Nigel Lloyd Hannon, R (on the application of) v The Crown Court at Bristol
[2024] EWHC 105 (Admin)
Simon Wiltshire, R (on the application of) v Crown Court at Bristol
17 November 2023
[2023] EWHC 2879 (Admin)
High Court
A truck driver was found guilty of careless driving. He appealed, but lost. He then sued, saying the judge didn't explain the decision clearly enough. The higher court disagreed, saying the judge's explanation, though short, was good enough to show why the driver was at fault.
Key Facts
- •Simon Wiltshire was convicted of careless driving in the Magistrates' Court.
- •His appeal to the Crown Court was dismissed.
- •Wiltshire brought judicial review proceedings, arguing inadequate reasons were given for the dismissal.
- •The Crown Court found Wiltshire's manoeuvre was reasonable if safe, but he failed to adequately assess its safety.
- •The Crown Court considered dashcam footage and witness testimonies.
Legal Principles
The Crown Court, in its appellate capacity, must give reasons for its decisions. These reasons need not be elaborate but must show the basis of the decision.
R v Harrow Crown Court, ex parte Dave [1994] 1 WLR 98
Reasons should be sufficient to enable the defendant to understand why he has been found guilty.
R (McGowan) v Brent Justices [2001] EWHC 814 (Admin)
A reasons challenge is more akin to judicial review than an appeal by way of case stated.
Section 28 of the Senior Courts Act 1981
Outcomes
Claim for judicial review dismissed.
The Court found the Crown Court's reasons were adequate. The Crown Court concluded Wiltshire was careless for not adequately assessing the safety of his manoeuvre before executing it. The Court rejected arguments of internal contradiction and inconsistency with the prosecution's opening.