Ryan, R. v [2021] EWCA Crim 262 (05 March 2021)
The absence of a clear and proper cross-admissibility direction to the jury regarding the evidence of multiple complainants created ambiguity and left the jury without necessary guidance on how to use such evidence, rendering the convictions unsafe.
- Citation
- [2021] EWCA Crim 262
- Parties
- Applicant/appellant: Regina; Respondent: Patrick John Ryan
- Jurisdiction
- England and Wales
- Judgment Date
- 05 March 2021
- Procedural Posture
- Criminal Appeal / Appeal Against Conviction After Trial at Woolwich Crown Court
- Outcome
- Appeal allowed; convictions quashed; retrial ordered.
- Legal Topics
- Sexual Offences, Appeal Against Conviction, Cross Admissibility of Evidence, Fresh Evidence, Jury Directions
Case Brief
Summary, issues, holding and outcome
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Parties
Regina
Applicant/appellant
Patrick John Ryan
Respondent
Procedural Posture
Criminal Appeal / Appeal Against Conviction After Trial at Woolwich Crown Court
Legal Issues
- 1 Whether the trial judge erred in failing to give a cross-admissibility direction regarding evidence from multiple complainants
- 2 Whether fresh evidence should be admitted on appeal
- 3 Whether the absence of certain jury directions rendered the conviction unsafe
Ratio Decidendi
The absence of a clear and proper cross-admissibility direction to the jury regarding the evidence of multiple complainants created ambiguity and left the jury without necessary guidance on how to use such evidence, rendering the convictions unsafe.
Court Disposition
Appeal allowed; convictions quashed; retrial ordered.
Orders
- Extension of time granted and leave to appeal given.
- Convictions quashed.
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