As there were no clear rules to follow in serving and adducing evidence, especially hearsay evidence, in support of applications for anti-social behaviour orders under the Crime and Disorder Act 1998 s.1C in the Crown Court, the court presumed that hearsay evidence was capable of being adduced in the Crown Court in support of such applications, as the proceedings were civil in nature and thus subject to the provisions of the Civil Evidence Act 1995. In the instant case a proper procedure was not followed and, in the absence of any specific findings of fact as to anti-social behaviour, the decision that ASBOs were necessary could not be upheld.

[2006] EWCA Crim 686