Charlene Hughes v The Commissioners for HMRC

Charlene Hughes v The Commissioners for HMRC

Appellant was in physical possession of the duty unpaid cigarettes at the relevant time, making her the 'holder' liable for excise duty under Regulation 10(1) HMDP Regulations; no earlier duty point could be established; criminal conviction and guilty plea are weighty evidence; fairness and proportionality arguments do not override statutory liability.

Parties
Appellant: Charlene Hughes; Respondents: The Commissioners for HM Revenue and Customs
Jurisdiction
England and Wales
Judgment Date
03 November 2022
Procedural Posture
Appeal / Final Judgment
Outcome
Appeal dismissed
Legal Topics
Excise Duty Assessment, Liability for Unpaid Duty, Physical Possession, Duty Point, Fair Trial Rights, Adjournment Applications

Case Brief

Summary, issues, holding and outcome

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Parties

Charlene Hughes

Appellant

The Commissioners for HM Revenue and Customs

Respondents

Procedural Posture

Appeal / Final Judgment

  1. 1 Whether appellant was 'holder' of cigarettes liable for excise duty
  2. 2 Whether an earlier duty point could be established
  3. 3 Fairness and proportionality of assessment

Ratio Decidendi

Appellant was in physical possession of the duty unpaid cigarettes at the relevant time, making her the 'holder' liable for excise duty under Regulation 10(1) HMDP Regulations; no earlier duty point could be established; criminal conviction and guilty plea are weighty evidence; fairness and proportionality arguments do not override statutory liability.

Court Disposition

Appeal dismissed

Orders

  • Assessment for excise duty in sum of £213,332 upheld against appellant