Robinson-Pierre v R

Robinson-Pierre v R

Section 3(1) of the Dangerous Dogs Act 1991 creates a strict liability offence but requires proof of an act or omission by the defendant that contributed to the dog being dangerously out of control in a public place. The trial judge erred in directing the jury that the owner's conduct was irrelevant, and the...

Source-derived case information.

Parties
Appellant: Symieon Robinson-Pierre; Respondent: Regina
Jurisdiction
England and Wales
Judgment Date
20 December 2013
Procedural Posture
Criminal Appeal / Appeal Against Conviction
Outcome
appeal allowed; conviction quashed
Legal Topics
Strict Liability, Dangerous Dogs, Causation, Public Safety, Statutory Interpretation
Criminal Law Strict Liability Dangerous Dogs Causation Public Safety Statutory Interpretation

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Parties

Symieon Robinson-Pierre

Appellant

Regina

Respondent

Procedural Posture

Criminal Appeal / Appeal Against Conviction

Legal Issues

  1. 1 Does section 3(1) of the Dangerous Dogs Act 1991 require proof of an act or omission by the owner causing the dog to be dangerously out of control in a public place?
  2. 2 Is liability under section 3(1) absolute or does it require some causal connection between the defendant's conduct and the prohibited state of affairs?

Ratio Decidendi

Section 3(1) of the Dangerous Dogs Act 1991 creates a strict liability offence but requires proof of an act or omission by the defendant that contributed to the dog being dangerously out of control in a public place. The trial judge erred in directing the jury that the owner's conduct was irrelevant, and the conviction is therefore unsafe.

Court Disposition

appeal allowed; conviction quashed

Orders

  • Conviction quashed
  • No order as to sentence as sentence already served