Bond, R. v [2022] EWCA Crim 427 (24 March 2022)

Bond, R. v [2022] EWCA Crim 427 (24 March 2022)

The SFO's failure to disclose material relevant to the admissibility and reliability of BAJ's guilty pleas was a serious breach of its disclosure obligations. This non-disclosure significantly handicapped the applicant's ability to present his case, as it did in Akle's case. The applicant was prevented from...

Source-derived case information.

Citation
[2022] EWCA Crim 427
Parties
Prosecution: Regina; Applicant: Paul Bond
Jurisdiction
England and Wales
Judgment Date
24 March 2022
Procedural Posture
Criminal Appeal / Application for Extension of Time and Appeal Against Conviction
Outcome
Appeal allowed; convictions quashed
Legal Topics
Disclosure Obligations, Abuse of Process, Admissibility of Evidence, Conspiracy to Give Corrupt Payments, Fair Trial Rights
Criminal Law Disclosure Obligations Abuse of Process Admissibility of Evidence Conspiracy to Give Corrupt Payments Fair Trial Rights

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Parties

Regina

Prosecution

Paul Bond

Applicant

Procedural Posture

Criminal Appeal / Application for Extension of Time and Appeal Against Conviction

Legal Issues

  1. 1 Whether the Serious Fraud Office (SFO) failed in its duty of disclosure under the Criminal Procedure and Investigations Act 1996 (CPIA)
  2. 2 Whether the non-disclosure of material relevant to the admissibility and reliability of a co-defendant's guilty pleas rendered the applicant's trial unfair
  3. 3 Whether the logic of the decision in R v Akle applies to the applicant's case

Ratio Decidendi

The SFO's failure to disclose material relevant to the admissibility and reliability of BAJ's guilty pleas was a serious breach of its disclosure obligations. This non-disclosure significantly handicapped the applicant's ability to present his case, as it did in Akle's case. The applicant was prevented from presenting his case in its best light, and his convictions are not safe.

Court Disposition

Appeal allowed; convictions quashed

Orders

  • Extension of time granted for application for leave to appeal against conviction
  • Leave to appeal against conviction granted