Dent, R v

Dent, R v

Non-disclosed material and missing records were either inadmissible, of marginal relevance, or not determinative; only Counts 2 and 3 were impermissibly prosecuted and convictions on those counts are quashed; remaining convictions are safe.

Parties
Prosecution: Regina; Appellant: John Dent
Jurisdiction
England and Wales
Judgment Date
18 March 2014
Procedural Posture
Criminal Appeal / Judgment on Appeal From CCRC Reference
Outcome
Appeal dismissed save for quashing convictions on Counts 2 and 3.
Legal Topics
Sexual Offences, Historic Abuse, Non Disclosure, Credibility of Witnesses, Admissibility of Evidence
Criminal Law Sexual Offences Historic Abuse Non Disclosure Credibility of Witnesses Admissibility of Evidence

Case Brief

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Parties

Regina

Prosecution

John Dent

Appellant

Procedural Posture

Criminal Appeal / Judgment on Appeal From CCRC Reference

Legal Issues

  1. 1 Whether non-disclosure of material relating to the truthfulness of complainant CF rendered the conviction unsafe
  2. 2 Whether prosecution for indecent assault outside the statutory time limit was permissible
  3. 3 Whether missing contemporaneous documents affected the possibility of the offence alleged in Count 4

Ratio Decidendi

Non-disclosed material and missing records were either inadmissible, of marginal relevance, or not determinative; only Counts 2 and 3 were impermissibly prosecuted and convictions on those counts are quashed; remaining convictions are safe.

Court Disposition

Appeal dismissed save for quashing convictions on Counts 2 and 3.

Orders

  • Convictions on Counts 2 and 3 quashed.
  • Remaining convictions upheld.