Facts
- In 1762, Nathan Carrington, a chief messenger, and three others entered the home of John Entick under the purported authority of a warrant issued by the Earl of Halifax, Secretary of State.
- The warrant directed the search for and seizure of alleged seditious papers authored by Entick.
- During the search, Carrington and his associates caused property damage and removed charts and pamphlets from Entick’s home.
- Entick brought a claim for trespass against Carrington, challenging the lawfulness of the entry and seizure.
- The court was required to determine whether the Secretary of State’s warrant provided adequate legal justification for the actions taken.
Issues
- Whether the Secretary of State’s warrant was sufficient legal authority for Carrington and others to enter Entick’s property and seize materials.
- Whether the executive could exercise powers that were not explicitly grounded in statute, precedent, or established legal principles.
- Whether actions infringing individual property rights could be justified solely on the basis of government practice or unchallenged custom.
Decision
- The King’s Bench ruled in favour of Entick, holding that Carrington and his associates had committed trespass.
- The court found there was no statutory or common law authority to justify the warrant or the government’s actions.
- Lord Camden asserted that the lawfulness of executive action must be found in established legal sources; absent such authority, the action was not lawful.
- The court rejected arguments that executive practice or lack of past legal challenge constituted lawful authority.
Legal Principles
- The state may only act within the bounds of explicit legal authorization derived from statute or common law.
- Executive power is limited and must be justified with reference to legal rules; government officials cannot exercise authority without a clear legal basis.
- Individual liberty is protected by restricting state actions to what is specifically permitted by law, while individuals may do anything not expressly forbidden.
- The protection of private property is a core element, with any entry or seizure by state agents requiring explicit legal justification.
- The judiciary has a critical role in reviewing and restraining executive actions to prevent abuse of power.
Conclusion
Entick v Carrington is a foundational case affirming that all government power must be authorized by law, decisively limiting executive authority and safeguarding individual rights. Its enduring influence forms a central principle of constitutional law and the doctrine of judicial review.