Director of Public Prosecutions -v- Wilson [2017] IESC 53 (13 July 2017)

Director of Public Prosecutions -v- Wilson [2017] IESC 53 (13 July 2017)

Section 19 of the Criminal Justice Act 1984 may not be utilised in a trial for an offence other than the offence in respect of which the inference caution was expressly invoked. The caution and opportunity for legal advice must relate to the same offence as the one ultimately prosecuted. Any other approach would require further legislation.

Citation
[2017] IESC 53
Parties
Respondent: Director of Public Prosecutions; Applicant/appellant: Alan Wilson
Jurisdiction
Ireland
Judgment Date
13 July 2017
Procedural Posture
Criminal Appeal / Supreme Court Appeal From Court of Appeal
Outcome
appeal allowed; conviction quashed
Legal Topics
Adverse Inferences, Statutory Interpretation, Right to Silence, Burglary, Firearms Offences

Case Brief

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Parties

Director of Public Prosecutions

Respondent

Alan Wilson

Applicant/appellant

Procedural Posture

Criminal Appeal / Supreme Court Appeal From Court of Appeal

  1. 1 Whether section 19 of the Criminal Justice Act 1984 may be utilised in a trial for an offence other than the offence about which the accused was questioned when the section was invoked

Ratio Decidendi

Section 19 of the Criminal Justice Act 1984 may not be utilised in a trial for an offence other than the offence in respect of which the inference caution was expressly invoked. The caution and opportunity for legal advice must relate to the same offence as the one ultimately prosecuted. Any other approach would require further legislation.

Court Disposition

appeal allowed; conviction quashed

Orders

  • Appeal allowed
  • Conviction quashed