/URI (https://eprints.bbk.ac.uk/id/eprint/16447/) Will that significant difference in label and sentence constitute the substantial injustice required for the grant of exceptional leave? The Supreme Court quickly suppressed any hope of wholesale correction. % Laird Criminal Law Review ZJogee: not the end of a legal saga but the start of one? [2016] Crim. x[oF ?JM$qKq=Z}-fB(;3;"WfDcv 'Jogee: Not the end of a legal saga but the start of one?' 539-552, 4. 22 Dec 2016. [4] The empirical research of conviction rates, provided by JfKL, illustrated that the law disproportionately affected young people caught up in gang-related violence, which suggests considering responses other than recourse to the criminal justice system to rehabilitate. SEX attacks across Lancashire soared by more than 30 per cent over the last 12 months according to official figures. The CCRC is obliged to approach each case applying the test laid down in S13 of the Criminal Appeal Act 1995, which . David's observations and analysis are frequently cited with approval in the Court of Appeal Criminal Division and the Supreme Court. Ameen Jogee (pictured) was handed a second chance back in February in a landmark case, having initially been found guilty of the Paul Fyfe's murder, along with a friend, and given a life sentence. 'Jogee: Not the End of a Legal Saga, but the Start of One?' [2016] Crim LR 539. The Oldie - read now online on YUMPU News Magazine flat rate Subscription Read digitally YUMPU News digital subscription - 30 days free trial! 8Y4&\c&9fE|eXHKKa|S%C+8|\`>2eb 6@:0Ba:?AFiQ:/sKHgr+1)X iTe X &.PT{!=X`h*C Aw]&Anf9?00p,-. 'JogeeNot the End of a Legal Saga but the Start of a New One?' [2016] Crim. Call 07764929487. LexisNexis, Quadrant House, The Quadrant, Brighton Road, Sutton, SM2 5AS. <>/Metadata 221 0 R/ViewerPreferences 222 0 R>> Lacking from the Courts judgment was discussion regarding the written submissions made on behalf of JfKL and JENGbA, which demonstrated the ways in which the shortcomings of PAL were compounded when applied to children and young people. Dont make chili, thats OK. Come sample and help to judge. The consequences of the Supreme Court's judgment in the case of Ameen Jogee are becoming apparent, and many campaigners and criminal lawyers are delighted. On 18 February 2016, the Supreme Court handed down its much awaited judgment in the appeal of R v Jogee [2013] EWCA Crim 1433, which was consolidated with the Privy Council appeal of Ruddock v The Queen JCPC 2015/0020. Big leap in serious and sex crimes. L.R. Jury burden: One potential difficulty introduced by Jogee is there is a greater burden on the jury to take responsibility for delineating murder from manslaughter. As the Supreme Court points out, when a conviction is based upon the law as it applied at the time, the only option available to the defendant is to apply for exceptional leave to appeal. Jogee also closes the exception based on an inability to foresee the use of a more lethal weapon. If you would like to know more about mens rea issues under Jogee in relation to conditional intent, you can watch my video on it here. % Theres never a dull moment, and you get the best prices in town. LEGO Star Wars: The Skywalker Saga - LEGO Star Wars:The Skywalker Saga Deluxe EditionThe Deluxe Edition includes 7 downloadable content character packs. Ormerod, D. and Laird, K. (2016) 'Jogee: not the end of a legal saga but the start of one . On 18 February 2016, the Supreme Court handed down its much awaited judgment in the appeal of R v Jogee [2013] EWCA Crim 1433, which was consolidated with the Privy Council appeal of Ruddock v The Queen JCPC 2015/0020. Thirty years later it was put right. The next question would have been: what about the safety of historic convictions based on the old, pre-Jogee, law? Copyright 2022. . The judgment ought to be rightly lauded for not only taking the step to clarify the previous law, but to reform secondary liability to meet public expectations of justice. /Subtype /Link (See Wilson and Ormerod Simply Harsh to Fairly Simple [2015] Crim LR 3). The court allowed the appeal on the basis that this was not planned as a robbery and no violence was initially intended; C was not accused of intending or foreseeing any violence when they arrived at the flat, nor of inflicting the violence, or intending to cause grievous bodily harm. xksg#N;+hFi: "F1gR}] 32px,}'gn1m?9n'6O7'NwZ|M>= ]}Wyiq2o~K~"qpxF@(AU ~/g~xz?W?}7_.Wm0U9$98\||D'?O`t>|!.