Chapter Updates

Chapter 12: Introduction to criminal liability

Grievous bodily harm on the football pitch

As the case of R v Barnes (2005) illustrates (see textbook, p253), the courts are cautious about imposing criminal liability for conduct during a sporting fixture. However, the case of R v Cotterill (2007) provides a clear–cut example of grievous bodily harm on the football pitch: Cotterill, a player for Barrow AFC, had punched Rigg, of Bristol Rovers, during a first round FA Cup match, causing him grievous bodily harm (a fractured jaw). Rigg had been walking away when Cotterill attacked him from behind. The incident was captured on film by BBC’s Match of the Day, which was covering the match. Cotterill pleaded guilty to the charge and was sentenced to four months’ imprisonment. Judge Robert Brown, at Preston Crown Court, stressed that this sort of violence in an off–the–ball incident constituted a serious criminal offence for which a custodial sentence was inevitably required. It might be concluded, therefore, that Cotterill’s conduct was as the Criminal Court of Appeal in Barnes had envisaged: ‘sufficiently grave to be properly categorised as criminal’.