R v Nevada Horatio Farrel

R v Nevada Horatio Farrel

The Recorder fatally incorporated the adult element of 'no realistic alternative' into the direction for the minor applicant, instead of the correct test of whether a reasonable person would do the act, rendering the conviction unsafe.

Parties
Applicant: Nevada Horatio Farrel; Respondent: The Crown
Jurisdiction
England and Wales
Judgment Date
26 May 2022
Procedural Posture
Criminal Appeal / Judgment on Appeal Against Conviction
Outcome
appeal allowed
Legal Topics
Misdirection, Modern Slavery Defence, Drug Offences, Youth Justice

Case Brief

Summary, issues, holding and outcome

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Parties

Nevada Horatio Farrel

Applicant

The Crown

Respondent

Procedural Posture

Criminal Appeal / Judgment on Appeal Against Conviction

  1. 1 Whether the Recorder misdirected the jury regarding the section 45 Modern Slavery Act 2015 defence for a minor
  2. 2 Whether the conviction is unsafe due to the misdirection

Ratio Decidendi

The Recorder fatally incorporated the adult element of 'no realistic alternative' into the direction for the minor applicant, instead of the correct test of whether a reasonable person would do the act, rendering the conviction unsafe.

Court Disposition

appeal allowed

Orders

  • application for leave granted
  • convictions quashed