Twigg & Anor, R. v [2026] EWCA Crim 587 (14 May 2026)

Twigg & Anor, R. v [2026] EWCA Crim 587 (14 May 2026)

The Court held that the question of whether a person is 'for the time being in charge' of a dog under section 3(1) Dangerous Dogs Act 1991 is a matter of fact and degree for the jury, and that more than one person can be in charge at the same time, even if not physically present. The trial judge's directions were correct, and there was sufficient evidence for the jury to convict the first applicant. The sentence imposed on the second applicant was within the proper range and not manifestly excessive.

Citation
[2026] EWCA Crim 587
Parties
First Applicant: Mark Twigg; Second Applicant: Joanne Bedford; Respondent: Rex
Jurisdiction
England and Wales
Judgment Date
14 May 2026
Procedural Posture
Criminal Appeal / Court of Appeal Judgment on Conviction and Sentence
Outcome
Applications for leave to appeal against conviction (first applicant) and sentence (second applicant) refused.
Legal Topics
Dangerous Dogs Act 1991, Strict Liability Offences, Being in Charge of a Dog, Causation in Criminal Law, Sentencing Guidelines
Criminal Law Dangerous Dogs Act 1991 Strict Liability Offences Being in Charge of a Dog Causation in Criminal Law Sentencing Guidelines

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Parties

Mark Twigg

First Applicant

Joanne Bedford

Second Applicant

Rex

Respondent

Procedural Posture

Criminal Appeal / Court of Appeal Judgment on Conviction and Sentence

Legal Issues

  1. 1 Whether the trial judge erred in dismissing the first applicant's submission of no case to answer under section 3(1) Dangerous Dogs Act 1991
  2. 2 Whether the jury directions on 'being in charge' were legally correct
  3. 3 Whether the verdicts were inconsistent as to joint responsibility

Ratio Decidendi

The Court held that the question of whether a person is 'for the time being in charge' of a dog under section 3(1) Dangerous Dogs Act 1991 is a matter of fact and degree for the jury, and that more than one person can be in charge at the same time, even if not physically present. The trial judge's directions were correct, and there was sufficient evidence for the jury to convict the first applicant. The sentence imposed on the second applicant was within the proper range and not manifestly excessive.

Court Disposition

Applications for leave to appeal against conviction (first applicant) and sentence (second applicant) refused.