FROM WILD JUSTICE ON BREACHES OF LAW ON GAME BIRD RELEASES IN SUFFOLK

Good morning! Today’s newsletter is a special edition, bringing you an update on our ongoing investigations into the world of gamebird releases. We’ve been busy, both on the ground and digitally, scrutinising the complex and somewhat murky world of gamebird (Pheasant and Red-legged Partridge) releases around protected sites. Today we can tell you we’ve found another case of unlawful gamebird release, as well as associated non-compliance with mandatory biosecurity measures, at a site that might be familiar to many of you... You can read a full-length blog about our findings here, complete with more photo evidence and maps. Read on for a shorter summary of this case. The beginning 2020: Wild Justice wins a legal challenge against Defra, forcing it to introduce a licensing scheme for the release of gamebirds near sites protected for wildlife (Natura 2000 sites). 2021: General Licence 43 (GL43) is introduced for shoot operators wishing to release gamebirds on or near (within a 500m buffer zone) Special Areas of Conservation (SACs). Shoot operators wanting to release birds on Special Protection Areas (SPAs) still require individual licences. 2023: Wild Justice wins a legal challenge, after showing that individual licences granted by Defra Ministers for gamebird releases on or near the Deben Estuary SPA in Suffolk and the Breckland SPA in Norfolk was contrary to Natural England’s (NE) formal advice. 2024: General Licence 45 (GL45) is introduced for shoot operators wanting to release gamebirds on or close to Special Protection Areas (SPAs). March 2025: Defra announced it would not be issuing General Licence 45 for the 2025 shooting season, meaning shoots wanting to release gamebirds on or near SPAs in 2025 would require individual licences once again. This was because of the heightened risk of transmitting Highly Pathogenic Avian Influenza (HPAI). April 2025: Natural England take this a step further and advise that some licences are likely to only be permitted with a delayed release date for gamebirds, if permitted at all. August 2025: The UK’s Chief Veterinary Officer announces new mandatory biosecurity measures to counter the heightened risk of HPAI in England. These measures include requirements such as disinfectant regimes, cleaning and hygiene of feeding and water stations, pens and apparatus, removal of dead gamebirds and reporting of dead wild birds. Back to the Deben Estuary - a tip off In August 2025, Wild Justice received a tip off from a supporter at Ramsholt, next to the Deben Estuary in Suffolk. He was familiar with our case in 2023, and so alarm bells started ringing when he saw lots of young Pheasants and Red-legged Partridges running around the site. After seeing his photos and a grid reference of a Red-legged Partridge release pen, we reckoned the gamebirds were being released within 500m of the Deben Estuary SPA. Asking questions: Curious, we got in touch with Natural England, asking them a few questions, including: Had an individual licence to release gamebirds on or near this SPA been issued for the 2025/26 shooting season? If so, on what grounds had it been approved? Could NE provide us with copies of any licence applications for 2025 at this site, and any subsequent licences issued. And then we waited. Heading into the field Whilst waiting for a reply from NE, Wild Justice headed into the field. Over several visits to Ramsholt in August and September, we found: A second Red-legged Partridge (RLP) release pen (about 1km away from the one reported by our supporter). A huge open-topped Pheasant release pen. Four different gamebird feeding stations. Lots and lots of free-roaming gamebirds. No evidence of disinfection procedures (e.g. for vehicles using the site). Dirty water stations at the release pens, as well as spilled food which remained present between our visits. A decomposing RLP in the second release pen. Suspicious findings: Recording grid references for each of our findings, we headed back to our desks, and discovered: The first RLP release pen was within the 500m buffer zone of the SPA. Conclusion:licence required. The second RLP release pen was 20m outside the 500m buffer zone. Conclusion: No licence required. The large Pheasant release pen straddled the 500m SPA buffer zone. Conclusion:licence required. We also reported our findings about the apparent non-compliance with biosecurity regulations to Suffolk County Council Trading Standards team (responsible for biosecurity investigation and enforcement), who subsequently assigned an officer to investigate this case. Some answers! On 10th September 2025, we received some answers from Natural England. They told us that two applications for individual licences to release gamebirds on or near the Deben Estuary SPA had been made – and it made for a very interesting timeline: 23rd April 2025: The first licence application was submitted to NE, for 2,450 gamebirds across several pens, to be released between July and August 2025. 