R (on the application of Sandiford) v Secretary of State for Foreign and Commonwealth Affairs [2014] UKSC 44, [2014] All ER (D) 158 (Jul)
Jurisdiction under Art 1 of the European Convention on Human Rights was “primarily territorial”, but there were certain recognised exceptions, one of which was in relation to the acts of diplomatic and consular agents, which might amount to an exercise of jurisdiction when those agents exerted authority and control over others. Whether the exception existed or not depended on the facts of the particular case.
