02.04.26
“As a former police wildlife crime officer, I have seen first-hand how the weaknesses in the Hunting Act have been exploited to provide a smokescreen for illegal hunting. For too long, so-called trail hunting has been used to mask unlawful activity, making enforcement difficult for both the police and the courts. Now is the time to ensure this ends once and for all.
This consultation must mark the beginning of the end of relentless illegal hunting and ensure meaningful protection for wildlife.” – Jim Clark, Wildlife Crime Campaign Manager.
Responding to the trail hunting ban consultation
Here’s how you can help:
We are urging everyone who cares about wildlife in England and Wales to take part. This is a rare chance to help shape the law.
The proposed ban on trail hunting in England and Wales presents a vital opportunity to resolve the long-standing weaknesses in the Hunting Act 2004. While the Act aimed to prohibit hunting wild mammals with dogs, its lack of clarity and enforceability has allowed practices such as trail hunting to emerge, often criticised as a “smokescreen” for illegal hunting.
Current loopholes mean that, despite the 2004 Hunting ban, some hunts can still operate outside the law. Now, decision-makers want to hear from the public. What happens next depends on how many of us speak up.
Opportunities like this do not come around often. If we want stronger protection for wildlife and an end to ongoing cruelty, we must make our voices heard. Together, we can push for meaningful change.
The time to act is now – read the consultation here
We’ve read the consultation in full and carefully considered Defra’s proposals. Below, we’ve shared our observations to help you have your say.
We encourage all our supporters to visit the official Defra consultation page and submit your views: https://consult.defra.gov.uk/defra/trail-hunting-consultation/
To help you make your voice heard:
To help you make your views known, we’ve broken the consultation questions into a clear, bite-sized guide, along with the rationale behind our suggested responses. We hope this helps you feel confident and informed as you complete the consultation.
If you’d like to explore the issues in more depth, you may also find these hunting blogs on our website helpful:
- https://naturewatch.org/the-promise-to-ban-trail-hunting/
- https://naturewatch.org/fox-hunting-licensing-codes-and-traditions-will-not-protect-wildlife/
- https://naturewatch.org/hunting-act-2004-in-england-and-wales-wildlife-crime/
When adding your responses to the Defra consultation, you may also like to keep this page open for reference.
Together, let us deliver this ban.
Questions 1 – 6: Your personal details.
Please note: Naturewatch Foundation will also submit our recommendations.
Question 7: Do you agree with this proposed definition of “trail hunting”?
Our answer: No – Trail hunting only lives on paper and is often used as a smokescreen for illegal hunting.
Our suggestion would include wording similar to “Any activity by which there is any intent, recklessness or negligence, in which one or more dogs are deployed or allowed in a manner reasonably capable of resulting in the pursuit of an animal, or allowed to search or locate the scent of an animal, whether or not pursuit occurs. A person hunts where a reasonable person would foresee a risk that dogs may pursue an animal and does so with the intention of enabling or permitting that pursuit”. Note that the legal definition must be robust and withstand extensive legal examination. This is also your opportunity to suggest your definition.
Question 8: What types of conduct should be covered by ‘engagement’ or ‘participation’ in trail hunting?
Our answer: Yes – Hunting is a collective activity. Engagement should include anyone actively involved in the hunt, including Masters, hunt staff, hound handlers, and riders. Participation should cover anyone present and contributing to the hunt, such as laying trails, following, or directing hounds on foot, by bicycle, or in a car, providing logistical or financial support, or otherwise facilitating the activity, including the use of horns and voice calls to encourage or direct hounds. Strict liability ensures accountability for all involved.
Question 9: In relation to offences or conduct which would assist unlawful trail hunting to take place, we intend that it should be an offence for the owner or occupier of land to knowingly cause or permit another person to engage or participate in trail hunting on that land. Do you agree?
Our answer: Yes – Landowners or those in control (occupiers) of land by trust or other means have the power to allow or prevent hunts on their property. Making it a criminal offence to “allow” or “overlook” ensures accountability and prevents organised hunts from exploiting permissive landowners to continue illegal activity. Adding a “failure to prevent” provision ensures that landowners cannot evade responsibility through inaction, thereby strengthening the ban’s effectiveness and enforceability.
Question 10: In relation to offences or conduct which would assist unlawful trail hunting to take place, we intend that it should be an offence for the owner or person responsible for a dog to knowingly cause or permit another person to use the dog for trail hunting. Do you agree?
Our answer: Yes – Dog owners can control how their dogs are used. This measure prevents indirect participation in illegal hunting and ensures responsibility follows the persons and those in control of the animal.
Question 11: Are there any other forms of conduct which should be considered as possible offences in relation to offences or conduct which would assist unlawful trail hunting to take place?
Our answer: Yes – Offences should include funding hunts, transporting hounds, providing equipment, or going equipped to facilitate illegal hunting of a wild mammal with an animal. A “going equipped” offence should be introduced. A person commits an offence if they have in their possession any article, equipment, device, or dog that a reasonable person would consider capable of being used to locate, search for, pursue, or capture a wild mammal with a dog, in circumstances where a reasonable person would infer that the item is intended for use in connection with such activity.
