Ending impunity
Justice for survivors exists in theory but not in practice. Britain offers powerful perpetrators and institutions a trifecta of impunity: civil courts where wealth prices victims out before trial, criminal courts that almost never convict them, and a reputation-management industry, built on claimant-friendly libel laws, that keeps allegations out of the press.
The Trifecta of Impunity
Britain has never jailed a predator as powerful as Mohamed Fayed.
The United States jailed Jeffrey Epstein, Harvey Weinstein, and Larry Nassar. Canada jailed the fashion tycoon Peter Nygard. China jailed the billionaire Wang Zhenhua. Israel jailed its own former president, Moshe Katsav. Why is Britain different?
The answer is Britain’s architecture of impunity. It rests on three pillars:
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Dead end civil justice. It is virtually impossible for a survivor to take a powerful perpetrator to civil court.
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A state that fails to protect. Serious sexual offending is policed so ineffectively that it has been decriminalised in all but name.
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Gagged speech. When the courts and the police fail, journalists should be the last line of defence. Instead, strategic lawsuits against public participation (SLAPPs) let the wealthy threaten press into silence. NDAs apply similar pressure to victims.
Until this architecture is dismantled, the Government cannot credibly claim to be protecting the vulnerable, or to be serious about its promises on violence against women and girls.
In Britain, survivors must wait for their abuser to die before they can safely speak. That is why NOA is calling for a statutory public inquiry.
1. Dead end civil justice
For survivors of abuse connected to Harrods and other powerful institutions, access to justice remains largely theoretical. Civil claims are prohibitively expensive, risky, and structurally biased in favour of defendants with vast resources and reputational influence.
It is not uncommon for survivors of such cases to be denied representation altogether because their cases are seen as commercially unviable under current funding and cost regimes. Legal aid is largely unavailable, affordable insurance does not exist, and existing damages frameworks undervalue lifelong trauma.
The result is a justice system that protects wealth and power rather than truth and accountability — leaving survivors without meaningful routes to redress or protection.
NOA evidence to the Justice Committee
Access to Justice: Written evidence submitted by No One Above
This submission by No One Above (NOA) responds to the Justice Committee’s Access to Justice Inquiry.
It highlights the systemic barriers survivors face when bringing civil claims against powerful or well-resourced abusers, including prohibitive costs, lack of affordable insurance, restrictive limitation laws, and undervalued damages. NOA argues that the current system effectively denies survivors justice, forcing many into silence or unsafe settlements.
The submission calls for reforms to costs protection, funding, and legal aid, alongside the creation of independent, perpetrator-funded statutory redress schemes to provide fair, trauma-informed justice.
Testimony to the Justice Committee's inquiry on Access to Justice
On March 9, 2026, NOA was invited to the Justice Committee's Access to Justice foundable.
We shared survivor perspectives on the barriers survivors face when seeking justice — including unequal legal resources, litigation cost risks, and the ways powerful perpetrators can weaponise legal systems.
2. A State that fails to protect
The failure to police Mohamed Fayed and his network was not the failure of a few officers. It was a failure of the State.
In 2020 the Victims’ Commissioner warned that rape had, in effect, been decriminalised. Today one recorded rape in twenty ends in a charge. In December 2025 the Government declared violence against women and girls a national emergency and promised to halve it in a decade.
Trafficking tests that promise. It is a pattern crime, and only specialist units can see the pattern. In 2010, with allegations against Fayed already on file, the Home Office defunded Britain’s only dedicated trafficking team. In 2020 the national modern slavery policing unit lost two-thirds of its budget. Three months after the national emergency was declared, the Home Office closed what remained. Five months later, Fayed survivors confirmed by the Home Office as trafficking victims disclosed that the Met had never offered them the referral it is legally obliged to make.
A state that charges one rape in twenty, defunds the units built to catch traffickers, and then fails the victims who come forward anyway has not under-performed. It has abandoned the people it is legally bound to protect.
