Clarke, R. v [2026] EWCA Crim 184 (06 February 2026)

Clarke, R. v [2026] EWCA Crim 184 (06 February 2026)

Section 58 of the Criminal Justice Act 2003 does not prevent a trial judge from reversing a ruling of no case to answer during an adjournment for prosecution to consider appeal; the judge's discretion to do so was properly exercised, and no unfair prejudice or legitimate expectation arose to vitiate the conviction.

Citation
[2026] EWCA Crim 184
Parties
Prosecution: Rex; Applicant: Alan Clarke
Jurisdiction
England and Wales
Judgment Date
06 February 2026
Procedural Posture
Criminal Appeal / Application for Leave to Appeal Against Conviction
Outcome
application for leave to appeal refused
Legal Topics
Sexual Offences, Attempted Rape, Judicial Discretion, No Case to Answer, Criminal Procedure

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Parties

Rex

Prosecution

Alan Clarke

Applicant

Procedural Posture

Criminal Appeal / Application for Leave to Appeal Against Conviction

  1. 1 Whether a trial judge may lawfully reverse a ruling of 'no case to answer' during an adjournment under section 58 of the Criminal Justice Act 2003
  2. 2 Whether the judge's exercise of discretion to reverse the ruling was proper
  3. 3 Whether the applicant had a legitimate expectation that the initial ruling would stand

Ratio Decidendi

Section 58 of the Criminal Justice Act 2003 does not prevent a trial judge from reversing a ruling of no case to answer during an adjournment for prosecution to consider appeal; the judge's discretion to do so was properly exercised, and no unfair prejudice or legitimate expectation arose to vitiate the conviction.

Court Disposition

application for leave to appeal refused