Hong Kong Case Law: Decisions & Judgments | LexChat

Hong Kong Case Law

Issue estoppel in criminal proceedings
  • 19 Nov 1999

    HKSAR v. CHING CHIN PANG

    Citation
    HKSAR v. CHING CHIN PANG
    Court
    Court of First Instance
    Case number
    HCMA732/1999

    The acquittal under the Dutiable Commodities Ordinance did not bar prosecution and conviction under the Dangerous Goods (General) Regulations because the two offences have different statutory ingredients and gravamen; issue estoppel and autrefois acquit do not apply where charges are different; prior rulings on admissibility do not preclude re‑admission at a subsequent trial; the magistrate was entitled to infer fumes and thus knowledge from the facts; conviction was therefore upheld while the custodial element of sentence was quashed as manifestly excessive.