position “wholly different” from a local authority housing department, precisely because of the police’s constitutional role in upholding the rule of law ([21]).
• The underlying facts here involve an arrest, directly implicating the individual’s liberty interest, unlike the landlord‑tenant context in Bempoa ([21]).
• Most importantly, in Buzzard‑Quashie:
  • the Chief Constable had already admitted contempt on 22 October 2025, recognising that the appeal could not be contested on the facts; yet
  • this did not produce a “sea change” in approach to compliance with court orders ([21]).

The Court therefore holds that, unlike in Bempoa, a public judgment alone is not enough to mark the seriousness of this contempt.

4.3 Statutory Framework: Ministers v Chief Constables

In addressing the analogy with M v Home Office, the Court notes that a full analysis would require working through:

• the Crown Proceedings Act 1947 and the dicta in M v Home Office relating to Ministers of the Crown; and
• the status of a Chief Constable, from the original County Police Act 1839 to the present framework under the Police Reform and Social Responsibility Act 2011 (“the 2011 Act”) ([19]).

Under the 2011 Act:

• Police and Crime Commissioners (PCCs) are created as elected officials;
• PCCs appoint Chief Constables, replacing the previous model of police authorities;
• section 2(2) and Schedule 2 paragraph 2 deal with the appointment, accountability, and legal status of Chief Constables.

The Court explicitly states that it has not heard full argument on whether Chief Constables are properly analogous to Ministers in all relevant respects, and that such an analysis is not necessary to decide this case ([19]). The key practical point is:

• Chief Constables are senior public officers with institutional responsibility, but their legal and constitutional status is not identical to that of Ministers of the Crown; and
• the Court is therefore cautious about transposing the ministerial contempt model wholesale.

5. The Court’s Legal Reasoning

5.1 Gravity of the Contempt and Aggravating Features

The Court’s assessment of sanction starts from a clear recognition of exceptional gravity. Key aggravating factors include:

• Prolonged non‑compliance:
  • Failure to comply with the April 23 Order from 2023 through to November 2025;
  • Failure to comply with the Court of Appeal’s own order, issued 22 October and sealed 28 October 2025.
• Repetition of false or inaccurate statements:
  • The audit trail shows critical video footage was viewed but later denied on oath ([9(4)]);
  • Hillery 2 was inadequate; evidence from Ms Kightely‑Jones later became unreliable ([10], [12]).
• Continuation of disobedience even after admission of contempt:
  • The “litany of breach” that formed the basis for the original contempt continued even after 22 October 2025;
  • This is “extraordinary” in light of the apology and the explicit warning that compliance was “not optional” ([11]).
• Serious impact on the appellant:
  • Her witness statement of 24 October 2025 describes profound personal, emotional and financial costs;
  • The late‑disclosed footage is highly significant to her account of an arrest involving deprivation of liberty ([13]).

The Court also notes that “actions speak somewhat louder than words” ([11]): apologies and expressions of regret are weighed against the objective pattern of continued disobedience.

5.2 Official vs Personal Capacity and Vicarious Responsibility

A central theme is the distinction between:

• the Chief Constable’s official capacity as head of the police force; and
• his personal culpability for specific acts of disobedience.

The Court finds that:

• The Chief Constable is vicariously responsible for what those in the force and legal team did on his behalf ([22]).
• “The vast majority of what has occurred has been done by those who act on his behalf, not by him in his personal capacity” ([22]).

Nonetheless:

• As head of the force, he bears ultimate responsibility for compliance with court orders;
• He properly stands as the defendant in contempt proceedings, just as a Minister would on behalf of a department.

This reasoning tracks the approach in M v Home Office, but the Court stops short of a purely declaratory remedy: the Chief Constable cannot shelter behind the errors of his subordinates. Instead, his status both:

• protects him from personal imprisonment (on these facts); but
• exposes the force to a substantial financial sanction as the institutional response.

5.3 Why Committal Was Rejected

The Court’s rejection of committal (imprisonment) is nuanced.

On the one hand, the Court is explicit:

• “Were a private individual to have breached court orders in the way that has occurred in this case, I would undoubtedly consider that to justify a term of imprisonment upon the contemnor.” ([22])

On the other hand, in relation to the Chief Constable:

• It would be “highly exceptional, and very unusual and difficult” to imprison “an official such as a Chief Constable” for contempt committed in an official capacity ([19]).
• On the specific facts, imprisonment is said to be:
  • “unavailable as a matter of principle”; and
  • “unnecessary” ([22]).

