It was appropriate in the interest of proportionality to reduce the fine imposed on a rail track maintenance contractor for its failure to discharge its duty as an employer under the Health and Safety at Work etc. Act 1974 s.3, which was a cause of the Hatfield rail disaster, where there was a huge disparity between the fine imposed on the contractor and the fine imposed on the co-defendant rail network owner.

[2006] EWCA Crim 1586