The legislation should include individuals of business who use any actions to facilitate hunting, coordinate hunts, or recruit participants. These are all means by which hunting is facilitated and should be criminalised to close existing loopholes.
Question 12: Do you consider that any other legislative changes are necessary to ensure that a ban on trail hunting is effective?
Our answer: Yes and these are the necessary changes:
- Overhaul the Hunting Act 2004 to strengthen species protection (including hare, deer, and mink).
- Create primary legislation that would ban trail hunting.
- Clearly define “hunting,” introduce strict liability with a reversed burden of proof, and close existing loopholes (e.g., flushing, stalking, and hunting rats or rabbits).
- Limit exemptions to genuine scientific and wildlife management purposes, supported by new, specific legislation.
- Create offences for going equipped, aiding, or facilitating hunting, and align sentencing with the Animal Welfare Act 2006.
- Require hunts to comply with Health & Safety regulations, including mandatory record-keeping, pre-event risk assessments, and designated responsible persons to ensure accountability.
Question 13: Do you think that it is possible for dogs to be appropriately trained for specific purposes other than trail hunting without the use of either animal-based scents or artificial scents which mimic an animal-based scent?
Our answer: Yes – Training for pest control or search tasks can be achieved using artificial, non-animal scents or alternative methods, such as scent pads or synthetic lures.
Source: https://assets.publishing.service.gov.uk/media/5a7c9cbae5274a30fa38fdff/Detector_Dogs.pdf
Question 14: Do you think that it should remain lawful, in certain circumstances, for animal-based scents, or scents which mimic animal-based scents, to be used in training dogs for certain purposes?
Our answer: Yes – Only in highly controlled circumstances. If used, it should be licensed and limited to enclosed areas for specific purposes, such as the preservation of life and limb, the detection of wildlife crime or search-and-rescue, with strict oversight to prevent accidental encouragement of hunting behaviour. If new legislation is required or existing laws require amending, then a “non-sport” clause should be inserted.
Question 15: We understand that drag hunting is an equestrian sport where an artificial non-animal-based scent trail, which does not mimic an animal-based scent, is laid along a pre-determined route for hounds to follow. Do you agree that this is an accurate description of drag hunting?
Our answer: Yes – The description is largely accurate. Drag hunting involves following a pre-laid, artificial, non-animal scent along a set course, presenting a lower foreseeable risk of pursuing wild mammals.
Source: https://mdbassociation.com/
Question 16: Do you think that there is a risk that dogs engaged in drag hunting will deviate from the pre-laid trail by the scent of a wild mammal and then pursue the wild mammal?
Our answer: Yes – Dogs may occasionally deviate, but pre-planned trails, supervision, and hound control measures minimise this risk. Any legal definition should specify that no scent may be laid in any location where wildlife is likely to be present or reside, including (but not limited to) roads, woodlands, crop fields, or similar areas, to ensure effective protection of wildlife.
Question 17: We understand ‘clean boot’ hunting is an activity where hounds hunt human runners who neither wear nor drag any form of artificial scent enhancement. Do you agree that this is an accurate description of ‘clean boot’ hunting?
Our answer: Yes – The description is largely accurate. Clean-boot hunting involves dogs tracking only human scent, with no artificial or animal scents used. The breed of hounds should be legislated for the use of genetic “blood hounds” only.
Source: https://mdbassociation.com/
Question 18: Do you think there is a risk that dogs engaged in clean boot hunting will deviate from their pursuit of human runners to the pursuit of wild mammals?
Our answer: Yes – Human scent is the focus. Minimal risk, but not zero due to hound genetics and prey dive. Whilst there is no deliberate exposure to wildlife scent, standard supervision and training may prevent deviations. Any legal definition should specify that no “runner” may “lead” or “encourage” hounds in any location where wildlife is likely to be present or reside, including (but not limited to) roads, woodlands, crop fields, or similar areas, to ensure effective protection of wildlife.
Question 19: Do you think that a new law to ban trail hunting would need to include any additional provisions in relation to drag hunting or clean boot hunting?
Our answer: Yes – Both activities already minimise contact with wild mammals; clear definitions and oversight are generally sufficient. However, they should be subject to any proposed Hunting Act amendment or new primary legislation to avoid migration of genetic “fox hounds” and practises under the Hunting Act 2004. The current legislation fails to regulate how hunting takes place and places no intent on those taking part.
Question 20: Are there any equestrian activities other than drag hunting, for example point to pointing, which you think are at risk from being affected by the proposed ban on trail hunting?
Our Answer: No – Point-to-point racing or other equestrian sports do not involve following wild animal scent and would not be affected if the legislation clearly distinguishes trail hunting. Although some in the equestrian community acknowledge that point-to-point events are used to fund hunts, under potential legislative changes, this would be unlawful.
