Haydon v Rex [2026] EWCA Crim 12 (21 January 2026)

Haydon v Rex [2026] EWCA Crim 12 (21 January 2026)

The word 'likely' in section 2 of the Explosive Substances Act 1883 means 'could well happen' in context, not 'more likely than not'; the judge's directions and evidentiary rulings were correct; the mental element required is intention or recklessness as to causing an explosion, not as to its magnitude or consequences.

Source-derived case information.

Citation
[2026] EWCA Crim 12
Parties
Appellant: Matthew Haydon; Respondent: Rex
Jurisdiction
England and Wales
Judgment Date
21 January 2026
Procedural Posture
Criminal Appeal / Appeal Against Conviction From Central Criminal Court to Court of Appeal (criminal Division)
Outcome
Appeal dismissed
Legal Topics
Explosive Substances Act 1883, Jury Directions, Admissibility of Evidence, Mens Rea, Statutory Interpretation
Criminal Law Explosive Substances Act 1883 Jury Directions Admissibility of Evidence Mens Rea Statutory Interpretation

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Parties

Matthew Haydon

Appellant

Rex

Respondent

Procedural Posture

Criminal Appeal / Appeal Against Conviction From Central Criminal Court to Court of Appeal (criminal Division)

Legal Issues

  1. 1 Proper interpretation of 'likely' in section 2 of the Explosive Substances Act 1883
  2. 2 Admissibility of prejudicial evidence under section 78 of the Police and Criminal Evidence Act 1984
  3. 3 Required mental element (mens rea) for section 2 offence under the 1883 Act

Ratio Decidendi

The word 'likely' in section 2 of the Explosive Substances Act 1883 means 'could well happen' in context, not 'more likely than not'; the judge's directions and evidentiary rulings were correct; the mental element required is intention or recklessness as to causing an explosion, not as to its magnitude or consequences.

Court Disposition

Appeal dismissed