\/kBQ%EP/J/-rOh6NF;5~'0O8- . William Wilson and David Ormerod QC argued that there remains a real risk of unsatisfactory elements of the previous law creeping back in by the phrase joint enterprise remaining part of the legal lexicon. He is seconded from University College London. Line 13.21.1. ney, at 9 a m . << Maybe try searching. jogee: not the end of a legal saga but the start of one. << JFIF LExif II* V ^ ( 1 f 2 t i GIMP 2.10.18 2020:06:24 15:09:41 O = JFIF C L.R. Image: "Guru Multhoo Byragee Jogee, a native of Ajmere aged 90, in jail (1840)," by Colesworthey Grant, 1844, Image extracted from page 099 of A series of miscellaneous rough sketches of . Above n 98, 546. Infringers not only remain hidden by the . Under the old law, the jury was explicitly directed that D's foresight of a real possibility that P might intentionally kill or do GBH made him a murderer. "G]a(ob1e 61~tz2)^@| /6eJ8(z O"5Zb-.:PQg&~a2{mm{lw@i^FXtd`t* e#^)F^n #8>'H8SLZTSx<1ZzID vyi`,;xBaBs=,@S#&. Technology -I have undertaken a specialist role working with senior Ministry of Justice officials on the legal . Dynamics in one complex variable by John Milnor. Crime, Reason and History 3rd edn. DVD/ / rustinjames.com MgAEQWsC oXbKd-138019051 SKY-HI2017DVD AAA by 's shop - SKY-HI2017DVD SKY-HI2017 . % 60 One is that the law always 'really' required an intention to encourage or assist the principal's wrongdoing (ie OAL), . 80(3) 173-176 [R] Law Commission, Liability for . Authentication required. A properly directed jury will instead be informed that foresight is evidence upon which intent may be inferred. !if you have song requests you can leave it in the comment section below! The mere existence of foresight is no longer conclusive of guilt. As always, the food will be great and the company will be awesome. The decision of the Supreme Court and Privy Council inR v Jogee[2016] UKSC 8;Ruddock v The Queen[2016] UKPC 7 has unsurprisingly achieved considerable publicity and comment. He co-authors Smith and Hogans Criminal Law and is the editor in chief of Blackstones Criminal Practice and the Criminal Law Review. 3 0 obj The Court of Appeal refused to certify a question because it had no jurisdiction to do so because there had been no appeal, only applications for leave. Education. Criminal law and the law of evidence. 4 0 obj 'Jogee: Not the End of a Legal Saga, but the Start of One?' A proposal that the mens rea for accessorial liability should be recklessness. The court was interested in [T]he strength of the case advanced that the change in the law would, in fact, have made a difference ([21] emphasis added). 3 0 obj He talks to Joshua Rozenberg KC (hon) about his priorities for the Bar and its future, The Young Barristers' Committee Chair, Michael Harwood, sets out his key priorities to meet the challenges ahead. The Jogee case overruled the principle for accessorial liability as laid down in the Chan Wing-Siu case, concluding that "the introduction of the principle was based on an incomplete, and in some aspects erroneous reading of the previous case law, coupled with generalised and questionable policy arguments." William Wilson and David Ormerod QC wrote that [a] striking illustration of the unsatisfactory state of the law is that we cannot confidently describe the precise scope of joint enterprise liability.[1] The Court emphasised that those concerned with criminal justice are entitled to expect a clear statement of the law [87]. Not to say that's a bad thing, but going with a formula of introducing one main character at a time to then establish their whereabouts and then they get together with a bit of a tussle and then they meet the bad guy for the first time and then they loose to him and then they squabble with each other for a bit but then they meet their . With over 300 playable characters, over 100 vehicles, and 23 planets to explore, a galaxy far, far away has never been more fun!About the GameThe galaxy is . Thursday 8th June, 1950. decision in Jogee not only fail to acknowledge the violence and exclusionary character o f . /C [0 1 1] [2016] Crim LR 539. He shouted at F to leave on two occasions, helped M when F pushed and later punched M. C left and waited outside for ten minutes. By Mike Pini, Rachel Davenport outlines what you need to know about alcohol monitoring technology, and how it can be used to evidence levels and patterns of alcohol consumption or sobriety, Casey Randall answers some of the most common questions about prenatal paternity testing for legal matters, In this Counsel magazine broadcast interview, Chair of the Bar Nick Vineall KC talks to Joshua Rozenberg about priorities for his term in office the Criminal Bar, protecting the rule of law and the independent role of lawyers, and tackling systemic issues in regulation, diversity, entry to profession and the courts, What does Nick Vineall KC have in his sights for his term of office? Replies to the article by David Ormerod and Karl Laird entitled "Jogee: not the end of a legal saga but the start of one? Crim. giorgio brato . Ds conduct in assisting, encouraging, or causing P to commit the crime may take different forms. Loading. The development stems from the much-awaited case of R v Jogee, which the Supreme Court heard in a three day hearing in October one that gripped the press and sparked intense social media . >^ The legal aid system was created in 1949 as part of the development of the post-war Welfare State, alongside the National Health Service. The law's approach to most issues at the time was inconsistent Footnote 79 and so discrepancies are not unexpected. The language of the judgment is also noteworthy. With a range of features as standard, our 3-year fixed price cover and the option to add breakdown assistance too. Professor David Ormerod KC is Law Commissioner for England and Wales. Discrete orthogonal polynomials : asymptotics and applications J. Baik [and others]. He is also a member of the Bar of Northern Ireland. The views expressed are the authors personal views and not those of theLaw Commission. 