APPEAL AGAINST CONVICTION BY EM AGAINST HMA [2024] ScotHC HCJAC_9 (22 February 2024)

APPEAL AGAINST CONVICTION BY EM AGAINST HMA [2024] ScotHC HCJAC_9 (22 February 2024)

There was no misdirection by the trial judge regarding the use of the communications between the complainer and KP. The jury was made aware that only distress evidence could corroborate lack of consent. The absence of a specific direction did not amount to a miscarriage of justice.

Citation
[2024] ScotHC HCJAC_9
Parties
Appellant: EM; Respondent: His Majesty's Advocate
Jurisdiction
Scotland
Judgment Date
22 February 2024
Procedural Posture
Criminal Appeal / Appeal Against Conviction
Outcome
Appeal dismissed
Legal Topics
Rape, Corroboration, Jury Directions, Consent

Case Brief

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Parties

EM

Appellant

His Majesty's Advocate

Respondent

Procedural Posture

Criminal Appeal / Appeal Against Conviction

  1. 1 Whether the trial judge erred by failing to direct the jury specifically on the use of communications between the complainer and KP as corroboration of lack of consent
  2. 2 Whether such failure resulted in a miscarriage of justice

Ratio Decidendi

There was no misdirection by the trial judge regarding the use of the communications between the complainer and KP. The jury was made aware that only distress evidence could corroborate lack of consent. The absence of a specific direction did not amount to a miscarriage of justice.

Court Disposition

Appeal dismissed