Caselaw Digest
Caselaw Digest

BKY & Ors v R

[2023] EWCA Crim 1095
A group of teenagers were found guilty of murder. They tried to appeal, saying the judge wasn't fair, but the appeal court disagreed and said the guilty verdicts were correct. One of them also appealed their sentence, but that was also rejected.

Key Facts

  • Jack Woodley was stabbed to death by a group of youths on October 16, 2021.
  • Ten young appellants were convicted of murder after a trial at Newcastle Crown Court.
  • The appellants were aged between 14 and 17 at the time of the offense.
  • Calum Maddison inflicted the fatal stab wound.
  • The prosecution case was that all appellants were jointly engaged in attacking Woodley with a common purpose to cause really serious injury.
  • The attack was captured on CCTV and mobile phone video.
  • The trial suffered significant delays due to the Covid-19 pandemic.
  • A two-week break occurred in the trial between closing speeches and the judge's summing up of the facts.

Legal Principles

A judge must not descend into the arena and give the impression of acting as an advocate.

R v Hulusi (1974) 58 CAR 378

The summing up of the facts must deal with the essentials of the case and must strike a fair balance between the prosecution and defence cases.

R v Haddon [2020] EWCA Crim 887

The judge is entitled to comment on the evidence by pointing out matters which may tend to support or undermine either party’s case, but the judge’s review of the evidence should be objective and impartial.

R v Merchant [2018] EWCA Crim 2606

The guiding principle in summing up must always be balance and fairness. An objective marshalling and presentation of the evidence is a feature of every good summing-up.

R v Awil [2020] EWCA Crim 1802

Paragraph 3(a) of Part 25.14 of the Criminal Procedure Rules requires a judge to give the jurors directions about the relevant law and to summarise for them the evidence relevant to the issues they must decide.

Criminal Procedure Rules (as amended with effect from 4 April 2022)

Section 45 of the Youth Justice and Criminal Evidence Act 1999 allows for reporting restrictions to protect the identities of young offenders.

Youth Justice and Criminal Evidence Act 1999

Section 100 of the Criminal Justice Act 2003 governs the admissibility of bad character evidence.

Criminal Justice Act 2003

Outcomes

Appeals against conviction dismissed.

The Court of Appeal found that the judge's summing up, while containing minor imperfections, was overall fair and balanced, and did not render the convictions unsafe. The two-week break, while unfortunate, did not, in itself, make the convictions unsafe, and the judge's efforts to summarise the evidence after the break were sufficient.

Mayo's appeal against sentence dismissed.

The Court of Appeal found the minimum 11-year sentence imposed on Mayo was within the appropriate range, considering the aggravating and mitigating factors.

Maddison's application for an extension of time and leave to appeal dismissed.

The Court found no grounds for an appeal based on the summing-up.

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