Ultra-Violence on the Pitch: Establishing a Threshold for the Intervention of Criminal Law in English Football

Despite a steadily growing list of cases, there has been little guidanceand clarity as to when it is appropriate to pursue criminal charges in cases of on-field participator violence in English football. While the Barnes Court of Appealruling in 2004gave some lawyers, legal scholars, and sport administrators hope that a threshold of criminality had been established, more recent casessuch as Ward in 2009 and Chapman in 2010 have cast doubt on the authority of Barnes. In so doing, doubt has been cast on where a threshold of criminality might lie in cases of on-field participator violence in England. This article critically examines potential test criteria that could be used in determining an appropriate threshold for the intervention of criminal law in English football.