PLAN and PLANE
The test for police use of force in Criminal Law Act 1967 section 3 and PACE section 117, and the PLAN and PLANE mnemonics used to justify it.
The expansion
- P: proportionate
- L: legal (or lawful)
- A: accountable
- N: necessary
- E: ethical (the added letter in PLANE)
What it is for
Every use of force by an officer has to be explained afterwards, in a use-of-force form, a statement, or a courtroom. PLAN is the frame recruits are taught to explain it in: the force had a lawful basis, was no more than needed, was necessary at all, and can be accounted for. PLANE adds ethical, which reflects the Code of Ethics at the centre of the National Decision Model.
This is training shorthand; the test it stands for is in Criminal Law Act 1967 section 3, PACE section 117 and the National Decision Model. The Surrey and Sussex Use of Force Policy (1225/2026) uses the words without the acronym: officers must "only use force that is proportionate, legal, accountable, and necessary for the circumstances" (paragraph 1.2), and an officer's account must show the force was "proportionate, legal, accountable, necessary, ethical, and reasonable in the circumstances" (paragraph 5.6).
Where it comes from
Section 3(1) of the Criminal Law Act 1967: "A person may use such force as is reasonable in the circumstances in the prevention of crime, or in effecting or assisting in the lawful arrest of offenders or suspected offenders or of persons unlawfully at large." Section 3(2) says this replaces the common law rules on when force for those purposes is justified.
Section 117 of the Police and Criminal Evidence Act 1984: where a provision of the Act "confers a power on a constable" and does not require someone's consent, "the officer may use reasonable force, if necessary, in the exercise of the power." It covers searches, arrests, entry and the other PACE powers.
The College of Policing's National Decision Model asks at the options stage whether the action is "proportionate, legitimate, necessary and ethical", and after the event invites officers to "review your decisions, using the NDM". The Sussex policy (paragraph 1.4) tells officers to reassess throughout an incident using the NDM.
When it is used
Before, during and after any use of force, from taking hold of an arm to handcuffing, PAVA, baton or Taser. The policy quoted above requires every officer's account to cover the circumstances, each use of force, the justification for each, and the legal power relied on.
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Sources
Last updated 19 October 2026. Reviewed 19 October 2026
