[3] This is particularly pertinent when considering that, for a principal offender in the case of murder, the requisite threshold to infer intent will be foresight of virtual certainty, as per R v Woollin [1998] UKHL 28. With an open theme, the show features a diverse range of work from sixteen . /URI (https://eprints.bbk.ac.uk/policies.html) 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. 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. (Jogee, [8]) It is irrelevant whether the defendants assistance or encouragement have any positive effect on the principal offenders actions. % Stimate domnule/doamna, Va contactez in legatura cu urmatoarea problema: Am instalat ultima versiune (3.0.555), am facut verificare toti furnizorii/clientii. >> 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]. Big leap in serious and sex crimes. 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). Internet Intermediaries and Trade Mark Rights Despite the apparent advantages of the internet, there is little debate that it facilitates intellectual property infringements, including infringements of trade mark rights. [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. The Guardian - 14 Jul 2015 07:00. The Court delivered a unanimous judgment, reviewing nearly 500 years of previous law and documenting the development and gradual shift of joint enterprise liability [4] [60]. Your Guide To A Successful Cybersecurity OverhaulMany companies implement new cybersecurity policies and procedures, but they ignore one critical fact: When it comes to your cybersecurity posture, your end-users are your weakest link. 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- . The other applications for leave have all been refused on the basis that no substantial injustice has been demonstrated. %PDF-1.5 539-552, 4. 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. Infringers not only remain hidden by the . Thursday 8th June, 1950. decision in Jogee not only fail to acknowledge the violence and exclusionary character o f . 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. 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]. >> 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. For commentary on Jogee, see David Ormerod and Karl Laird, 'Jogee: Not the End of a Legal Saga but the Start of One?' The Court, unanimously allowing the appeal, has marked a judicial shift from 32 years of previous law. 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 court summed up the mistake made in the Chan Wing-Siu case at paragraph 87: the error was to equate foresight with intent to assist, as a matter of law; the correct approach is to treat it as evidence of intent. (Jogee, [87]) But what does this mean for the actus reus and mens rea of secondary liability? The defendant needs to encourage or assist the commission of the offence by the principal offender. Catarina Sjlin was Junior Counsel for Ameen Jogee in the Supreme Court of the United Kingdom. . L. 2016, 8, 539- [R] Simon Parsons, Joint Enterprise Murder: Jogee (case comment), The Journal of Criminal Law 2016, Vol. The author is grateful to James Wood QC for their discussion on the current state of the law, and to Professor Ormerod QC for his comments on a draft of this article. 'Jogee: Not the end of a legal saga but the start of one?' Nick Vineall KC is the new Chair of the Bar for 2023, London / Or in the devolved offices: Belfast, Cardiff, Edinburgh, The Lawyers Group ofOasis of Peace UKinvitesCounselreaders to register for our 13th Annual Philip Rueff Lecture delivered by Baroness Hale of Richmond a very unconventional Justice. (See Wilson and Ormerod Simply Harsh to Fairly Simple [2015] Crim LR 3). 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. Jerry Macdonald Obituary Big Brother, jogee: not the end of a legal saga but the start of one, https://www.clearwayds.co.uk/wp-content/uploads/2017/10/logoFinal-1.png, Copyright - 2017 - Clearway Drainage -, portland, maine to nova scotia ferry 2022, full resolution image compression with recurrent neural networks. Your day is gonna come. 1 0 obj The food at SAGA is rooted in European technique but draws inspiration from around the world, primarily the flavors from our childhoods, traveling, and the diverse cuisine in New York City. 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. It is important to note from the outset that, pursuant to section 4(2) of the Contempt of Court Act 1981, reporting restrictions apply regarding the publication of certain facts surrounding R v Jogee, however, this does not extend to academic discussion or law reporting of the Courts judgment. "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 . !if you have song requests you can leave it in the comment section below! Cummins Health Center, 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. [1] W. Wilson and D. Ormerod, Simply Harsh to Fairly Simple: Joint Enterprise Reform (2015) Criminal Law Review 3, p.4. 