Williams-Rigby & Anor, R v [2003] EWCA Crim 693 (14 March 2003)
The convictions of Williams-Rigby were unsafe due to credible fresh evidence undermining key complainants, which could have affected the jury's verdict. Lawson's convictions were unsafe due to the cumulative prejudicial effect of the Scene 22 document, the threat to admit Williams-Rigby's now-unsafe convictions, and fresh evidence undermining a key complainant, all of which could have distorted the fairness of the trial.
- Citation
- [2003] EWCA Crim 693
- Parties
- Prosecution: R; Appellant: Basil Anthony Williams-Rigby; Appellant: Michael James Lawson
- Jurisdiction
- England and Wales
- Judgment Date
- 14 March 2003
- Procedural Posture
- Criminal Appeal / Court of Appeal (criminal Division) Judgment on Appeal Against Conviction
- Outcome
- Appeals allowed; convictions quashed; no retrial ordered.
- Legal Topics
- Sexual Offences, Fresh Evidence on Appeal, Good Character Direction, Similar Fact Evidence, Admissibility of Prior Convictions, Fair Trial, Compensation Claims and Witness Credibility
Case Brief
Summary, issues, holding and outcome
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Parties
R
Prosecution
Basil Anthony Williams-Rigby
Appellant
Michael James Lawson
Appellant
Procedural Posture
Criminal Appeal / Court of Appeal (criminal Division) Judgment on Appeal Against Conviction
Legal Issues
- 1 Whether fresh evidence renders convictions unsafe
- 2 Whether the trial judge's directions on good character and similar fact evidence were adequate
- 3 Whether the use of prior convictions and Scene 22 document prejudiced the fairness of the trial
Ratio Decidendi
The convictions of Williams-Rigby were unsafe due to credible fresh evidence undermining key complainants, which could have affected the jury's verdict. Lawson's convictions were unsafe due to the cumulative prejudicial effect of the Scene 22 document, the threat to admit Williams-Rigby's now-unsafe convictions, and fresh evidence undermining a key complainant, all of which could have distorted the fairness of the trial.
Court Disposition
Appeals allowed; convictions quashed; no retrial ordered.
Orders
- Convictions of Basil Anthony Williams-Rigby quashed.
- Convictions of Michael James Lawson quashed.
Full Case Text
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