- 17 A B - refused to give consent to relator proceedings. In answering the question in the negative, the House of Lords laid down important general principles on the use of civil injunctions in aid of the criminal law. C D A B B & Q and the line of authorities to follow saw an extension of this jurisprudence to cases in which local authorities applied for injunctions to restrain persistent C D breaches of local bye-laws: see for example, City of London Corp v Bovis E F Construction Ltd [1992] 3 All ER 697; 27 Portsmouth City Council v Richards [1989] 1 CMLR 673; Guildford BC v Hein [2005] BLGR 797; E F and Birmingham City Council v Shafi, [2009] 1 WLR 1961. G H G It is unanimously stressed in the authorities that the power to 26. H grant injunctions in aid of the criminal law must be exercised with great I caution. There are three overlapping primary reasons: J I J (1) K The injunctions sought are usually in identical or almost identical terms to the criminal law that they seek to aid. Because of the commonality, when an offender commits a L K L breach of the injunction, he would have also committed a M criminal offence. The prospect of him facing both the ensuing contempt proceedings and criminal trial may give rise N to difficulties. O N In Gouriet at p 481C-F, Lord Wilberforce acknowledged that granting civil injunctions in aid of the criminal law is an exceptional power confined, in practice, to P M O P cases where an offence is frequently repeated in disregard of Q an, usually, inadequate penalty or to cases of emergency. His Lordship pointed out that because of the difficulties R involving the justification for granting civil injunctions which S may attract sanctions more severe than the penalty which the T U V Q R S T 27 The judgment in Bovis was delivered on 18 April 1988. U V