Arowolo v Department for Work and Pensions

Arowolo v Department for Work and Pensions

The magistrates were entitled to admit secondary evidence of the application form after finding the original could not be found and a reasonable explanation was given. The evidence, including the interview, was sufficient to prove the appellant knowingly failed to disclose the accounts. The best evidence rule did not require more, and hearsay was admissible by agreement.

Parties
Claimant: Arowolo; Defendant: Department for Work and Pensions
Jurisdiction
England and Wales
Judgment Date
30 April 2013
Procedural Posture
Criminal Appeal (case Stated) / Judgment on Appeal
Outcome
Appeal dismissed
Legal Topics
Best Evidence Rule, Admissibility of Secondary Evidence, Hearsay, Social Security Fraud

Case Brief

Summary, issues, holding and outcome

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Parties

Arowolo

Claimant

Department for Work and Pensions

Defendant

Procedural Posture

Criminal Appeal (case Stated) / Judgment on Appeal

  1. 1 Whether the magistrates were entitled to convict without the original job seekers allowance application form
  2. 2 Whether secondary evidence of the form's contents was admissible
  3. 3 Whether a sufficient search for the original form was conducted

Ratio Decidendi

The magistrates were entitled to admit secondary evidence of the application form after finding the original could not be found and a reasonable explanation was given. The evidence, including the interview, was sufficient to prove the appellant knowingly failed to disclose the accounts. The best evidence rule did not require more, and hearsay was admissible by agreement.

Court Disposition

Appeal dismissed

Orders

  • Detailed assessment of the claimant's publicly funded costs