De facto decriminalisation of sex offending
Even when survivors report, criminal justice offers offenders near-certain impunity. In 2020 the Centre for Women’s Justice, the End Violence Against Women Coalition, Imkaan and Rape Crisis found that rape had been effectively decriminalised in England and Wales: a complainant’s chance of seeing her attacker charged was roughly one in 70. The Home Affairs Committee recorded that conclusion without contradiction – in the year to September 2021, 1.3% of recorded rapes resulted in a charge – and even on the latest revised figures, only 5.2% of rapes recorded in the year to March 2025 have resulted in a charge. For a wealthy perpetrator, before lawyers, NDAs and reputation managers are even brought to bear, those odds amount to a rational expectation of no consequences. The Fayed case is the proof.
The Metropolitan Police, which Baroness Casey found in 2023 to be institutionally failing victims of rape and sexual assault, received reports against Mohamed Fayed over decades, sent files to prosecutors in 2008 and 2015, and never charged him. He died in 2023 uncharged, with reported offending spanning 1977 to at least 2014.
No resolve from No.10
When survivors met then Prime Minister Sir Keir Starmer in June 2026, he answered their concerns about the catastrophic failure of justice in the Fayed and similar cases with an assurance that Government would look to Dr Gillian Fairfield's review of the Met's progress since the 2023 Casey report.
This is treating a haemorrhage with a sticking-plaster – and disregards the ongoing deficiencies with Operation Cornpoppy. Survivors are justified in demanding urgent intervention from the Government.
Dismantling of Britain's anti-trafficking protections
Where trafficking is involved, the odds lengthen further. Britain identifies more victims every year – more than 19,000 were referred to the National Referral Mechanism in 2024 – but prosecutes almost none of their exploiters. In the year to June 2024 the Crown Prosecution Service brought 467 prosecutions flagged as modern slavery, and just 58 people were convicted under the Modern Slavery Act, with prosecutors often charging lesser offences to secure a result – a practice evident in Operation Cornpoppy's focus on RASSO offending, noted by GRETA, the Council of Europe's Anti-Trafficking monitoring body.
The capacity to do better is being dismantled. The Independent Anti-Slavery Commissioner found in 2025 that funding for modern slavery policing has been slashed to around 30% of its pre-2021 level, that specialist teams are being merged or disbanded behind immigration enforcement, and that live investigations fell by 18% in two years. GRETA’s 2026 evaluation of the UK urged that trafficking be investigated and prosecuted as such, backed by financial investigation. For a wealthy trafficking network the two failures compound: a sexual offences system that rarely charges, and a trafficking system that rarely looks.
It needn't be this way. The office of Independent Anti-Slavery Commissioner and a consortium of anti-trafficking NGOs have published compelling visions of an alternative future, in which the state swiftly intervenes to stop exploitation.
NOA's engagement with the international community
Under the Council of Europe Anti-Trafficking Convention and Article 4 of the European Convention on Human Rights, the UK must identify potential victims of trafficking and investigate and prosecute trafficking as the crime it is. In the Fayed case it did neither.
When we put these failures to the Home Office, our evidence went unpublished and unanswered. So we took it to the bodies that hold Britain to its international commitments: GRETA, the Council of Europe’s anti-trafficking monitoring body; the US State Department’s annual Trafficking in Persons Report, which grades every government against international minimum standards; the Council of Europe Commissioner for Human Rights; and the UN Special Rapporteur on trafficking in persons.
GRETA’s fourth evaluation of the UK, published in May 2026, cited our evidence, questioned the Met’s characterisation of the case and recommended that trafficking offences be investigated and prosecuted as such – recognition that Britain’s own institutions had refused to give.
3. Gagged speech
A SLAPP – a strategic lawsuit against public participation – is a legal threat or claim brought not to win, but to make speaking out too expensive and too frightening to continue. Most never reach a courtroom: a letter from a costly law firm, the prospect of six-figure costs, and a story is softened, delayed or dropped. Alongside the NDAs that gagged survivors and the libel tourism that drew the world’s wealthy to London, SLAPPs are how allegations against the powerful are kept from the public.
Victims were also compelled to sign NDAs – and were left believing that a word to the police or the press would cost them everything until Harrods assured victims that it would not attempt to enforce them in 2024, missing several opportunities to provide the same reassurance during Fayed's lifetime. In law, an NDA cannot stop anyone reporting a crime to the police; whether it can stop them telling a journalist is a question a court decides afterwards – and no survivor holding a lawyer’s letter could be sure of the answer. Every suppressed story and every gagging clause closed off the route by which victims of a trafficking network learn they are not alone and come forward. Silence in the press meant silence from survivors, decades more exploitation – and a delay in disclosure that Parliament now proposes, through clause 36 of the Immigration and Asylum Bill, to count against the credibility of trafficking victims.