14th May 2025: Natural England REJECTED this application, concluding it wasn’t possible to rule out adverse effects on the SPA. 16th May 2025: The same applicant submitted another licence application, hoping to change NE’s mind. In supplementary documents submitted with this application, the applicant said: “Before the end of February 2025 all my Days shooting at [REDACTED] had been sold for this season, with some deposits paid and the pheasant and partridge poults ordered from the game farm. Without a licence I'm going to be in a very embarrasing [sic] business situation”. Unknown date: Natural England REJECTED this second licence application (likely to have informed the applicant on or before 6th June 2025). Asking more questions Now we knew two things: Individual licences to permit the release of gamebirds on or close to the Deben Estuary SPA had been refused by NE. We’d seen evidence, and witnessed ourselves, gamebirds having been released within the 500m buffer zone of the Deben Estuary SPA. Naturally, we had more questions for NE and asked them what enforcement action they would be taking to address these unlawful releases. NE told us: “Where a licence has not been issued, wildlife offences are a matter for the police to investigate. Natural England will support the police in any investigation they undertake. Our recommendation is that in this instance, as you hold the relevant evidence, you should report it direct to Suffolk Constabulary”. We submitted an online report to Suffolk Constabulary the same day. Some unsatisfying answers: On 13th October 2025, we received correspondence from Suffolk County Council Trading Standards Department, letting us know that a Trading Standards Officer had visited the site. We were told the officer had provided verbal advice to the shoot operator relating to breaches of the mandatory biosecurity regulations. Asking yet more questions: Unsatisfied, we wrote back to Trading Standards and asked them: For specific detail of the verbal advice provided. Why no stronger enforcement action had been taken. Yet more unsatisfying answers: Trading Standards told us that ‘In the first instance we would always look to engage with, and provide advice to, businesses and individuals engaged in potential breaches’ and that ‘….we would also look to progress this in a positive way without resorting to immediate formal action such as prosecution.’. Perhaps unsurprisingly, they also told us ‘We are unable to share specifics of the verbal guidance provided to the responsible person in this instance, as these matters are confidential’. On 14th October 2025 we heard back from Suffolk Constabulary. They told us a Police Rural Crime Officer had visited the site (at the same time as the Trading Standards Officer) and had issued the shoot with a Community Resolution Order (CRO). We asked for details of this CRO, and of the officer’s visit, and were told: The CRO is disclosable in enhanced DBS checks, and the shoot operator won’t be given the chance to receive another CRO for any future offences. The CRO advises the shoot operator to work with Trading Standards and adhere to their advice. The current shoot operator was new and so was not the same person who applied for the licence from NE (hmm…). The original applicant and the new shoot operator weren’t linked to each other (another hmm…). That it was quite plausible that the new shoot operator was completely unaware of the restrictions (a very sceptical hmmm…) This new shoot owner was very remorseful and fully admitted his part in the offences. Our thoughts: Offences under the Animal Health Act 1981 and the Wildlife & Countryside Act 1981 can attract penalties of unlimited fines and/or custodial sentences. In our opinion, the low level of enforcement action in this case does not reflect the seriousness of the offences, nor does it offer a deterrent to other shoot operators who might be thinking of ignoring the legislation, and nor does it engender public confidence in the authorities’ ability to manage and control disease outbreak, especially HPAI. We consider it utterly implausible that the shoot operator was “not linked” to the licence applicant, as Suffolk Constabulary were led to believe. The timeline outlined above would provide only a matter of weeks (a tiny window) for a ‘new operator’ to start up, establish infrastructure, acquire birds and then release them, all supposedly without communicating with the previous shoot operator/licence applicant. In our opinion, it seems an easy loophole to exploit to avoid prosecution, and it’ll be interesting to see whether a similar explanation of a supposed change of shoot operators is used in other cases. You can read the full report on this case on our blog – click here. This is a detailed and complex case, and we don’t know how widespread this sort of offending might be. Wild Justice believes the release of millions of non-native gamebirds into the UK’s countryside each year is detrimental to wildlife and the environment. When rules attempting to reduce the impact of this damaging industry can be flouted, circumvented or ignored, with minimal sanction, it shows that enforcement isn’t up to scratch. We’ll be keeping an eye on this subject and will update you on it soon. Wild Justice relies entirely on donations to fund our work. If you think what we do is important and feel able to support us with a donation, however small, you can do so by clicking here. That's it for now, but we hope to be back soon with news of a new court date for our Badger legal challenge. Thank you once again, Wild Justice (CEO: Bob Elliot. Directors: Chris Packham and Ruth Tingay). 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