AG v Quinn (Royal Court : Hearing (Criminal) : Binnington) [2025] JRC 322 (2 December 2025)

AG v Quinn (Royal Court : Hearing (Criminal) : Binnington) [2025] JRC 322 (2 December 2025)

The Defendant's previous convictions for violence are admissible under Article 82F as they are capable of establishing a propensity to commit offences of the kind charged, and the similarities between the prior convictions and the present charge justify their admission. The time elapsed does not render them...

Source-derived case information.

Citation
[2025] JRC 322
Parties
Applicant: The Crown; Defendant: [Defendant's Name Not Provided]; Complainant: Cameron Smith
Jurisdiction
Jersey
Judgment Date
02 December 2025
Procedural Posture
Criminal / Pre Trial Applications
Outcome
Applications granted in part
Legal Topics
Bad Character Evidence, Expert Evidence, Self Defence, Propensity, Admissibility of Evidence
Criminal Law Evidence Bad Character Evidence Expert Evidence Self Defence Propensity Admissibility of Evidence

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Parties

The Crown

Applicant

[Defendant's Name Not Provided]

Defendant

Cameron Smith

Complainant

Procedural Posture

Criminal / Pre Trial Applications

Legal Issues

  1. 1 Whether the Crown may adduce evidence of the Defendant's bad character at trial under the Police Procedure and Criminal Evidence (Jersey) Law 2003
  2. 2 Whether the Crown may adduce expert evidence regarding the degree of force used to cause the Complainant's injuries

Ratio Decidendi

The Defendant's previous convictions for violence are admissible under Article 82F as they are capable of establishing a propensity to commit offences of the kind charged, and the similarities between the prior convictions and the present charge justify their admission. The time elapsed does not render them inadmissible. The Crown is also permitted to adduce expert evidence regarding the degree of force used, as this is outside the jury's ordinary experience and relevant to the issue of self-defence.

Court Disposition

Applications granted in part

Orders

  • Leave granted to the Crown to adduce evidence of the Defendant's bad character under Article 82F of the Police Procedure and Criminal Evidence (Jersey) Law 2003.
  • Leave granted to the Crown to adduce expert evidence from Dr Deryn Evans regarding the degree of force used to cause the Complainant's injuries.