Two strands of reasoning support this:

1. Principled limitation on imprisoning senior public officials for official‑capacity contempts:
   • The Court draws from M v Home Office the idea that the primary object of contempt proceedings against public office‑holders is vindication of the rule of law, not personal punishment.
   • Imprisonment of a Chief Constable — particularly for systemic failures by subordinates — would mark a deeply exceptional step in the constitutional relationship between the courts and the police.
2. Case‑specific factors:
   • There has (belatedly) been fuller compliance and disclosure;
   • The Chief Constable has provided a fuller, more candid second statement and appeared in person to apologise;
   • The matter has been referred to the IOPC for independent investigation;
   • There has been a complete change of legal team and evidential approach, signalling an attempt to rectify matters ([9(3)–(5)], [10]).

On this combination of constitutional and factual considerations, the Court finds that imprisonment is neither appropriate nor necessary—while stressing that this would not have been the conclusion for a private litigant.

5.4 Justification for a £50,000 Fine

Having rejected committal and the “finding only” approach, the Court turns to the question of financial sanctions.

Several points are made:

• The Court is keenly aware that a fine against a police force diverts public funds from front‑line policing ([23]).
• Nonetheless, the seriousness of this contempt requires a sanction that:
  • goes beyond symbolic condemnation;
  • adequately reflects the duration, pattern and impact of non‑compliance; and
  • deters similar conduct and underscores the obligation of public bodies to obey court orders.

The Court therefore imposes a £50,000 fine ([24]), expressly noting that this sum:

• “properly reflects the gravity of the situation”; and
• takes account of the fact that funds will have to come from the Northamptonshire Police budget.

Although the judgment does not set out a formal tariff or matrix for contempt fines against public bodies, the size and reasoning indicate:

• a willingness to impose substantial six‑figure‑adjacent penalties on police forces where there has been prolonged and egregious contempt; and
• a recognition that the need to vindicate the rule of law can override concerns about the indirect burden on local policing resources.

5.5 The Non‑Optional Nature of Court Orders and Procedural Discipline

Alongside the specific sanction, the judgment lays down firm guidance on procedural discipline in the Court of Appeal:

• Compliance with a Court of Appeal order is never optional. The Court had already spelled this out in the draft judgment: “for the avoidance of doubt” compliance was “not in any way optional” ([4]).
• Nor can the parties “vary” a Court of Appeal order by agreement between themselves:
  • “A party to litigation cannot vary an order of this court by agreement.” ([5]);
  • any extension or change must be sought from the Court by appropriate application.
• Informal correspondence to opposing solicitors, without notifying or applying to the Court, is insufficient to protect a party from being in breach.

The message to litigants, particularly institutional litigants and their legal teams, is clear: court orders – especially from the Court of Appeal – are to be treated as binding commands, not flexible suggestions.

6. Impact and Prospective Significance

6.1 For Police Forces and Chief Constables

The implications for policing are profound:

• Enhanced accountability: Chief Constables can face both:
  • a formal finding of contempt; and
  • substantial fines, payable from force budgets,
  where their forces systematically disobey court orders.
• Systemic scrutiny: The referral to the IOPC and the need to deploy “entirely new personnel” to provide evidence suggest that:
  • misconduct or mismanagement in evidence handling (especially video) will attract serious judicial criticism;
  • forces must have robust systems for locating, preserving and disclosing digital evidence.
• Deterrent effect: Other forces are put on notice that:
  • failure to comply with disclosure orders, particularly where liberty‑implicating arrests are concerned, may result in large financial penalties; and
  • late, piecemeal compliance and belated apologies will not immunise them from sanctions.

6.2 For Public Authorities More Generally

Beyond policing, the judgment sends signals to all public bodies:

• Courts will not treat public authorities as immune from meaningful sanctions simply because they are publicly funded.
• At the same time, conviction and imprisonment of senior officials in their official capacity will remain exceptional, but:
  • substantial fines,
  • public judgments naming the authority, and
  • referral to oversight bodies (e.g. IOPC, Ombudsmen)
  are to be expected where court orders are flouted.
• The judgment distinguishes between:
  • truth‑seeking procedural failures (e.g. bureaucratic delay); and
  • active misrepresentation and non‑disclosure, particularly of exculpatory evidence.
  The latter will invite far sterner sanctions.

6.3 For Contempt Jurisprudence

The case refines the law of contempt in three main ways:

1. Clarifying the status of senior public officials:
   • It confirms that contempt findings can properly be made against a Chief Constable in an official capacity, drawing on the logic of M v Home Office.
   • It strongly suggests that imprisonment of such an official for official‑capacity contempt will be reserved for “highly exceptional” cases ([19]).
2. Confirming fines as a serious but proportionate sanction against public bodies:
   • The Court recognises budgetary impact but nonetheless imposes a £50,000 fine to reflect gravity and uphold the rule of law;
   • This may serve as a reference point in future for the scale of fines suitable where there has been long‑term, systemic non‑compliance coupled with misleading evidence.
3. Reinforcing procedural orthodoxy in appellate litigation:
   • The judgment makes it unmistakable that parties cannot alter or delay compliance with Court of Appeal orders by private agreement ([5]).
   • Future litigants and lawyers will be hard‑pressed to argue they believed compliance was “optional” or that informal correspondence sufficed.

