This is a copy of the criminal complaint made against Julia Mulligan. The complaint was filed by Tony Nixon at Northallerton Police Station on 22 April.
By Tony Nixon
I, Anthony Frederick Nixon (a retired solicitor), make a complaint against Julia Mulligan - the Police & Crime Commissioner for North Yorkshire - in respect of her fraudulent use of public monies.
Below, I refer to the following;
 - extract from an email dated 18/3/15 from myself to Julia Mulligan.
 - extract from an article in the Yorkshire Post of 20/3/15.
 - You Tube video of BBC programme featuring the North Yorks Enquirer.
 - Copy of the Crime Prosecution Service (CPS) guidelines re the common law criminal offence of misconduct in public office.
As a taxpayer and resident of North Yorkshire I was furious to learn (around mid-February 2015) that Julia Mulligan (PCC for North Yorks) had illegally used public monies and had determined to continue doing such re a private, civil High Court action brought by nine Complainants against three Defendants. Two of the latter included Nigel Ward and Tim Hicks; who have run an excellent citizens blog for a number of years (namely, the North Yorks Enquirer). In effect, she has and still is using monies from the police budget - together with labour paid for out of both the police and PCC budget - to finance the action on behalf of the nine civil complainants. Such actions by her are blatantly illegal and criminal.
In order to facilitate an easier understanding of this complaint, I refer to the four items mentioned in the second paragraph of this statement as follows:
1] - extract from an email dated 18/3/15 from myself to Julia Mulligan.I refer, of course, to your illegal - and, I believe, criminal - decision to misuse monies provided by taxpayers and North Yorkshire council tax payers (such as myself). Such monies being in the budget for funding North Yorks Police Authority (NYPA) to finance a High Court civil action brought by nine individuals acting in a personal capacity. The nine Complainants are seeking a permanent injunction to stop three citizens exercising their right of free speech via use of allegations of harassment by the latter.
Though I do not know the names of all nine Complainants, I am aware that three are serving police officers in North Yorks Police Authority and one is a retired officer from the same force. The other five appear to be individuals who are at odds with Mr Hicks and Mr Ward. The latter two people run the very popular North Yorks Enquirer website which has, for years, been exposing corruption within North Yorkshire Police and in various local authorities within North Yorkshire. I know that the North Yorks Enquirer was the first media outlet to expose the infamous Savile/Jaconelli paedophile scandal in Scarborough and Whitby. This was a scandal which North Yorks Police - recently assisted by yourself - has for years made every attempt to sweep under the carpet. Everyone knows about Jimmy Savile, whilst Jaconelli was a very prominent name in the area; at one time being the Conservative Mayor of Scarborough Council.
I now turn to Mr Hicks and Mr Ward.
Though I have never had the pleasure of meeting either of these two gentlemen, I have, during the past few years, read numerous articles they have written for North Yorks Enquirer. Having done so, I must admit to being extremely impressed by their great integrity, their extensive detailed research, and the fair and equitable manner in which their articles have been presented. These two gentlemen have been - and still are - of huge benefit to the community in North Yorks for they very diligently expose corruption where it exists. Unlike yourself, Mrs Mulligan, both believe in the rule of law, equity and the basic human right of freedom of speech. I might add that anyone who has been legitimately offended by anything they have written could have sued them for defamation. As I understand it, no such action has ever been taken by anyone against the North Yorks Enquirer.
Whatever the merits of the application for an injunction to try to suppress the freedom of speech of these two excellent gentleman, one matter is absolutely 100% certain and it is this: your decision to use public (taxpayers') money to finance a private civil action is illegal. The fact that three of the Complainants are police officers is not material as all citizens are equal under English Law and a police officer has no more rights than anyone else (as you well know).
What other projects do you have in mind for using public money for private purposes? Perhaps you intend the police budget to fund a visit by your deputy, 'Woeful Will' Naylor, to some posh hairdresser in Harrogate to have his hair permed and his toenails manicured? Maybe you intend to purchase a stylish miniskirt for your CEO, Joanna Carter.
