R v Rimon Ali

R v Rimon Ali

All categories of electronic data from which the prosecution relied on extracts (including web history, web log entries, instant messages, and notes) should be included in the PPE count. The methodology of removing blank columns and using a print preview to derive the page count from spreadsheets is sensible and realistic, provided it does not artificially compress or manipulate the data. The correct PPE count is 2,023, and the appeal succeeds to that extent.

Parties
Prosecution: R; Defendant: Rimon Ali
Jurisdiction
England and Wales
Judgment Date
07 February 2024
Procedural Posture
Criminal Costs Appeal / Appeal Judgment
Outcome
Appeal allowed in part
Legal Topics
Legal Aid Remuneration, Litigators’ Graduated Fee Scheme, Electronic Evidence, Pages of Prosecution Evidence (ppe) Calculation
Criminal Law Legal Costs Legal Aid Remuneration Litigators’ Graduated Fee Scheme Electronic Evidence Pages of Prosecution Evidence (ppe) Calculation

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Parties

R

Prosecution

Rimon Ali

Defendant

Procedural Posture

Criminal Costs Appeal / Appeal Judgment

Legal Issues

  1. 1 What categories of electronic data should be included in the PPE count for the purposes of the Litigators’ Graduated Fee Scheme under the Criminal Legal Aid (Remuneration) Regulations 2013?
  2. 2 What is the correct methodology for deriving a page count from electronic evidence served in spreadsheet format?

Ratio Decidendi

All categories of electronic data from which the prosecution relied on extracts (including web history, web log entries, instant messages, and notes) should be included in the PPE count. The methodology of removing blank columns and using a print preview to derive the page count from spreadsheets is sensible and realistic, provided it does not artificially compress or manipulate the data. The correct PPE count is 2,023, and the appeal succeeds to that extent.

Court Disposition

Appeal allowed in part

Orders

  • The PPE count is set at 2,023 pages.
  • The Appellant is awarded an additional payment based on the revised PPE count.