99 See R v Jogee [2016] UKSC 8 para 9. I. Patrick Matthews and Arnold Joseph carried out a surgical procedure. At the end of her column, one feels sad for the owls as opposed to Erwin Coombs' narrative that evokes laughter with his much . The court will ask Can it therefore be said that there is a sufficiently strong case that the defendant would not have been convicted of murder if the law had been explained to the jury as set out in R v Jogee? ([191] emphasis added).iii.In determining this question, the court will consider the following factors: If crime A is a crime of violence which the jury concluded must have involved the use of a weapon so that the inference of participation with an intention to cause really serious harm is strong, that is likely to be very difficult. During proceedings, the appellants emphasised that the overriding objective of the law ought to be justice, not prosecutorial convenience or judicial reputation. . He is also a team lawyer at the Law Commission for England and Wales. The result of this invidious doctrine, as formulated in Chan Wing-Siu v The Queen [1985] 1 AC 168, meant that if two people set out to commit an offence (crime A), and in the course of that joint enterprise, one of them (D1) commits another offence (crime B), the second person (D2) is guilty as an accessory to crime B if he has foreseen the possibility that D1 might act as he did.. (2012: 4) define legal legitimacy as 'the presence or absence of legal cynicism' or the personal belief as to whether laws are binding and one is obliged (or not) to follow them.They distinguish between this form of legal legitimacy and the 'perceived morality of the offence'. The Court held that the mens rea in cases of alleged secondary participation is that the accessory intended, be it conditionally or otherwise, to encourage or assist D1 to commit the crime, acting with whatever mental element the offence requested of D1. . The putative accomplice's act must also be deliberate and she must also have intended the principal to act with the mens rea required for the principal offence. The jury found Jogee not guilty of murder but guilty of manslaughter. The Supreme Court states in emphatic terms that it does not follow from the fact an individual was convicted under the old law that his conviction will now be quashed. For years there has been a legal battle over joint enterprise and how it is used to convict secondary parties to a crime. David OrmerodandKarl Lairdexamine where secondary liability and joint enterprise stand in law afterJogee. Line 13.20.. Prl7cs In connection with No 2072 Lottcrj will be payable on nnd aftef. The article Daisy Ogle has been proposed for deletion because of the following concern: . David Ormerod and Karl Laird, 'Jogee: Not the End of a Legal Saga but the Start of One?' !3623,100 It is nonetheless important to understand that this case marks the beginning, rather than the end, of the process to correct the law: those looking to appeal must be properly advised, juries tasked with a greater burden must be properly directed and, above all, the principles laid down by the Court must be universally applied. The elves leave Middle-earth, but the Fourth Age begins. The Jogee case overruled the principle for accessorial liability as laid down in the Chan Wing-Siu case, concluding that "the introduction of the principle was based on an incomplete, and in some aspects erroneous reading of the previous case law, coupled with generalised and questionable policy arguments." (Jogee, [79]) The intervention by Just for Kids Law and Joint Enterprise: Not Guilty by . [C] R v Jogee [2016], available at. Jogee is a reminder to us as we go about our work that sometimes justice in an individual case and the letter of the law as it exists or is interpreted at any one time may not always go hand. 'Jogee: not the end of a legal saga but the start of one?'