Mark Twigg & Anor v R

Mark Twigg & Anor v R

The court held that section 3(1) of the Dangerous Dogs Act 1991 allows for more than one person to be 'for the time being in charge' of a dog, and that whether a person remains in charge after leaving the scene is a question of fact and degree for the jury. The evidence was sufficient for the jury to convict both applicants, and the sentencing was within the guideline range and not manifestly excessive.

Parties
First Applicant: Mark Twigg; Second Applicant: Joanne Bedford; Respondent: Rex
Jurisdiction
England and Wales
Judgment Date
14 May 2026
Procedural Posture
Criminal Appeal / Judgment on Applications for Leave to Appeal Against Conviction and Sentence
Outcome
Applications for leave to appeal against conviction and sentence refused.
Legal Topics
Dangerous Dogs Act 1991, Strict Liability, Causal Connection, Sentencing Guidelines, Joint Responsibility
Criminal Law Dangerous Dogs Act 1991 Strict Liability Causal Connection Sentencing Guidelines Joint Responsibility

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Parties

Mark Twigg

First Applicant

Joanne Bedford

Second Applicant

Rex

Respondent

Procedural Posture

Criminal Appeal / Judgment on Applications for Leave to Appeal Against Conviction and Sentence

Legal Issues

  1. 1 Whether more than one person can be 'for the time being in charge' of a dog under section 3(1) of the Dangerous Dogs Act 1991
  2. 2 Whether the first applicant had a case to answer for being in charge of the dog when absent from the scene
  3. 3 Whether the jury directions on joint charge were correct

Ratio Decidendi

The court held that section 3(1) of the Dangerous Dogs Act 1991 allows for more than one person to be 'for the time being in charge' of a dog, and that whether a person remains in charge after leaving the scene is a question of fact and degree for the jury. The evidence was sufficient for the jury to convict both applicants, and the sentencing was within the guideline range and not manifestly excessive.

Court Disposition

Applications for leave to appeal against conviction and sentence refused.

Orders

  • Leave to appeal against conviction refused for Mark Twigg.
  • Leave to appeal against sentence refused for Joanne Bedford.