And the reply to that is that there is no criteria requiring intent in this law.

It appears that way. Mens rea is a legal concept applied to some of common law (although not always effectively).

http://en.wikipedia.org/wiki/Mens_rea#England

EDIT: British common law divides up laws between those requiring intent and those that don't.

And the reply to that:

The UK law in question does not require intent (mens rea).

So a law which you have to prove yourself innocent and can be applied to anyone - but the police get to decide who to apply it to.

nope, can't see any problem with that.