HM Advocate v Stewart & Anor [2010] ScotHC HCJAC_25 (26 February 2010)

HM Advocate v Stewart & Anor [2010] ScotHC HCJAC_25 (26 February 2010)

Charge 4 is relevant as it libels two contemporaneous crimes, abduction and assault, with sufficient factual averments and fair notice. The inclusion of both crimes in one charge does not prejudice the defence or impede fair trial, and procedural mechanisms exist to address partial submissions and special defences.

Citation
[2010] ScotHC HCJAC_25
Parties
Appellant: Elish Angiolini; First Respondent: Lee Donald Stewart; Second Respondent: Colin Stewart
Jurisdiction
Scotland
Judgment Date
26 February 2010
Procedural Posture
Criminal Appeal / Appeal Against Dismissal of Charge at First Diet
Outcome
appeal allowed
Legal Topics
Charge Relevancy, Plurality of Crimes, Abduction, Assault, Fair Notice, Special Defence

Case Brief

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Parties

Elish Angiolini

Appellant

Lee Donald Stewart

First Respondent

Colin Stewart

Second Respondent

Procedural Posture

Criminal Appeal / Appeal Against Dismissal of Charge at First Diet

  1. 1 Whether Charge 4, libelling abduction and assault in one charge, is irrelevant
  2. 2 Whether the framing of Charge 4 prejudices the defence or impedes fair trial

Ratio Decidendi

Charge 4 is relevant as it libels two contemporaneous crimes, abduction and assault, with sufficient factual averments and fair notice. The inclusion of both crimes in one charge does not prejudice the defence or impede fair trial, and procedural mechanisms exist to address partial submissions and special defences.

Court Disposition

appeal allowed

Orders

  • sheriff's decision dismissing Charge 4 reversed
  • case remitted to sheriff to proceed as accords