Animal – Animal welfare. The Animal Welfare Act 2006 s 8(1)(h), which made it a criminal offence to keep or train an animal for use in connection with an animal fight, was to be interpreted to include those who had actual physical possession, as well as those who retained control of the animal whilst it was elsewhere. Accordingly, the Administrative Court dismissed the claimant's application for judicial review of the defendant court's refusal to state a case concerning her conviction for that offence.