- 19 A - should be the means of enforcing compliance with a statute, the reasons for using the power with caution are plain and B A B were fully explained by their Lordships in Gouriet; and the C criminal law should ordinarily be pursued as the primary means of enforcement. In a similar vein, Sir Anthony Clarke D C D MR and Rix LJ in Shafi at [36] pointed out that the principles E governing the grant of injunctions in aid of the criminal law are subject to any legislation which is designed to deal with F E F the very situation which an injunction is sought to control. G H G In Bovis, in the context of a local authority seeking to enforce 27. H the criminal law by civil injunctions, Bingham LJ, after reviewing the I J K earlier authorities including Gouriet and B & Q, stated at p 714g-j three guiding principles: (1) L M (2) The jurisdiction is to be invoked and exercised exceptionally J K and with great caution. L There must certainly be something more than mere M infringement of the criminal law before the assistance of civil N I N proceedings can be invoked and accorded for the protection or promotion of the interests of the inhabitants of the area. O P Q (3) The essential foundation for the exercise of the court’s discretion to grant an injunction is not that the offender is O P Q deliberately and flagrantly flouting the law but the need to R S T draw the inference that the defendant’s unlawful operations will continue unless and until effectively restrained by the law and that nothing short of an injunction will be effective to restrain them. R S T U U V V