. At that point in time, a simplistic summary of Jogee may have been: In 1985 the law on joint enterprise took a wrong turn. While there's an urgent need to im- high-tech, highly mechanised agri- true security and sustainability come cannot be left in the hands of a few the pervasive lack of action by leaders. The consequence of this restrictive approach has been that, despite 30 years of erroneously applying the common law in this area, only one conviction has been quashed and only three have been referred back to the Court of Appeal by the CCRC. /C [0 1 1] 80(3) 173- Seraph of the End: Vampire Reign. the same principles govern every form of secondaryliability [76]; there are only three ways in which a defendant can be liable in this context:(a) as a principal or joint principal where D has played a part in the commission of theactus reusof the offence; (b) as an accessory under the Accessories and Abettors Act 1861, s 8 where D has aided, abetted, counselled or procured P in the commission of the acts from which the crime was constructed; (c) under the SeriousCrime Act 2007; there is no longer a separate category of parasitic accessory/joint enterprise liability. Jackson et al. The number of infected Americans continued to climb over the weekend. University home ; Library home [2016] Crim. The Privy Council in. [4] The intervener submissions drew attention to the research of Dr. Dennis Eady and JENGbA cited by the Bureau of Investigative Journalism at p. 29 of its report: Perceptions of People Maintaining Unjust Conviction under Joint Enterprise Law (June 2013). -It is argued that while the subjective basis of mens rea is essential to ensure that it is the accused's culpability that is being judged, courts must be prepared to accept that there is a residual objective element that is part of mens rea and it is that which determines whether the accused is morally blameworthy. The doubting Thomases will shout that if there had not been a war against Adolph Hitler, then the world would have been a sorry place faced with post-war Nazi victory. 3 For commentaries: R Buxton, 'Jogee: upheaval in secondary liability for murder', (2016) CLR 324-333; D. Ormerod and K. Laird, 'Jogee: not the end of a legal saga but the start of one?, (2016) CLR 539-552; M. Dyson and R. Buxton, Letter to the Editor, 2016 CLR 638-643; AP Although the court recognised that foresight was 'good evidence' of intention and that the two were 'not synonymous', Jogee is crucially silent on what threshold of foresight from the defendant might enable a jury to infer requisite intent. . The unfairness is felt most acutely in murder cases because of what has been described as the prosecutions obvious and profound advantage of being able to secure the conviction of defendant A on the limited basis that, having been a secondary party to a joint enterprise with P (Principal) to commit a lesser crime than murder, A realised that P might commit GBH or kill with intent, even if A did not intend this and even if A pleaded with P not to act in that way (see CFA finds no wrong turning: Michael Jackson, Hong Kong Lawyer, March 2017). who is the father of jennifer arcuri baby; paul cook 680 news; The extent to which the law can be regarded as fair. This marks a huge sea change in the burden for the prosecution, by which defendants may no longer find themselves convicted for the most serious of crimes based on dubious evidence of participation. In this regard, it is hoped that the judgment will bring an end to the frequency of appeals concerning PAL, an issue which the Court itself drew attention to in its judgment [81]. This is not at all a large quantity of fuel, not even over relatively long lifetimes of quasar activity of up to say 10 8 year. (T&Cs apply). The Cambridge Law Journal Volume 76 Issue 1 March 2017 [R] Ormerod, D. Jogee: not the end of a legal saga but the start of one? >> The violence was limited. As has been pointed out, there is a qualitative difference between being labelled as a murder and a manslaughterer as a matter of both label and sentence (see Jogee Not the End of a Legal Saga but the Start of One?: Ormerod, Laird: [2016] Crim LR 539, 551).iv. May 25, 2022 . The use of the date on which the application for leave was lodged as the sole criteria for triggering the far stricter substantial injustice test can lead to arbitrary results. Academics, practitioners and legal reform groups have long criticised PAL as both appallingly unclear and manifestly unfair, which has now culminated in a clear indication that the Court felt duty-bound to clarify the law. He is a door tenant at 18 Red Lion Court and a bencher of Middle Temple. That legal war came to a head in the Supreme Court in the case of Ameen. At the extreme end of the spectrum of nuclear activity are luminous quasars, which may need up to 10 M year 1 of fuel to be powered. With an open theme, the show features a diverse range of work from sixteen . From then on Cs role was limited to searching the bedroom. Globally-recognized as an expert in cases of war crimes, Dr. Joseph Rikhof was with the Crimes Against Humanity and War Crimes Section of the Canadian Department of Justice and teaches International Criminal Law in the Faculty of Law at University of Ottawa. Disclaimer: This work was produced by one of our expert legal writers, . [1] W. Wilson