R v Patrick John Ryan
The absence of a clear and properly crafted cross admissibility direction left the jury in a position where they may have improperly used evidence from one complainant as propensity evidence against the other, rendering the convictions unsafe. The other grounds of appeal and the application to admit fresh evidence were without merit.
- 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
- Outcome
- Appeal allowed, convictions quashed, retrial ordered
- Legal Topics
- Sexual Offences, Appeal Against Conviction, Fresh Evidence, Jury Directions, Cross Admissibility
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
Legal Issues
- 1 Whether the trial judge failed to give proper directions on cross admissibility of evidence between complainants
- 2 Whether the judge failed to give appropriate directions regarding alleged lies and adverse inferences
- 3 Whether fresh evidence should be admitted on appeal
Ratio Decidendi
The absence of a clear and properly crafted cross admissibility direction left the jury in a position where they may have improperly used evidence from one complainant as propensity evidence against the other, rendering the convictions unsafe. The other grounds of appeal and the application to admit fresh evidence were without merit.
Court Disposition
Appeal allowed, convictions quashed, retrial ordered
Orders
- Extension of time granted
- Leave to appeal granted
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