R v Christian Dorot

R v Christian Dorot

Given the positive defence case regarding phone access, a higher proportion of images (25%) should be allowed as PPE, and a 'page' is properly defined as a PDF page containing 10 thumbnail images, not each image individually.

Parties
Prosecution: R; Defendant: Christian Dorot; Appellant's Advocate: Harewood Law Solicitors
Jurisdiction
England and Wales
Judgment Date
23 September 2025
Procedural Posture
Criminal Costs Appeal / Appeal From Determining Officer's Decision on Graduated Fee Calculation
Outcome
Appeal allowed in part
Legal Topics
Litigators Graduated Fee Scheme, Prosecution Evidence Page Count, Electronic Evidence Assessment
Criminal Law Legal Aid Costs Litigators Graduated Fee Scheme Prosecution Evidence Page Count Electronic Evidence Assessment

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Parties

R

Prosecution

Christian Dorot

Defendant

Harewood Law Solicitors

Appellant's Advocate

Procedural Posture

Criminal Costs Appeal / Appeal From Determining Officer's Decision on Graduated Fee Calculation

Legal Issues

  1. 1 What is the appropriate number of pages of prosecution evidence (PPE) to be allowed for electronic images in calculating the litigators graduated fee?
  2. 2 Should the percentage of images allowed as PPE be increased due to the nature of the defence?
  3. 3 How should a 'page' be defined when images are served as thumbnails in electronic format?

Ratio Decidendi

Given the positive defence case regarding phone access, a higher proportion of images (25%) should be allowed as PPE, and a 'page' is properly defined as a PDF page containing 10 thumbnail images, not each image individually.

Court Disposition

Appeal allowed in part

Orders

  • PPE in respect of images allowed at 1,125 pages instead of 450 pages
  • Appellant entitled to costs of the appeal