Elvis Skeete v R

Elvis Skeete v R

The judge's decision not to discharge the entire jury, and instead to require each juror to confirm their impartiality through direct questioning, was within the range of reasonable responses to the concern raised. The steps taken were sufficient to dispel any real danger of bias, and the verdict was safe.

Parties
Appellant: Elvis Skeete; Respondent: Rex
Jurisdiction
England and Wales
Judgment Date
17 November 2022
Procedural Posture
Criminal Appeal / Judgment on Appeal Against Conviction
Outcome
appeal dismissed
Legal Topics
Rape, Jury Bias, Jury Discharge, Majority Verdict, Criminal Procedure
Criminal Law Rape Jury Bias Jury Discharge Majority Verdict Criminal Procedure

Case Brief

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Downloadable case file Legal principles 4 Authorities cited 9 Party arguments 2 Amounts and remedies 1
Sign in to unlock

Parties

Elvis Skeete

Appellant

Rex

Respondent

Procedural Posture

Criminal Appeal / Judgment on Appeal Against Conviction

Legal Issues

  1. 1 Whether the presence of jurors with personal experience of sexual assault created apparent bias rendering the verdict unsafe
  2. 2 Whether the trial judge erred in refusing to discharge the entire jury after a note raised concerns about possible bias
  3. 3 Whether the discharge of individual jurors for personal reasons during deliberations was a material irregularity

Ratio Decidendi

The judge's decision not to discharge the entire jury, and instead to require each juror to confirm their impartiality through direct questioning, was within the range of reasonable responses to the concern raised. The steps taken were sufficient to dispel any real danger of bias, and the verdict was safe.

Court Disposition

appeal dismissed