10 Downing Street has recently confirmed that Boris Johnson, the current Prime Minister of the United Kingdom, will be issued a fixed penalty notice for breaching COVID-19 related laws in June 2020.

Several commentators have suggested that it is very unusual, perhaps even uniquely so, for a sitting Prime Minister to be found to have broken the law. For example, the BBC says:

Mr Johnson's fine makes him the UK's first serving prime minister to be sanctioned for breaking the law.

whereas The New York Times makes the slightly different claim that:

making him (Johnson) the first holder of his office to be found breaking the law in living memory.

Are these claims correct? Have any other British prime ministers been found to have broken the law, while in office? I don't know of any counter-example, but I am still somewhat surprised by this. Have there, perhaps, been cases where a prime minister resigned shortly before being found to have broken the law? Regarding the New York Times' statement, were there prime ministers predating living memory who were found to have broken the law, while serving or otherwise?

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    It sounds like the question is whether he is the first to be convicted and punished for violating the law while in office, which is quite different from merely breaking the law without that violation of the law resulting in legal consequences, or while not in office (which is surely true of most prime ministers).
    – ohwilleke
    Apr 12, 2022 at 20:19
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    @ohwilleke Yes, that is essentially the sense in which I am using "found" here. The reason I didn't ask if he is the first to be convicted is that, to the best of my understanding, an FPN doesn't constitute a conviction in English law. Apr 12, 2022 at 20:36
  • "broken the law" is somewhat of an unclear target. Would getting a traffic ticket count? Keeping in mind that those partygate fines dont end up on your criminal record : If paid promptly, such fines do not result in a criminal record. But, yeah, what Johnson and then, as usual, lied about, was pretty reprehensible. Apr 12, 2022 at 22:04
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    @ItalianPhilosophers4Monica "traffic ticket" is itself a colloquialism that is not well defined in English law. The police will issue Fixed Penalty Notices in relation to speeding offences, and I certainly think that counts as "breaking the law" for the purposes of this question. On the other hand, breaking some traffic regulations, such as in relation to parking, can result in a Penalty Charge Notice, which is a civil matter and not really what I'm interested in here. Apr 12, 2022 at 22:31

1 Answer 1


Yes, the only other instance I’m aware of is Robert Walpole - considered to be the first Prime Minister, he was impeached by Parliament in 1712 and found guilty of ‘a high breach of trust and notorious corruption’ - according to the Gazette:

By 1710, the Tories had won a landslide victory, and made Walpole their political target. In 1712, they accused him of ‘venality and corruption’, relating to his benefiting from two forage contracts for the army. Walpole was imprisoned in the Tower of London for six months, and expelled from parliament, ‘guilty of a high breach of trust and notorious corruption’, during which time he was visited by leading figures, and became something of a Whig martyr and national celebrity.

This isn’t really a conviction in the same sense as Johnson’s fixed penalty notice, however, and in any case, it took place before he became Prime Minister in 1721.

Johnson remained the only Prime Minister to have been found to have broken the law while in office until Rishi Sunak was issued with a fixed penalty notice for not wearing a seatbelt while filming a social media clip in the back of a moving car.

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    A good answer. I gave others time to post their own answers, but this interesting edge case seems to be the closest thing to any other PM being found to have broken the law. Apr 19, 2022 at 16:21

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