[2025] EWCA Crim 1320

The relationship requirement

This was also a positive requirement and therefore subject to section 347A. Again, there was no evidence from the offender manager to support this requirement. In any event, we consider that the requirement was vague in that it failed to identify what sort of relationship must be reported and at what stage after meeting a person the obligation is said to arise. Again the requirement is unlimited in time, and apparently will apply long after the appellant has an offender manager allocated to his case. Such a vague, wide-ranging and unlimited requirement was not necessary. Further, its imposition and the attendant risk of criminal liability for its breach were oppressive and disproportionate.