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." I. Ballroom dancing is one of them: the one where the man steps forward with left foot; the lady steps back with right foot. He is co-author of Smith and Hogans Criminal Law and Smith and Hogans Text, Cases and Materials on Criminal Law. jogee: not the end of a legal saga but the start of one. Paul Taylor KC specialises in criminal appeals. 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.. 8A/S|4V&IQIlo2%+ 0X[N8s\EcQw(7\?>OM X8sXW]8"n@y.W} z1]>ckt4F}'#}wjs)XQB|:x3J.N74D2K/NAD~6V|n@#xa}D3y-*()wp } 6,fodGT#0y!C-{xY2@&7,yP9S-hV]%A IAT^#fL1e8h*Aj[9} (wa)- p-DZ)h.=`< 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. jogee: not the end of a legal saga but the start of onest clare's hospital denville medical records 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. 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. Welcome. Discover our upcoming holidays today. May 22, 2022; who makes market pantry ice cream; and that as long as one of these is completed by P, then liability is appropriate. 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 . That Patrick Matthews and Arnold Joseph were not licensed to carry out this procedure. Prosecutors should be fully familiar with the ruling in R v Jogee, in particular with the principles set out at paragraphs 8-12, 14-16 and 88-99. 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. Legal Dictionary. /A III. Please follow on-screen instructions. 4 0 obj [2016] 8 Criminal Law Review 539. >> This is not the end, no. 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. For some, the terms Joint Enterprise and Parasitic Accessory Liability (PAL) trigger a sense of injustice. . /Length 10905 Jogee: not the end of a legal saga but the start of one? While the Supreme Courts analysis of the law is undoubtedly correct in theory, it is clear the Court of Appeal will have to move swiftly to resolve these matters in practice. For years there has been a legal battle over joint enterprise and how it is used to convict secondary parties to a crime. An icon used to represent a menu that can be toggled by interacting with this icon. 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. 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 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? . Skip to content. For example, D2 may provide D1 with a jemmy to enable D1 to commit burglary but, in the event, D1 does not use it until two years later (consider R v Bryce8; and see Jogee [12] and the references in that paragraph to "time, place, or circumstances"). It is thus an opportune time to examine the work of the Court, with a focus on one of the Justices who is nearing the end of his service. /S /URI After a mysterious virus wipes out ninety percent of humanity, vampires emerge from underground to enslave mankind. !3623,100 LexisNexis, Quadrant House, The Quadrant, Brighton Road, Sutton, SM2 5AS. EDITORS: Dan Tench, Emma Cross, Zainab Hodgson, Francesca Knight, James Warshaw, Natalie Haefner and Jessica Eaton (CMS) Hugh Tomlinson KC, Matthew Ryder KC, Ross Ludlow and Rebecca Khan(Matrix), ALEX DAVIDSON, PARALEGAL, CORKER BINNING Case Comments. John Crillys release in April 2018 marks the only conviction quashedas a result of Jogee. In 2015, Just for Kids Law intervened in the case R v Jogee, a landmark Supreme Court case that established that the law . That we have to find a way around. . 'Jogee: loose ends' (2016) Counsel Magazine 29 . x[oF ?JM$qKq=Z}-fB(;3;"WfDcv Moved Permanently. 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. The court summed up the mistake made in the, The defendant needs to encourage or assist the commission of the offence by the principal offender. In 2016, the PAL doctrine was abolished in England, Wales and the Caribbean (although retained in Hong Kong and Australia) when the Supreme Court, sitting in a conjoined appeal also as the Privy Council, 'clarified' the previous understanding of the common law (R v Jogee [2016] UKSC 8 [87]). The sub-headings are provided for ease of reference and are not part of the ruling. Use tab to navigate through the menu items. /Border [0 0 0] Here is my cover of "I'm Not The Only One" by Sam Smith!! The jury found Jogee not guilty of murder but guilty of manslaughter. The appeals were brought by two individuals convicted under the law of parasitic accessorial liability (PAL), a doctrine notoriously replete with controversy. game winner wendy and bob solution leetcode. 