McInerney, R. v [2024] EWCA Crim 165 (06 February 2024)

McInerney, R. v [2024] EWCA Crim 165 (06 February 2024)

It is impermissible for defence counsel to suggest speculative reasons for a defendant's silence in the absence of supporting evidence; the trial judge was correct to prevent such submissions, and the conviction is safe.

Citation
[2024] EWCA Crim 165
Parties
Prosecution: Rex; Applicant: Steven McInerney
Jurisdiction
England and Wales
Judgment Date
06 February 2024
Procedural Posture
Criminal Appeal / Renewed Application for Leave to Appeal Against Conviction
Outcome
application dismissed
Legal Topics
Adverse Inference From Silence, Jury Directions, Murder, Joint Enterprise, Grounds for Appeal

Case Brief

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Parties

Rex

Prosecution

Steven McInerney

Applicant

Procedural Posture

Criminal Appeal / Renewed Application for Leave to Appeal Against Conviction

  1. 1 Whether the trial judge erred in preventing defence counsel from suggesting possible reasons for the applicant's silence at trial beyond those supported by evidence
  2. 2 Whether the conviction is unsafe due to alleged unfairness in summing up and directions to the jury

Ratio Decidendi

It is impermissible for defence counsel to suggest speculative reasons for a defendant's silence in the absence of supporting evidence; the trial judge was correct to prevent such submissions, and the conviction is safe.

Court Disposition

application dismissed

Orders

  • renewed application for leave to appeal against conviction is dismissed
  • three-day extension of time to apply for leave to appeal is granted