DPP v Janman [2004] EWHC 101 (Admin) (22 January 2004)

DPP v Janman [2004] EWHC 101 (Admin) (22 January 2004)

A person supervising a learner driver is in charge of the vehicle for the purposes of section 5(1)(b) regardless of statutory qualification, and the defence under section 5(2) was not established on the facts as the statutory purpose of supervision implies a likelihood of driving.

Citation
[2004] EWHC 101 (Admin)
Parties
Claimant: DPP; Defendant: Janman
Jurisdiction
England and Wales
Judgment Date
22 January 2004
Procedural Posture
Appeal by Way of Case Stated / High Court, Queen's Bench Division, Divisional Court
Outcome
appeal allowed
Legal Topics
Supervision of Learner Drivers, Driving Under Influence, Section 5 Road Traffic Act 1988, Defence Under Section 5(2)

Case Brief

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Parties

DPP

Claimant

Janman

Defendant

Procedural Posture

Appeal by Way of Case Stated / High Court, Queen's Bench Division, Divisional Court

  1. 1 Whether a supervisor of a learner driver is 'in charge' under section 5(1)(b) Road Traffic Act 1988
  2. 2 Whether the defence under section 5(2) is available to a supervisor who claims no likelihood of driving
  3. 3 Whether statutory qualification to supervise is required for 'in charge' status

Ratio Decidendi

A person supervising a learner driver is in charge of the vehicle for the purposes of section 5(1)(b) regardless of statutory qualification, and the defence under section 5(2) was not established on the facts as the statutory purpose of supervision implies a likelihood of driving.

Court Disposition

appeal allowed

Orders

  • case remitted to justices with direction to convict