Grant, R. v

Grant, R. v

The conviction for contempt was unsafe due to lack of procedural safeguards, including failure to enquire whether the appellant admitted the conduct, insufficient investigation, and failure to consider apology and provocation; the sentence was also inappropriate due to lack of enquiry into means.

Parties
Appellant: Ras Grant; Respondent: Regina (The Crown)
Jurisdiction
England and Wales
Judgment Date
02 February 2010
Procedural Posture
Criminal Appeal / Judgment on Appeal Against Conviction and Sentence
Outcome
conviction quashed
Legal Topics
Summary Contempt, Procedural Safeguards, Sentencing, Courtroom Conduct
Criminal Law Contempt of Court Summary Contempt Procedural Safeguards Sentencing Courtroom Conduct

Case Brief

Summary, issues, holding and outcome

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Parties

Ras Grant

Appellant

Regina (The Crown)

Respondent

Procedural Posture

Criminal Appeal / Judgment on Appeal Against Conviction and Sentence

Legal Issues

  1. 1 Whether the summary conviction for contempt of court was safe given the procedural safeguards
  2. 2 Whether the sentence imposed was appropriate given the appellant's means

Ratio Decidendi

The conviction for contempt was unsafe due to lack of procedural safeguards, including failure to enquire whether the appellant admitted the conduct, insufficient investigation, and failure to consider apology and provocation; the sentence was also inappropriate due to lack of enquiry into means.

Court Disposition

conviction quashed

Orders

  • conviction for contempt of court quashed
  • sentence of £1,000 fine quashed