and D. Ormerod, Simply Harsh to Fairly Simple: Joint Enterprise Reform (2015) Criminal Law Review 3, p.4. That decision stated that a defendant charged as a secondary party to murder can only be convicted if he participated with the intention to encourage/assist P to commit the offence with the required intent to kill or cause GBH. . At that point in time, a simplistic summary of Jogee may have been: 'In 1985 the law on joint enterprise took "a wrong turn". But despite (or perhaps because of) these challenges, there has been one successful post-Jogee appeal. In 2016, the Court handed down a total of 53 judgments with a HCA media-neutral citation, which was the same number as 2015. Under Sch 21 of the Criminal Justice Act 2003, the sentences for murder are much higher than they would be for manslaughter and impact for life on the offender. You are here: Home 1 / Clearway in the Community 2 / Uncategorised 3 / jogee: not the end of a legal saga but the start of one. jogee: not the end of a legal saga but the start of one. [2016] Crim LR 543 Buxton, 'Jogee: Upheaval in Secondary Liability for Murder' [2016] Crim LR 324 The legal dictionary also incorporates The People's Law Dictionary, by renowned authorities Gerald and Kathleen Hill. <> Paul Taylor QC is a member of Doughty Street Chambers, London. 4 Since the Jogee ruling, the relevance of knowledge to consideration of intent has been reiterated by the Court of Appeal in the case of R v Anwar and others, [2016] EWCA Crim 551. Inregistrare facturi. L. 2016, 8, 539- [R] Simon Parsons, Joint Enterprise Murder: Jogee (case comment), The Journal of Criminal Law 2016, Vol. and that as long as one of these is completed by P, then liability is appropriate. There are more and less compelling readings of Jogee. About the Author. /Height 78 The Cambridge Law Journal Volume 76 Issue 1 March 2017 [R] Ormerod, D. Jogee: not the end of a legal saga but the start of one? This is not the end, no. The defendant needs to encourage or assist the commission of the offence by the principal offender. murder) the defendant must intend to assist/encourage the principal to act with that intent. Options taught He also conducts high profile criminal appeals and miscarriage of justice work. Wonderful clarity with much wider implications for those undertaking certain styles of conduct within the Financial Services sectors as a way of business leaving millions feeling misled and aggrieved by the historic deceptions? The Jogee case overruled the principle for accessorial liability as laid down in the Chan Wing-Siu case, concluding that the introduction of the principle was based on an incomplete, and in some aspects erroneous reading of the previous case law, coupled with generalised and questionable policy arguments. (Jogee, [79]). We all have our ups and all have our downs. Mr Crilly [C] sought leave to appeal, out of time, against his 2005 murder conviction ([2018] EWCA Crim 168). Criminal law and the law of evidence. Moreover, as a matter of practice, the law was continuing to create difficulty for trial judges and to generate appeals. This is a revised version of a post that first appeared on the Corker Binning Blog. John Crillys release in April 2018 marks the only conviction quashedas a result of Jogee. Cummins Health Center, The prosecution case that was put to the jury was that the men were a party to an assault with intent to rob. Research Interests. ' Big leap in serious and sex crimes. in secondary liability, the same principles apply whether D, by agreement with P, aids and abets P in committing one crime, or more; without prior agreement D aids and abets P in committing one or more crimes; or where, with or without prior agreement, D aids and abets P to commit one crime and P also commits a further crime in the course of doing so. Jogee: not the end of a legal saga but the start of one? >> /Type /Action The evidence against him was not so strong that we can safely and fairly infer the jury would have found the requisite intent to cause really serious bodily harm had the issue been left to them by the judge.. In all secondary liability cases, Dsactus reusis satisfied by proof that he did acts to encourage and/or assist P to commit the offence[8]. "Guru Multhoo Byragee Jogee, a native of Ajmere aged 90, in jail (1840)," by Colesworthey Grant, 1844, Image extracted from page 099 of A series of miscellaneous . At the other end of the spectrum, if crime A is a different crime, not involving intended violence or use of force, it may well be easier to demonstrate substantial injustice. As a matter of policy, the court was not satisfied that over the last 30 years the harsher parasitic accessory liability regime had served as a deterrent. The applicant drew attention to the particularly nebulous concepts of participation, foresight and withdrawal. And this is exactly what we see in the seminal complicity case of Jogee, 46 where, . Catarina Sjlin