Denton, R. v [1981] EWCA Crim 4 (22 October 1981)

Denton, R. v [1981] EWCA Crim 4 (22 October 1981)

The conviction was quashed because the trial judge erred in law by holding that the owner's consent was not a lawful excuse due to the fraudulent purpose; under the Criminal Damage Act 1971, consent of the owner suffices for lawful excuse regardless of motive, and the appellant's belief in such consent was sufficient.

Citation
[1981] EWCA Crim 4
Parties
Appellant: John Thomas Denton; Respondent: Crown
Jurisdiction
England and Wales
Judgment Date
22 October 1981
Procedural Posture
Criminal Appeal / Appeal Against Conviction
Outcome
conviction quashed, appeal allowed
Legal Topics
Arson, Lawful Excuse, Criminal Damage Act 1971, Consent to Damage, Insurance Fraud

Case Brief

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Parties

John Thomas Denton

Appellant

Crown

Respondent

Procedural Posture

Criminal Appeal / Appeal Against Conviction

  1. 1 Whether consent of the property owner to arson for fraudulent purposes constitutes a lawful excuse under section 5(2) of the Criminal Damage Act 1971
  2. 2 Whether the trial judge erred in law by ruling that 'entitled' in section 5(2) requires general lawfulness beyond private title

Ratio Decidendi

The conviction was quashed because the trial judge erred in law by holding that the owner's consent was not a lawful excuse due to the fraudulent purpose; under the Criminal Damage Act 1971, consent of the owner suffices for lawful excuse regardless of motive, and the appellant's belief in such consent was sufficient.

Court Disposition

conviction quashed, appeal allowed

Orders

  • Conviction on the second count quashed
  • Prosecution costs to be paid out of central funds