That is the trifecta working as designed: the more effectively wealth suppresses disclosure, the less the law protects the people harmed.
What's a SLAPP?
As defined by the Anti-SLAPP Coalition, a SLAPP is “an abusive lawsuit filed by a private party with the purpose of silencing critical speech.” Fayed was, in the words of David Hooper, lawyer for Vanity Fair's libel defence, "a notorious SLAPPster".
Read more
SLAPPs and the obstruction of justice in the Fayed Case
Mohamed Fayed did not use libel law to clear his name; he used it to make the truth unpublishable. His own in-house counsel told Vanity Fair in 1995 that when his lawyers said he could not win, his answer was “Sue. Sue anyway.” The writs came with a second weapon – Harrods’ advertising budget, pulled overnight from any paper that crossed him – and with London’s best-known reputation managers, some of whom later served Jeffrey Epstein.
For nearly thirty years, serious attempts to report the abuse were sued, threatened or starved into silence. These are the best-known examples:
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1995–97 Fayed sues Vanity Fair over its Harrods exposé; the magazine amasses evidence of his offending, then settles on terms that lock it away. Harrods’ advertising returns.
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1997 ITV’s The Big Story drops a rape allegation “amid repeated legal threats from Fayed”.
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1998 The Evening Standard prints a truthful exposé; Fayed pulls Harrods’ £1m-a-year advertising overnight. A decade-long news blackout follows – the likely peak of the abuse.
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2004 A judge halts the BBC’s The Curious Case of the Disappearing Pharaoh hours before transmission; it airs only after a court fight.
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2005 Harrods sues The Sunday Times for breach of confidence over reports on the “chairman’s ladies” – his young internal informants, the visible edge of the trafficking system – and blocks evidence from some sixty former directors. Their testimony is never heard.
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2008 After legal letters, the Mail on Sunday reduces Fayed, under police investigation over a 15-year-old girl, to a “senior Harrods executive”.
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2017 His lawyers try to stop Channel 4’s Dispatches with a letter claiming dementia – since described by his son as faked. Three papers cover the broadcast; a follow-up gets none.
Only his death ended it. Within weeks of the BBC’s 2024 exposé, hundreds of women had come forward.
Listen to Saville investigative journalist Meirion Jones explain SLAPPs on Nicola Thorp's podcast: Al-Fayed: Who Looked Away (paywall)
NOA's campaigning against SLAPPs
March 2026 – Letter to the Prime Minister. NOA asked Sir Keir Starmer to honour his October 2024 pledge to act against legal intimidation by putting comprehensive anti-SLAPP legislation in the King’s Speech – adding survivors’ voices to the 166 editors, journalists and lawyers, 103 academics and Labour MPs who had already written. The letter sets out how legal threats altered, delayed or buried reporting on Fayed from the mid-1990s, and asks for early dismissal of abusive claims, costs protection for defendants, a clear statutory definition, coverage of all public-interest reporting, protection for sources and for survivors bringing civil claims, and real deterrents for those who misuse the courts. The May 2026 King’s Speech contained no anti-SLAPP bill.
March 2026 – Reform dossier to the Safeguarding Minister. Sent Jess Phillips MP recommendations on access to justice for survivors – the package in which anti-SLAPP protection sits alongside a statutory trafficking tort, limitation reform and fairer redress.
April 2026 – London: Hub for Fayed and Epstein Trafficking. NOA research showing how both networks drew on London’s reputation-management industry – the same PR advisers and libel firms – with Epstein himself advising that London’s libel laws were “much better” than America’s for keeping allegations quiet.
June 2026 – Meeting with the Minister for Courts and Legal Services. NOA members met Sarah Sackman MP, the minister responsible for SLAPP policy, and Catherine Atkinson MP on access to justice for victims of powerful perpetrators. The minister committed to continuing discussions on reform.
September 2026 – NOA contributed material to Index on Censorship for the Backbench Business debate on Strategic Lawsuits Against Public Participation (SLAPPs). The Fayed case was mentioned among the most notorious cases of the suppression of public interest journalism.
