Recommendation 14

We have significant concerns that large fixed penalties, such as those of £10,000, which are awarded irrespective of the individual’s circumstances, risk being inherently unjust. Given all that we know about the flaws in the system of enforcement of the coronavirus Regulations, it is woefully inadequate simply to assert that such FPN fines can be contested in the course of a criminal prosecution for those willing to run the risk of having a criminal record. This can seriously damage the future prospects of those convicted. Such an approach risks casualising criminality for so many, without any adequate appreciation of the significance or proportionality of such measures.