In principle, the above examples are no different to what you are actually doing. Quite simply, it is illegal to use public funds for private purposes. In your case the situation is greatly exacerbated by the fact that your motive is to stop the free speech of two top-rate citizens. I have spoken with a few of my fellow lawyers and every one of them has the same opinion as myself. Without any qualification, they believe that you are acting in a blatantly illegal manner. One has even suggested that the whole matter has the whiff of a 'criminal conspiracy'.
Such is your unbridled arrogance that I suspect that you have not thought through the consequences of your illegal actions. Therefore I will enlighten you. Should your actions be found to be illegal, a Court will then order you to repay to the police budget all monies spent by it (including labour costs) as a consequence of your ultra vires actions.
My experience tells me that it is likely that thousands of pounds of costs have already been accrued re this action. Via contacts, I have learned that a London-based Queens Counsel represented the Complainants at a hearing at Leeds High Court in early February. A QC - paid for by the taxpayers - in a private action? For goodness sake! With regard to a case such as this, I suspect that a large amount of preparation will have been done before pleadings will have been filed. This will have included the preparation of a large bundle of documents. If so, then I ask this question: Who has prepared them? Whatever time has been spent on doing this preparation by lawyers and ancillary staff - at both the PCC and NYPA - needs to be quantified by a cost accountant as this is clearly a cost which must be born by yourself as an individual. None of this staff should ever have been used for it is an improper use of taxpayers' monies.
I suspect that the costs figure - including the staff costs mentioned above - already exceeds five figures as it stands; though such a figure may very well be much higher than £10,000 (with the bulk of such sum not being the costs of solicitors and the QC but labour costs of staff at both the PCC & NYPA). Really, Mrs Mulligan, don't you think that you have created massive problems for yourself?
I now turn to the question of criminal misconduct on your part.
As you are aware, I have previously studied in detail the common law criminal offence of misconduct in public office. If you deign to look at the guidelines issued by the Crown Prosecution Service (CPS) you will conclude that your actions - in illegally using public monies to fund a civil case against citizens - falls squarely within the guidelines. You are also aware that this is a very serious criminal offence - hence the maximum sentence is life imprisonment.
 - extract from an article in the Yorkshire Post of 20/3/15
“North Yorkshire’s police and crime commissioner Julia Mulligan, who oversees the force’s spending, said:
'I have weighed up the arguments in favour and against doing this from a public purse point of view.
'I am satisfied that as it stands, taking this action will be better value for money because of the amount of money the police has already spent dealing with these matters.
'Persecution of individuals to the point where severe harm is done is really unacceptable. That is whether it is done face-to-face or remotely. It is unacceptable to put people through an ordeal like that.'
“She declined to say how much had been spent on the legal case but said 'the day-to-day cost of dealing with this far exceeds the legal costs so far'.
A preliminary hearing of this case took place at Leeds High Court on February the 9th and it is clear from the above extract that Mulligan has spent public monies financing the action prior to this hearing.
 - You Tube video of BBC programme featuring the North Yorks Enquirer.
 - Copy of the CPS guidelines re the common law criminal offence of misconduct in public office. Misconduct In Public Office: Legal Guidance: The Crown Prosecution Service.Any lawyer examining these excellent guidelines should easily conclude that Mulligan's actions of intentionally misusing public monies - so far thousands of pounds - puts her misconduct very firmly within the prerequisites contained in these guidelines.
However, as to which criminal offences she has committed, the CPS needs to carefully consider: e.g., offences relating to fraud, theft and, perhaps, criminal conspiracy.
Anthony Frederick Nixon,
*******************************************************) See also 'Tony Nixon vs. Julia Mulligan', 'Greater Manchester Police Inaction on Muslim Grooming Gangs' and 'The Illegal Misuse of Public Funds by PCC Julia Mulligan'.