Coombes v DPP

Coombes v DPP

Conviction for speeding cannot be sustained where the statutory requirement for adequate guidance via traffic signs is not met; signs must convey the speed limit to a reasonable motorist in sufficient time to reduce speed before entering the restricted stretch.

Parties
Claimant: John Coombes; Defendant: DPP
Jurisdiction
England and Wales
Judgment Date
20 December 2006
Procedural Posture
Appeal / Judgment
Outcome
Appeal allowed
Legal Topics
Speeding Offences, Traffic Signs, Statutory Interpretation
Criminal Law Traffic Law Speeding Offences Traffic Signs Statutory Interpretation

Case Brief

Summary, issues, holding and outcome

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Parties

John Coombes

Claimant

DPP

Defendant

Procedural Posture

Appeal / Judgment

Legal Issues

  1. 1 Whether obscured speed limit signs constitute a failure to 'maintain' under s.85 of the Road Traffic Regulation Act 1984
  2. 2 Whether visibility of only one speed limit sign is sufficient for conviction
  3. 3 Whether signs visible only at the point of passing are sufficiently erected and maintained

Ratio Decidendi

Conviction for speeding cannot be sustained where the statutory requirement for adequate guidance via traffic signs is not met; signs must convey the speed limit to a reasonable motorist in sufficient time to reduce speed before entering the restricted stretch.

Court Disposition

Appeal allowed

Orders

  • Conviction quashed