Natural England’s response to sentencing of criminal gamekeeper Paul Allen

Following the sentencing last week of criminal gamekeeper Paul Allen in Dorset (here), I’ve been reviewing the responses from various organisations including the RSPB (here), the game-shooting industry (here) and Dorset Police (here).

Today I’m reviewing Natural England’s response.

Natural England (NE) published the following blog (reproduced below) on the day Allen was sentenced (16th Feb 2023):

By Stephanie Bird-Halton, National Delivery Director.

Today, Paul Allen, a gamekeeper working on the Shaftesbury Estate in Dorset, was sentenced for offences of possession of dead buzzards, keeping of banned pesticides and failing to comply with conditions of shotgun and firearms certificates.

Natural England is determined to tackle the scourge of raptor persecution. One of our roles involves investigating incidents where wildlife has been poisoned and we assisted Dorset Police in in this prosecution, gathering evidence and providing specialist technical advice. We are extremely pleased that he has been held to account for his appalling offences against wildlife.

This case, and the death in Dorset of one of the stunning White-tailed Eagles reintroduced to the Isle of Wight, are clear examples of a wider problem: the widespread misuse and abuse of poisons in the countryside which is killing birds of prey, and poses ongoing risks to the public.

During the coronavirus lockdown period, there was a spike in the number of poisoning cases reported with 230 accepted into the Wildlife Incident Investigation Scheme (WIIS) in 2020/21 as compared with 124 in 2019/20 and the problem has not gone away. In 2021/22, Natural England accepted 133 incidents of animal deaths suspected to be poisonings into WIIS. Cases remain unevenly spread throughout England with the highest number of incidents consistently being found in North Yorkshire (28 in 2019/20 and 54 in 2020/21).

When we investigate an incident and confirm it is a poisoning, we assess the evidence gathered, post-mortem results and tissue analysis to find out if the poisoning was as a result of a misuse or abuse of pesticides. Misuse is not following the legal requirements of use, whereas abuse is deliberate use in an illegal manner to poison animals. Where the evidence is unclear, cases are classified as “unspecified”. Not all cases accepted into investigation reach the assessment process, particularly where it becomes clear that pesticides have not been involved in the death of the animal.

In 2020/21, 37 cases of animal poisoning were assessed as being the result of abuse. There were six cases of misuse and 140 unspecified. 21 of the abuse cases related to the poisoning of raptors and these cases were passed on to the Police for further investigation.

The RSPB’s Bird crime 2021 report, published last November tells the same story of raptor persecution, with 80 confirmed incidents of bird of prey persecution in England, mainly through shooting, trapping or poisoning.

Based on data from WIIS, from 2016 onward, Natural England has observed a particular increase in frequency of Second-Generation Anticoagulant Rodenticides (SGARS) being linked to the cause of death in animals or being found in relatively high concentrations in those animals.

Rodent control is essential to public health and users of rodenticides, including SGARS, span many industries including pest controllers, farmers and food producers. Other users of rodenticides include the game shooting industry. The use of anticoagulant rodenticides by professional users must follow the requirements of the industry led rodenticide stewardship regime Campaign for Responsible Rodenticide Use UK set up in 2016, as well as complying with the product label requirements.

It is imperative that anyone dealing with a rodent problem keeps within the law, follows the best practice guidelines, only using rodenticides after alternatives have been explored and doing so in a graduated, careful and responsible way, ensuring that rodent carcasses are disposed of promptly. However, cases of raptors dying with high levels of rodenticides in their system suggest there is a problem with the use of rodenticides – whether this be from deliberate abuse or misuse.

NE will continue to play its part, investigating poisoning incidents and working with the police and other partners to prosecute offences. Anyone can help – reports from the public can play an essential part in identifying cases of raptor persecution. However, without all landowners, land managers and gamekeepers complying with the law and reporting illegal activity, the impact on our wildlife will continue.


It’s a bit all over the place to be honest, mostly focusing on the mis-use of rodenticides, which, whilst important in the wider scheme of things, had nothing whatsoever to do with gamekeeper Paul Allen’s conviction.

It’s interesting though that they mention the poisoned white-tailed eagle that was found dead on the same estate ten months after Allen’s crimes were discovered (and for which nobody has been held responsible because Dorset Police botched the investigation). Natural England had a role to play in the follow-up to that botched investigation, along with the Health & Safety Executive, and I’ll return to this once NE has responded to some pending Freedom of Information requests.

The last sentence in NE’s statement is just laughable:

However, without all landowners, land managers and gamekeepers complying with the law and reporting illegal activity, the impact on our wildlife will continue‘.

You don’t say!

But at least NE has explicitly laid the blame of raptor persecution at the door of the game-shooting industry. That is helpful from a campaigning perspective.

