Nightingale, R. v

Nightingale, R. v

The Judge Advocate's uninvited sentence indication created inappropriate additional pressure on the appellant, improperly narrowing his freedom of choice and rendering his guilty plea a nullity. The conviction based on that plea must be quashed.

Parties
Prosecutor: Regina; Appellant: Danny Harold Nightingale
Jurisdiction
England and Wales
Judgment Date
13 March 2013
Procedural Posture
Criminal Appeal / Appeal Against Conviction and Sentence
Outcome
Appeal allowed; conviction quashed; retrial ordered
Legal Topics
Firearms Offences, Court Martial Procedure, Guilty Pleas, Judicial Sentence Indication, Freedom of Choice in Plea

Case Brief

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Parties

Regina

Prosecutor

Danny Harold Nightingale

Appellant

Procedural Posture

Criminal Appeal / Appeal Against Conviction and Sentence

  1. 1 Whether the Judge Advocate's uninvited sentence indication improperly pressured the appellant to plead guilty
  2. 2 Whether the guilty plea was valid given the circumstances of judicial indication

Ratio Decidendi

The Judge Advocate's uninvited sentence indication created inappropriate additional pressure on the appellant, improperly narrowing his freedom of choice and rendering his guilty plea a nullity. The conviction based on that plea must be quashed.

Court Disposition

Appeal allowed; conviction quashed; retrial ordered

Orders

  • Guilty plea set aside as a nullity
  • Conviction quashed