was Junior Counsel for Ameen Jogee in the Supreme Court of the United Kingdom. As the trial judge explained, this meant that the jury found that Jogee did not intend Hirsi to kill or cause serious injury to the police officer but did intend him to launch the attack and cause him some injury, albeit not serious injury. <> I. Ballroom dancing is one of them: the one where the man steps forward with left foot; the lady steps back with right foot. But there is neither the political will nor is there effective pressure from the community". >}8*7q(2* nz1_~|& endobj In Garwood, Miah and Hall [2017] EWCA Crim 59 the applicants attempted unsuccessfully to bring the substantial injustice test back before the Supreme Court to review and clarify. << 23 May 2016 by Adam Wagner. The requirement for the court to have regard to whether the applicant was guilty of other, though less serious, criminal conduct may cause particularly serious injustice. 22 22. (Jogee, [8]) It is irrelevant whether the defendants assistance or encouragement have any positive effect on the principal offenders actions. The Court made clear, however, that putting the law right does not render invalid those convicted under the previously erroneous law [100]. In Johnson [2016] EWCA Crim 1613, [2017] 4 WLR 104. jogee: not the end of a legal saga but the start of one 21st May 2022 . /H /I As the first test cases make their way through the courts, we will soon see the contours of criminal venture liability emerge. << Thirty years later it was put right.' The next question would have been: what about the safety of historic convictions based on the old, pre- Jogee, law? Introduction A large and varied set of criminal offences include ulterior mens rea requirements (i.e. /Width 250 It looks like the link pointing here was faulty. Jogee and Ruddock. /Length 10905 '2 this is a technical way to describe the occurrence Joint enterprise is a doctrine of criminal law which permits two or more defendants to be convicted of the same criminal offence in relation to the same incident , even where they had different types or levels of involvement in the incident . The case should find support with . Legal Dictionary. Following the analysis of case law, the Court went on to restate the correct principles of law prior to this erroneous tangent [88] [99]. Mix in the fennel seeds and sugar and bring all . About the author: Alex is a paralegal at Corker Binning, where his areas of work include regulatory investigations, financial crime, international crime and general criminal matters. 1 0 obj The Cambridge Law Journal Volume 76 Issue 1 March 2017 [R] Ormerod, D. Jogee: not the end of a legal saga but the start of one? Legal protection - up to 100,000 to help you recover uninsured losses (for example compensation for an accident in the UK that wasn't your fault), as long as an independent legal representative thinks you can win the case. He is the editor / contributor to Taylor on Criminal Appeals (Oxford University Press), and Head of the Doughty Street Appeals Unit. L.R. Line 13.21.. Lottery No 2074 will be drawn at Palings Concert Hall Ash Street, Syd-. John Crilly's release in April 2018 marks the only conviction quashed as a result of Jogee. He is co-author of Smith and Hogans Criminal Law and Smith and Hogans Text, Cases and Materials on Criminal Law. As Professor Ormerod QC has pointed out: Indeed, if the evidence is such that D would not have been convicted of murder then presumably it would be inappropriate for there to be a retrial for murder? (CALA Conference paper, November 2017, para 2.20.)ii. Tracey Fyfe, 53, says she is 'terrified' Ameen Jogee, 24, could be released from prison where he is serving a life sentence for murdering Paul Fyfe, 47, with his friend Mohammed Hirsi in Leicester . The Last Empire refers to the last earthly empire, the anti-christ's which will be brought down the Lord, Jesus and His army of angels and believers. /Border [0 0 0] material connection with the acts of D1, even though D1's crime is one that D2 intended. The human cost is too great and in the end no one really is the victor. 2016, 8, 539-552 [R] Simon Parsons, Joint Enterprise Murder: Jogee (case comment), The Journal of Criminal Law 2016, Vol. /H /I Baroness Hale on 'Life as a Lady Law Lord' (13th Annual Rueff Lecture), A new ransomware tactic has emerged: double extortion, Prenatal paternity testing for court: your questions answered, The COUNSEL interview: Chair of the Bar Nick Vineall KC talks to Joshua Rozenberg, Lessees and Management Company of Herons Court v Heronslea Ltd and others, Hinrichs and others v Oracle Corporation UK Ltd, Pricewatch Ltd v Gausden (East Sussex Fire and Rescue Services), R (on the application of Lasham Gliding Society Ltd) v Civil Aviation Authority, International Sales(Includes Middle East), Protecting human rights: Our Modern Slavery Act Statement. 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