BUV v Rex
The evidence of the complainant’s father regarding her change in demeanour was technically admissible as it was relevant to rebut the defence’s allegations of fabrication and 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 given the supporting contemporaneous evidence and medical findings.
- 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
- Sexual Offences, Admissibility of Evidence, Demeanour Evidence, Directions to Jury, Appeals Against Conviction
Case Brief
Summary, issues, holding and outcome
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Parties
BUV
Appellant
Rex
Respondent
Procedural Posture
Criminal Appeal / Appeal Against Conviction
Legal Issues
- 1 Whether evidence of the complainant’s change in demeanour after the alleged offences was wrongly admitted
- 2 Whether the judge gave proper directions to the jury regarding the approach to demeanour evidence
Ratio Decidendi
The evidence of the complainant’s father regarding her change in demeanour was technically admissible as it was relevant to rebut the defence’s allegations of fabrication and 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 given the supporting contemporaneous evidence and medical findings.
Court Disposition
Appeal dismissed
Full Case Text
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