T, R. v (Rev 1) [2021] EWCA Crim 318 (25 February 2021)

T, R. v (Rev 1) [2021] EWCA Crim 318 (25 February 2021)

In the circumstances of this case, questions regarding the complainant's sexual orientation and identity constituted 'sexual behaviour' under section 41 of the 1999 Act, required leave, and were properly excluded by the trial judge as speculative, irrelevant, and aimed at impugning credibility. The exclusion did not render the trial unfair.

Citation
[2021] EWCA Crim 318
Parties
Appellant: T; Respondent: Regina (The Crown)
Jurisdiction
England and Wales
Judgment Date
25 February 2021
Procedural Posture
Criminal Appeal / Appeal Against Conviction
Outcome
Appeal dismissed
Legal Topics
Rape, Cross Examination, Sexual History Evidence, Section 41 Youth Justice and Criminal Evidence Act 1999, Sexual Orientation, Fair Trial

Case Brief

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Parties

T

Appellant

Regina (The Crown)

Respondent

Procedural Posture

Criminal Appeal / Appeal Against Conviction

  1. 1 Whether questions regarding the complainant's sexual orientation and identity constitute 'sexual behaviour' under section 41 of the Youth Justice and Criminal Evidence Act 1999
  2. 2 Whether refusal to allow such cross-examination rendered the trial unfair

Ratio Decidendi

In the circumstances of this case, questions regarding the complainant's sexual orientation and identity constituted 'sexual behaviour' under section 41 of the 1999 Act, required leave, and were properly excluded by the trial judge as speculative, irrelevant, and aimed at impugning credibility. The exclusion did not render the trial unfair.

Court Disposition

Appeal dismissed