Cardiff University secures landmark injunction to protect campus from unlawful encampments

In recent years, universities across the UK have seen a rise in unlawful encampments in university buildings and on their grounds. Institutions are increasingly turning to the courts to protect their property and operations against the risk of future unlawful occupation before the trespass takes place. Against this backdrop, Cardiff University instructed our team to pursue a precautionary injunction to prevent unlawful activity before it could occur.

The Court’s decision

We were instructed by Cardiff University in relation to an application for a precautionary injunction against Persons Unknown not yet on its land. On 13 June 2025, following a hearing held on 12 June 2025 in the Cardiff High Court, Sir Peter Lane granted the University a ‘final’ injunction (or more accurately, a ‘quasi-final’ injunction) against Persons Unknown, protecting 11 of its sites from future unlawful direct trespass and nuisance action by protestors.

Sir Peter Lane considered the requirements of Wolverhampton City Council v London Gypsies and Travellers [2023] UKSC 47 as recently summarised by Mr Justice Soole in University of Cambridge v Persons Unknown [2025] EWHC 724. Additionally, applying Valero Energy Limited v Persons Unknown [2024] EWHC 134, the Judge was satisfied that all legal criteria were met. Notably, he rejected the contention that the University was seeking a de facto campus wide injunction – the scope was confined to what was strictly necessary.

The Judge accepted that the University had met its duty of full and frank disclosure, and it should not be deprived of relief.

Another key aspect of the judgment was the proportionality analysis, which fell squarely in favour of granting the injunction. Crucially, the University land is private land and Articles 10 and 11 ECHR do not include a right to trespass on private land. Any purported interference with those Articles would be justified and proportionate in the circumstances. That was said to strike a fair balance between upholding the right of freedom of speech, whilst protecting the University’s legitimate property rights.

As a result, the Judge granted injunctions until the end of July 2026 in respect of 11 sites that formed part of the University campus, to be reviewed in 12 months’ time.

Key takeaway for landowners and institutions

This ruling underscores the Courts’ willingness to grant targeted, forward-looking injunctions where there is a real and credible risk of unlawful activity, even before it begins. It reinforces that private landowners—particularly educational institutions, can take pre-emptive legal steps to safeguard their property and operations against the threat of unlawful encampments.

Our expertise

The decision in this case builds on our established track record in this area, following our recent success in University of Birmingham v (1) Persons Unknown (2) Ali [2024] EWHC 1770. Our team continues to advise major institutions on obtaining urgent possession orders and ‘newcomer’ injunctions to deter trespassers.

Need further support?

If your organisation is facing potential action, we can help you act swiftly and decisively. Contact our litigation and property dispute specialists to discuss how injunctions and possession orders can protect your property rights.