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This section permitted a defendant who had been charged by a private prosecutor to recover the costs of his legal defence if found not guilty.
In 1979, Duke was a founding member of the Gay Humanist Group, (now Gay and Lesbian Humanist Association) after Mary Whitehouse began a private prosecution for blasphemous libel against Gay News (see Whitehouse v Lemon.
Blackwell was a prosecution witness in the 1966 private prosecution attempt to bar the book Last Exit to Brooklyn from UK publication.
Along with racehorse trainer Sir Mark Prescott, Dickson Wright was charged with hare coursing with dogs in North Yorkshire in March 2007 under a private prosecution lodged by the International Fund for Animal Welfare under the Hunting Act 2004.