6.4 For Individual Litigants and Access to Justice

The judgment also has a wider justice‑system dimension:

• The Court expressly acknowledges that it was only through:
  • the “tenacity and resilience” of Ms Buzzard‑Quashie; and
  • the grant of permission to appeal by Lewison LJ “on points of law only”;
  that the long‑standing false factual position taken by the police was uncovered ([13]).
• This underlines the importance of:
  • robust appellate scrutiny of lower‑court findings, particularly where public authorities are concerned; and
  • the need for litigants to have the resources and support to pursue appeals and disclosure disputes.

7. Complex Concepts Simplified

7.1 Contempt of Court

Contempt of court is conduct that disobeys or shows disrespect for a court’s authority or orders. In civil proceedings like this:

• The typical contempt is breach of a court order (e.g. failing to disclose documents as ordered).
• The purpose of contempt jurisdiction is:
  • to enforce compliance with orders; and
  • to vindicate the authority of the court and the rule of law.

Sanctions for contempt can include:

• Committal to prison;
• Fines;
• Sequestration of assets (rare);
• A formal finding of contempt without additional punishment (in some cases).

7.2 Committal

Committal is the technical term for imprisoning a person as punishment for contempt. It is:

• a serious sanction of last resort;
• normally reserved for wilful, deliberate, serious or repeated breaches where lesser sanctions would be inadequate.

In the present case, the Court says it would have imprisoned a private individual who behaved in this way, but declines to do so for a Chief Constable acting in an official capacity.

7.3 Official vs Personal Capacity

When a Minister or a Chief Constable is sued, they may be:

• acting in their official capacity — representing a department or institution; or
• acting in a personal capacity — as an individual (less common in public law contexts).

Here, the contempt is tied to the institutional conduct of Northamptonshire Police:

• The Chief Constable is responsible for the force’s compliance, even where he did not personally make all the decisions or errors.
• Sanction is therefore directed at the office and institution, rather than at the individual as a private citizen.

7.4 Vicarious Responsibility in this Context

In this setting, vicarious responsibility means that:

• the Chief Constable is answerable for the acts and omissions of the officers and staff of Northamptonshire Police;
• failures by solicitors, officers handling video evidence, or other staff are legally attributable to the Chief Constable.

This does not mean he personally did everything wrong, but that the institution he heads is held to account through him in litigation.

7.5 The IOPC

The Independent Office for Police Conduct (IOPC) is the statutory body responsible for overseeing the police complaints system in England and Wales. Referral to the IOPC:

• triggers independent investigation into potential police misconduct or systemic failings;
• is particularly appropriate where there are allegations that:
  • evidence was concealed or mishandled; or
  • false witness statements were given in court proceedings.

In this case, the Chief Constable referred the matter, including events after the first Court of Appeal hearing, to the IOPC, signalling that the force accepts that serious internal investigation is required ([9(6)]).

8. Conclusion

Buzzard‑Quashie v Northamptonshire Police [2025] EWCA Civ 1502 is a significant addition to contempt jurisprudence and to the law governing public authority compliance with court orders.

Its key contributions can be summarised as follows:

• Non‑optional compliance with appellate orders: The Court of Appeal reinforces that its orders cannot be treated as flexible or varied by private agreement. Any variation requires a formal application to the Court.
• Heightened expectations of police forces: Given their role in upholding the rule of law, police forces face particularly severe criticism when they flout orders, especially in cases concerning the deprivation of liberty and the concealment or non‑disclosure of exculpatory evidence.
• Refined approach to sanctions against senior public officials:
  • Imprisonment of a Chief Constable for official‑capacity contempt will be highly exceptional;
  • yet contempt findings will be backed, where appropriate, by substantial financial penalties even in the face of public funding concerns.
• Rule of law vindication over administrative convenience: The Court gives clear priority to vindicating the rule of law and the integrity of the judicial process, even at the cost of imposing a £50,000 burden on a police budget.
• Recognition of individual perseverance: The Court acknowledges the tenacity of Ms Buzzard‑Quashie and the importance of appellate oversight in exposing systemic misrepresentation by a public authority.

In doctrinal terms, the judgment sits at the intersection of M v Home Office (contempt by Ministers) and first‑instance cases like Bempoa (where a declaration was sufficient), but it carves out a distinct path for Chief Constables and police forces. It makes plain that:

• while the courts will be cautious about imprisoning senior officials for official‑capacity contempts,
• they will not hesitate to impose meaningful, financially painful sanctions where the justice system has been undermined by persistent disobedience and misrepresentation.

As such, Buzzard‑Quashie is likely to serve as a leading authority on sanctions for contempt committed by senior policing figures, and more broadly as a warning to public bodies that the obedience they expect from citizens is equally demanded of them by the courts.