R v Umal

R v Umal

The appeal partially succeeds. The court held that, in addition to the 4,204 PPE assessed by the Determining Officer, 175 pages of instant messaging data, 4 pages of attribution data, and 560 pages of images (5% of total images) should be included, giving a total PPE count of 4,943. The timeline and other sections were excluded as duplicative or not central to the case. Incorrect page referencing and additional work do not justify further PPE but may be subject to a special preparation claim.

Parties
Respondent: R; Defendant: UMAL
Jurisdiction
England and Wales
Judgment Date
05 July 2025
Procedural Posture
Criminal Costs Appeal / Appeal Judgment
Outcome
Appeal allowed in part
Legal Topics
Litigators’ Graduated Fee Scheme, Electronic Evidence Inclusion, Pages of Crown Evidence (ppe), Special Preparation Claims
Criminal Law Legal Aid Costs Litigators’ Graduated Fee Scheme Electronic Evidence Inclusion Pages of Crown Evidence (ppe) Special Preparation Claims

Case Brief

Summary, issues, holding and outcome

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Parties

R

Respondent

UMAL

Defendant

Procedural Posture

Criminal Costs Appeal / Appeal Judgment

Legal Issues

  1. 1 Whether additional electronic evidence should be included in the PPE count for legal aid remuneration
  2. 2 Whether timelines and images from mobile phone downloads should be included in the PPE
  3. 3 Whether incorrect page referencing and additional work justify increased PPE

Ratio Decidendi

The appeal partially succeeds. The court held that, in addition to the 4,204 PPE assessed by the Determining Officer, 175 pages of instant messaging data, 4 pages of attribution data, and 560 pages of images (5% of total images) should be included, giving a total PPE count of 4,943. The timeline and other sections were excluded as duplicative or not central to the case. Incorrect page referencing and additional work do not justify further PPE but may be subject to a special preparation claim.

Court Disposition

Appeal allowed in part

Orders

  • The PPE count is increased to 4,943 pages.
  • The appropriate additional payment is to be made to the Applicant, including £500 for costs and the £100 paid on appeal.