BIG BROTHER WATCH AND OTHERS v. THE UNITED KINGDOM JUDGMENT
how this trend will be affected, for good or ill, by the physical collapse of the
so-called Islamic State in Syria and Iraq.
1.6 Thirdly, the profiles of the attackers ... display many familiar features. ...
1.7 Fourthly, though the targets of the first three attacks did not extend to the whole
of the current range, they had strong similarities to the targets of other recent western
attacks: political centres (e.g. Oslo 2011, Ottawa 2014, Brussels 2016); concert-goers,
revellers and crowds (e.g. Orlando 2016, Paris 2016, Barcelona 2017); and police
officers (e.g. Melbourne 2014, Berlin 2015, Charleroi 2016). There are precedents
also for attacks on observant Muslims which have crossed the boundary from hate
crime to terrorism, including the killing of Mohammed Saleem in the West Midlands
in 2013.
1.8 Fifthly, the modus operandi (MO) of terrorist attacks has diversified and
simplified over the years, as Daesh has employed its formidable propaganda effort to
inspire rather than to direct acts of terrorism in the west. The attacks under review
were typical in style for their time and place:
(a) Unlike the large, directed Islamist plots characteristic of the last decade, all four
attacks were committed by lone actors or small groups, with little evidence of
detailed planning or precise targeting.
(b) Strong gun controls in the UK mean that bladed weapons are more commonly
used than firearms in gang-related and terrorist crime.
(c) Since a truck killed 86 innocent people in Nice (July 2016), vehicles – which
featured in three of the four attacks under review – have been increasingly used as
weapons.
(d) The combination of a vehicle and bladed weapons, seen at Westminster and
London Bridge, had previously been used to kill the soldier Lee Rigby (Woolwich,
2013).
(e) Explosives, used in Manchester, were the most popular weapon for Islamist
terrorists targeting Europe between 2014 and 2017. The explosive TATP has proved
to be capable of manufacture (aided by on-line purchases and assembly instructions)
more easily than was once assumed.”
7. Annual Report of the Interception of Communications Commissioner
for 2016
168. The IC Commissioner observed that when conducting interception
under a section 8(4) warrant, an intercepting agency had to use its
knowledge of the way in which international communications were routed,
combined with regular surveys of relevant communications links, to identify
those individual communications bearers that were most likely to contain
external communications that would meet the descriptions of material
certified by the Secretary of State under section 8(4). It also had to conduct
the interception in ways that limited the collection of non-external
communications to the minimum level compatible with the objective of
intercepting the wanted external communications.
169. He further observed that prior to analysts being able to read, look at
or listen to material, they had to provide a justification, which included why
54