Love v Government of the United States of America
[2018] EWHC 172 (Admin)
Ratio Decidendi
The forum bar under s.19B Extradition Act 2003 can prevent extradition where a substantial measure of the criminal activity occurred in the UK and extradition would not be in the interests of justice.
ข้อเท็จจริง
Lauri Love was accused of hacking into US government computer systems. The US sought his extradition. Love argued the forum bar applied as the alleged offences could be tried in England.
สรุปคำพิพากษา
The court refused extradition under the forum bar. A substantial measure of the activity took place in the UK, and it was in the interests of justice for the case to be tried in England, particularly given Love's mental health.
คำกล่าวสำคัญ
"The forum bar requires consideration of where the interests of justice are best served."
— Lord Burnett CJ
การอ้างอิงภายหลัง
Applied in subsequent forum bar cases under the Extradition Act.