Criminal law – Defence. The Divisional Court refused the claimant's application for a declaration that the effect of the 'householder's defence' in s 76(5A) of the Criminal Justice and Immigration Act 2008 was incompatible with art 2 of the European Convention on Human Rights. Section 76(5A) of the Act did not direct that any degree of force less than grossly disproportionate was reasonable and there were reasonable safeguards against the commission of offences against the person in householder cases.