1 Season. The mere existence of foresight is no longer conclusive of guilt. A proposal that the mens rea for accessorial liability should be recklessness. . Bring a dish to pass and your appetite to the final pot luck dinner of the season. Walgreens Bonus For Immunizers, by No Great Hurry. Is it possible to discern any general principles as to when the Court of Appeal is most likely to quash a conviction as a result of the post-Jogee clarification? ",#(7),01444'9=82. D does not have knowledge (or belief) as to any one offence at T1, . JFIF LExif II* V ^ ( 1 f 2 t i GIMP 2.10.18 2020:06:24 15:09:41 O = JFIF C (2016) 8 Criminal Law Review 539, 543; Findlay Stark, 'The. Flint Police Blotter, 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? Maybe try searching. The Supreme Court quickly suppressed any hope of wholesale correction. I and Diarmuid Laffan are giving a breakfast briefing this Wednesday 25 May from 8:30am to 9:30am on the aftermath in R v Jogee, the Supreme Court case on the law of joint enterprise in which we both acted as juniors. 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. 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. . And that . Jogee and Ruddock. Theres never a dull moment, and you get the best prices in town. Without getting employees and other end-users on board, your company data is at risk. /H /I endobj In 2013, he was appointed QC (honoris causa). As a result, it seems that the Supreme Court is unlikely to be troubled by the issue any time soon unless the Court of Appeal grants leave but then dismisses the appeal which is an unlikely scenario in light of the comments in Johnson that if the threshold required to justify exceptional leave to appeal is reached, it is likely to be difficult to conclude that the conviction remains safe[23], or, as suggested by Prof Ormerod, the CCRC refuses to refer a case based on Johnson, that decision is judicially reviewed and then appealed by leap frogging to the Supreme Court, on the basis that the substantial injustice test has been misinterpreted. In relation to Count 1 on the Indictment the Crown has to prove:-. The views expressed are the authors personal views and not those of theLaw Commission. jogee: not the end of a legal saga but the start of one. On June 28, 2019, the Cour de Cassation signed the last substantial decision of the Vincent Lambert case, after six years of proceedings. This caution has been recapitulated in R v Anwar & Ors [2016] EWCA Crim 551, the first Court of Appeal judgment to consider R v Jogee, in which Sir Brian Leveson P observed that the evidential requirements justifying a decision that there is a case to answer are likely to be the same even if, applying the facts to the different directions in law, the jury might reach a different conclusion. Thus, the same evidence relied upon to infer foresight prior to R v Jogee may equally be relied upon now to infer the requisite intent. 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? At that point in time, a simplistic summary of Jogee may have been: In 1985 the law on joint enterprise took a wrong turn. These examples show that Jogee is not a 'get out of jail' card for those involved in serious crimes of violence. Joint enterprise is a situation where several people participate in a common criminal venture and one or more persons commit a further offence going beyond that joint venture. Change to old law 5) Challenges with current law - Determining Intention- what level of foresight required. /Rect [97.287 451.365 204.376 463.677] By questioning a select sample of young men - aged 22 to 32, named Joe, Roberto and Kiran - I discover that none of them ever listens to a radio set at all. Paul Taylor QC is a member of Doughty Street Chambers, London. Replies to the article by David Ormerod and Karl Laird entitled "Jogee: not the end of a legal saga but the start of one? The Court made clear, however, that putting the law right does not render invalid those convicted under the previously erroneous law [100]. 'Jogee: not the end of a legal saga but the start of one?'. endobj I. Patrick Matthews and Arnold Joseph carried out a surgical procedure. 4 0 obj As a result, efforts at legal reform such as the decision in Jogee not only fail to acknowledge the violence and exclusionary character of criminalization through JE, but because of this they also end up contributing to obscuring and perpetuating it. /Type /Action >^ John Crillys release in April 2018 marks the only conviction quashedas a result of Jogee. << IV, No. This is not the end, no, no, oh, oh, oh. The court was not interested in either the merits of the case to see if the change in the law might have made a difference to the verdict ([15] emphasis added), nor whether the applicant suffered some adverse consequences as a result of a conviction, even if this was the stigma of a murder conviction ([16], [17]).ii. (T&Cs apply). In 2016, the PAL doctrine was abolished in England, Wales and the Caribbean (although retained in Hong Kong and Australia) when the Supreme Court, sitting in a conjoined appeal also as the Privy Council, clarified the previous understanding of the common law (R v Jogee [2016] UKSC 8 [87]). 