Source: https://www.britishhorseracing.com/regulation/point-to-point/
Question 21: How do you think the introduction of a ban on trail hunting will affect dogs used for trail hunting? For example, will they be able to be re-directed to other activities?
Our observations: Hounds can be retrained for drag hunting, clean-boot hunting, search tasks, or other controlled activities. Proper planning and kennel support will ensure their welfare. Hounds are still being bred by those who are aware their activities are under threat.
Source: https://foxhoundwelfareuk.jimdofree.com/
Question 22: Do you think that there should be a transition period following the introduction of a ban on trail hunting and if so, how long should that period be?
Our Answer: No – The Government has indicated that a ban forms part of its broader animal welfare strategy and would be introduced within this Parliament. The activity of trail hunting offers no scientific benefits or positive benefits to animal welfare.
Question 23: Do you think that the proposed legislation to ban trail hunting in England and Wales will affect people and/or communities more widely?
Our Answer: No – Rural communities are as supportive of a hunting ban as those elsewhere. In practice, prohibiting hunting with hounds would bring clear local benefits by reducing road blockages, trespass, and intimidation, improving safety, access, and quality of life for many farmers, landowners, and other countryside users.
While some areas with historic ties to hunting may face cultural change, this can be mitigated by transitioning to lawful alternatives and other rural activities. This shift also creates opportunities for more inclusive, sustainable, and wildlife-friendly use of the countryside, supporting tourism and community cohesion.
Clear, robust legislation would further reduce conflict, ease pressure on policing, and lower enforcement costs, helping to create a safer, more harmonious rural environment while improving animal welfare.
Question 24: How do you think the proposed ban on trail hunting might affect the income and activities of the hunts currently involved in this activity?
Our Answer: No – Loss of income to flout the law is not a consideration. There are no credible economic arguments to justify trail hunting. This is apparent in the reported 2.4 million pounds of taxpayers’ money in the form of farming subsidies, business rate reliefs, and COVID-19 support grants. One example, The Belvoir Hunt, which is based near Grantham, has allegedly received £74,540.78 in subsidies, £81,821.50 in rate relief, and £39,500.14 in COVID-19 support grants.
Source: https://plantbasednews.org/animals/uk-hunts-claimed-million-taxpayer-money/
Question 25: How do you think the proposed ban on trail hunting might affect the income and activities of businesses directly linked with hunts which currently engage in trail hunting?
Our Answer: No – As trail hunting is a seasonal activity, it is unknown if businesses directly linked with hunts will be affected. However, hunts may, of course, engage in other activities that support equine-related businesses.
Question 26: Do you think that the proposed ban on trail hunting in England and Wales might affect other businesses not directly linked with hunts?
Our Answer: No – Hunts generate little work for local businesses; therefore, the impact will be minimal. The nature of the hunts, using varying geographical locations in the countryside over the five months of the season, twice a week, has an extraordinarily little positive impact on local businesses.
Question 27: How do you think that the proposed ban on trail hunting could affect the environment or wildlife?
Our Answer: Positive – Reduced wildlife disturbance and killing, protection of ecosystems, and support for natural population control by predation. Improved welfare outcomes for hounds if better controlled. Elimination of practices that expose horses, dogs, livestock, and wildlife to injury during hunts. A marked improvement for public health in the reduction of dogs’ faeces on public land, amongst livestock and crops.
Increased domestic animal protection with the reduction of “accidents.”
Question 28: Are there any other matters, including possible alternatives to primary legislation, which you feel should be taken into account in developing the legislation to ban trail hunting?
Our Answer: Yes – Comprehensive reform is essential as the existing Hunting Act 2004 is riddled with loopholes. Ensure Health & Safety compliance for hunts operating as businesses. Implement recordable offences, pre-event risk assessments, and designated accountability. Maintain clear guidance on lawful equestrian activities to prevent unintended consequences. Define activities based on risk, not intent.
Ultimately, clarity is the key to effectiveness. A well-defined and enforceable ban has the potential not only to achieve the government’s policy aim but also to reduce conflict, improve animal welfare, and restore public confidence in the law.
Question 29: Is there any other evidence you would like us to consider?
To finish, you may like to add your own thoughts and observations.
This section invites you to share any individual experiences of how hunting has negatively affected you. For example:
- You may be a walker or rambler whose enjoyment of the countryside has been disturbed by witnessing hounds chasing or killing a fox.
- You may be a rural resident whose property or garden has been entered by hounds.
- You may have concerns for the safety of your pets or livestock.
- You may be a motorist whose journey has been delayed or disrupted by hunts on public roads.
- You may be among those in rural communities who oppose hunting and feel intimidated or impacted by local hunt activity.
- You are passionate about our wildlife in England and Wales and want to see the countryside thrive.
Thank you for your participation in this extremely significant consultation. Your words will shape how the government implements its manifesto promise to ban trail hunting.
Jim,
Wildlife Crime Campaign Manager.
