S & Anor, R v

S & Anor, R v

Compelled disclosure of encryption keys under section 53 RIPA does not violate privilege against self-incrimination where the material exists independently of the will of the accused; statutory safeguards and proportionality ensure compliance with Article 6 ECHR; prosecution is not abusive.

Parties
Prosecution: R; Appellant: S; Appellant: A
Jurisdiction
England and Wales
Judgment Date
09 October 2008
Procedural Posture
Criminal Appeal / Interlocutory Appeal From Preparatory Hearing
Outcome
appeal dismissed
Legal Topics
Privilege Against Self Incrimination, Encrypted Evidence, Regulation of Investigatory Powers Act, European Convention on Human Rights, Proportionality, Abuse of Process

Case Brief

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Downloadable case file Legal principles 5 Authorities cited 19 Party arguments 2
Sign in to unlock

Parties

R

Prosecution

S

Appellant

A

Appellant

Procedural Posture

Criminal Appeal / Interlocutory Appeal From Preparatory Hearing

  1. 1 Whether compelled disclosure of encryption keys under section 53 of RIPA violates privilege against self-incrimination
  2. 2 Compatibility of section 53 RIPA with Article 6 ECHR
  3. 3 Whether prosecution under section 53 RIPA should be stayed as abuse of process

Ratio Decidendi

Compelled disclosure of encryption keys under section 53 RIPA does not violate privilege against self-incrimination where the material exists independently of the will of the accused; statutory safeguards and proportionality ensure compliance with Article 6 ECHR; prosecution is not abusive.

Court Disposition

appeal dismissed

Orders

  • Leave to appeal granted; appeals dismissed; prosecution under section 53 RIPA may proceed.