Crown Prosecution Service v Inegbu

Crown Prosecution Service v Inegbu

The court held that section 46(4) of the Railways Act 2005, read with the Interpretation Act 1978, preserved not only the effect of byelaws made under the Transport Act 2000 but also the procedural mechanism for proving them by certification. The District Judge erred in holding otherwise.

Parties
Claimant: Crown Prosecution Service; Defendant: Inegbu
Jurisdiction
England and Wales
Judgment Date
26 November 2008
Procedural Posture
Criminal Appeal by Way of Case Stated / High Court Appeal From Magistrates' Court
Outcome
Appeal allowed
Legal Topics
Railway Byelaws, Proof of Byelaws, Transitional Provisions, Certification of Byelaws

Case Brief

Summary, issues, holding and outcome

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Parties

Crown Prosecution Service

Claimant

Inegbu

Defendant

Procedural Posture

Criminal Appeal by Way of Case Stated / High Court Appeal From Magistrates' Court

  1. 1 Whether the mechanism for proving railway byelaws made under the Transport Act 2000 was preserved after repeal by the Railways Act 2005, specifically regarding certification under Schedule 20 of the 2000 Act.

Ratio Decidendi

The court held that section 46(4) of the Railways Act 2005, read with the Interpretation Act 1978, preserved not only the effect of byelaws made under the Transport Act 2000 but also the procedural mechanism for proving them by certification. The District Judge erred in holding otherwise.

Court Disposition

Appeal allowed

Orders

  • No retrial ordered; matter not remitted to Magistrates' Court.
  • Respondent to pay appellant's costs of these proceedings, subject to detailed assessment and consideration by the costs judge.