In addition to this blog, NE’s Chief Executive Marian Spain tweeted about the case:

She came in for some criticism from others on Twitter for failing to mention the other partners involved with this successful prosecution, notably the RSPB, just as Dorset Police had failed to acknowledge their involvement. Although in Marian’s case I doubt this was a deliberate, petty and vindictive move, unlike Dorset Police’s probable motivation.

But what struck me most about her tweet was her claim that one of the ways NE works to tackle raptor persecution is by ‘working with shooting bodies to change attitudes‘ and by ‘prosecuting offenders‘.

How’s that going then, Marian? How many attitudes has NE changed? Given that 2020 saw the highest level of reported raptor persecution crimes in 30 years (here) and the most recent report from 2021 had the second highest number on record (here), I’d argue that attitudes haven’t changed one bit.

She might point to DEFRA’s ludicrous hen harrier brood meddling sham as ‘evidence of changed attitudes’ (because a handful of grouse moor owners are now ‘allowing’ hen harriers to breed) but I’d point out that since hen harrier brood meddling began in 2018, at least 77 hen harriers are known to have been illegally killed or have gone ‘missing’, mostly on or close to grouse moors (here). That’s not a change in attitude. That’s evidence of on-going law breaking by an industry that NE has jumped into bed with, switched on the electric blanket and pulled up the duvet.

And as for ‘prosecuting offenders‘, I think Guy Shorrock’s tweet says it all (Guy, a now-retired RSPB Investigator, worked for 30 years in this field so I think he’s well placed to ask the question):

11 thoughts on “Natural England’s response to sentencing of criminal gamekeeper Paul Allen”

  1. The use of rodenticides should be banned. Raptors should be embraced to take care of the rodent problem. They are more effective and cheaper!!!!!!! The entire response is laughable. Until someone is really held to account with fines and imprisonment that matters – and isn’t laughed at – this practice of raptor persecution will not stop.

    1. Well said. We need proper sentencing and an actual change in attitude, not platitudes. Awful for all the people and organisations who are involved directly in trying to protect wildlife. The shooting fraternity/ gamekeepers continue, as before. Dreadful.

    2. “The use of rodenticides should be banned. Raptors should be embraced to take care of the rodent problem.”

      I very much doubt that would work.

    3. Much as I’d like to be able to agree with you, your approach won’t work. Basic ecology says that in the long term predators and prey are in balance so raptors will not in general remove humanities rat problem.

  2. Allen’s conviction had everything to do with poisonings as it was a poisoned red kite that got him nicked, so that might be why the focus is on poisonings in their blog.

  3. ‘However, without all landowners, land managers and gamekeepers complying with the law and reporting illegal activity, the impact on our wildlife will continue.” Perhaps we should ask NE or for that matter Dorset or any other police force in the UK exactly how many of these upstanding members of the shooting industry reporting wildlife crime and rodenticide misuse there are. I however think I know the answer will be near zero and this statement is a sop to NEs “friends” in shooting.

  4. It’s my impression that Brodifacoum misuse/abuse has increased considerably since the rules changed on its usage. Initially it was strictly for indoor use only, which presumably meant buildings from which there was no escape for rats which had consumed some of the substance. The relaxation of the rules, permitting its use close to buildings, was probably a reflection of the reality – the fact that it was being used in non-sealed environments from which rats were able to enter and exit anyway.

    Its efficacy and availability no doubt explain its probable use as a primary poison, maybe in the hope that its detection in poisoned raptors would be assumed to be secondary poisoning from its legitimate use – though the detected levels would no doubt indicate otherwise in many cases.

    I believe that second generation anti-coagulant rodenticides (SAGARS) should only be available for professional use. This should ensure that
    – other means of resolving a rat problem have already been tried and failed.
    – a proper plan is drawn up to tackle the problem,
    – the most appropriate rodenticide and method of application is used,
    – a programme for checking for dead rats and their safe disposal is implemented,
    – overall, much less rodenticide is released into the environment and that which is used is properly targeted.

    There is a myth abroad that certain rodenticides will not ‘second kill’, ie that the consumption of rats killed by them will not – in turn – kill the scavenger. I’ve yet to see this factor addressed and it’s high-time that it was.

    I see that the NE statement was provided by its ‘National Delivery Director’. Delivery of what and how? Makes it sound like Evri (other courier services are available)!

  5. I notice that Natural England express no opinions over the sentencing, just that they are extremely pleased that the offender was ‘held to account’.

  6. Natural England appears to be engaging in it’s fig leaf impression again. It seems to be more intent on placing the idea of accidental or careless poisoning in the minds of the public than the idea that there is a determined group of individuals out there with financial interests who are intent on killing as many birds of prey as they can…. with many of them collecting a weekly wage for it.

  7. Then just over the border in Wiltshire you have a huntswomen from a banned hunt who is a Wiltshire police rural officer in charge of wildlife protection

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