O'Neil, R v

O'Neil, R v

The conviction for escape was quashed because, on the agreed facts, the offence had not been committed in law, and the court's power to substitute a conviction for the summary offence under the Prisoners (Return to Custody) Act 1995 did not arise.

Parties
Applicant: James O'Neil; Respondent: Regina
Jurisdiction
England and Wales
Judgment Date
14 November 2007
Procedural Posture
Criminal Appeal / Judgment
Outcome
appeal allowed
Legal Topics
Escape, Summary Offences, Plea of Guilty, Substitution of Conviction

Case Brief

Summary, issues, holding and outcome

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Parties

James O'Neil

Applicant

Regina

Respondent

Procedural Posture

Criminal Appeal / Judgment

  1. 1 Whether failure to return from home leave constitutes the offence of escape
  2. 2 Whether the court can substitute a conviction for the offence under the Prisoners (Return to Custody) Act 1995

Ratio Decidendi

The conviction for escape was quashed because, on the agreed facts, the offence had not been committed in law, and the court's power to substitute a conviction for the summary offence under the Prisoners (Return to Custody) Act 1995 did not arise.

Court Disposition

appeal allowed

Orders

  • conviction quashed