BUV v R. [2025] EWCA Crim 327 (25 March 2025)

BUV v R. [2025] EWCA Crim 327 (25 March 2025)

The evidence of the complainant's father's observations about her demeanour after the alleged offences was technically admissible and had a concrete basis, given the defence's allegations of fabrication and family collusion. The judge's directions to the jury were sufficient, emphasizing that there is no typical reaction to sexual offences and that demeanour is not a reliable indicator of truthfulness. The conviction was safe even if the evidence had been inadmissible, due to contemporaneous messages and medical evidence supporting the complainant's account.

Citation
[2025] EWCA Crim 327
Parties
Appellant: BUV; Respondent: Rex
Jurisdiction
England and Wales
Judgment Date
25 March 2025
Procedural Posture
Criminal Appeal / Appeal Against Conviction
Outcome
Appeal dismissed
Legal Topics
Rape, Sexual Assault, Admissibility of Evidence, Demeanour Evidence, Jury Directions
Criminal Law Rape Sexual Assault Admissibility of Evidence Demeanour Evidence Jury Directions

Case Brief

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Parties

BUV

Appellant

Rex

Respondent

Procedural Posture

Criminal Appeal / Appeal Against Conviction

Legal Issues

  1. 1 Whether evidence of the complainant's change in demeanour after the alleged offences was wrongly admitted
  2. 2 Whether the jury was properly directed on the approach to demeanour evidence

Ratio Decidendi

The evidence of the complainant's father's observations about her demeanour after the alleged offences was technically admissible and had a concrete basis, given the defence's allegations of fabrication and family collusion. The judge's directions to the jury were sufficient, emphasizing that there is no typical reaction to sexual offences and that demeanour is not a reliable indicator of truthfulness. The conviction was safe even if the evidence had been inadmissible, due to contemporaneous messages and medical evidence supporting the complainant's account.

Court Disposition

Appeal dismissed