Ibrahima Bah v R

Ibrahima Bah v R

The chain of causation was not broken by the voluntary actions of the deceased because the applicant and deceased acted in concert during a single criminal episode; duty of care was owed regardless of joint criminal enterprise; jury irregularity was not substantiated and did not affect the safety of the conviction;...

Source-derived case information.

Parties
Applicant: Ibrahima Bah; Respondent: Rex
Jurisdiction
England and Wales
Judgment Date
23 July 2025
Procedural Posture
Criminal Appeal / Judgment on Application for Leave to Appeal Against Conviction and Sentence
Outcome
Leave to appeal against conviction and sentence refused.
Legal Topics
Gross Negligence Manslaughter, Facilitation of Breach of Immigration Law, Causation, Duty of Care, Sentencing, Jury Irregularity
Criminal Law Gross Negligence Manslaughter Facilitation of Breach of Immigration Law Causation Duty of Care Sentencing Jury Irregularity

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Parties

Ibrahima Bah

Applicant

Rex

Respondent

Procedural Posture

Criminal Appeal / Judgment on Application for Leave to Appeal Against Conviction and Sentence

Legal Issues

  1. 1 Whether voluntary actions of deceased broke chain of causation for gross negligence manslaughter
  2. 2 Whether applicant owed duty of care to deceased despite joint criminal enterprise
  3. 3 Whether jury irregularity rendered conviction unsafe

Ratio Decidendi

The chain of causation was not broken by the voluntary actions of the deceased because the applicant and deceased acted in concert during a single criminal episode; duty of care was owed regardless of joint criminal enterprise; jury irregularity was not substantiated and did not affect the safety of the conviction; the sentence imposed was proportionate and reflected harm, culpability, mitigation, and totality.

Court Disposition

Leave to appeal against conviction and sentence refused.

Orders

  • Leave to appeal against conviction refused.
  • Leave to appeal against sentence refused.