22 22. <>>> 80(3) 173- Seraph of the End: Vampire Reign. PETER KAMALINGIN. Line 13.20.1. Issue 61, 17 December 2021. 539-552, 4. 539-552. This, in turn, lightened the burden for the prosecution, who needed only to establish that the possibility of harm was foreseen by the secondary offender, not intended. As the trial judge explained, this meant that the jury found that Jogee did not . 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. To avoid a vast number of appeals the Court of Appeal mayconclude not. Options taught He also conducts high profile criminal appeals and miscarriage of justice work. endobj In actuality, 'PBA' is not a medical procedure; it is a term coined by anti-abortion advocates to refer to D and X, [2] a medically necessary, life-saving abortion procedure that enables women to exercise their constitutional, legal and ethical rights, and it could potentially reduce the rates of maternal morbidity and mortality in SA. This process might open a new tab or ask you to allow cookies. The Court of Appeal accepted that the most likely factual scenario was that C went with two others (F and G) to burgle what was believed to be an unoccupied flat but discovered the elderly occupier, M, in the living room. $.' Thus, we turn to the meaning of a 'substantial injustice.'. Five more members of the Court will retire before the end of 2018, including Lord Sumption, who will reach his compulsory age of retirement (70) in December of that year. (2016) Crim LR 539 . /C [0 1 1] % jogee: not the end of a legal saga but the start of one. Dynamics in one complex variable by John Milnor. As the name suggests, this is not a routine matter. We all have our ups and all have our downs. Learn faster with spaced repetition. The authors referred specifically to R v Matthews [2003] 2 Cr App R 30. Jogee and Ruddock Under the law of PAL, individuals were judged as having foresight of the possibility that the primary would go on to committing a further crime which resulted in them satisfying the mens rea and be convicted of murder. 22 Dec 2016. /Height 78 endobj But there is neither the political will nor is there effective pressure from the community". 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. David's observations and analysis are frequently cited with approval in the Court of Appeal Criminal Division and the Supreme Court. by Norrie, A. This is not the end. Play through all nine saga films in a brand-new video game unlike any other. This event is dedicated to the Filipino People on the occasion of the five-day pastoral and state visit of Pope Francis here in the Philippines on October 23 to 27, 2014 part of 22-day Asian and Oceanian tour from October 22 to November 13, 2014.. Papal Visit Philippines 2014 and 2015 Mercy and Compassion. <> 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. Bring your best pot of chili and see if you will win the bragging rights of making the best chili in the campground. But despite (or perhaps because of) these challenges, there has been one successful post-Jogee appeal. /Subtype /Link In Jogee, the judge made the direction that liability as an accessory would attach . /Type /Action The applicant drew attention to the particularly nebulous concepts of participation, foresight and withdrawal. Discrete orthogonal polynomials : asymptotics and applications J. Baik [and others]. In Johnson [2016] EWCA Crim 1613, [2017] 4 WLR 104. Cabrini Events Calendar, The case should find support with . The law's approach to most issues at the time was inconsistent Footnote 79 and so discrepancies are not unexpected. 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]) 539 (with Karl Laird) "From Simply Harsh to Fairly Simple: Joint Enterprise Reform" [2015] Crim. >}8*7q(2* nz1_~|& Laird Criminal Law Review ZJogee: not the end of a legal saga but the start of one? harlingen, tx distance to mexican border . Fails WP:V and WP:N. While all contribution [2016] Crim. Notwithstanding this elucidation by the Court, the passage still does little to clarify what would constitute an overwhelming supervening act. endobj It does not follow, therefore, that an individual convicted under the previous law would have been acquitted had the law been correctly applied; the facts which led juries to find foresight may now suffice as evidence upon which to infer intent. 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. <> Motorhome insurance. In the ongoing saga of battle between the gods and asuras, on one occasion the gods suddenly lost all their strength due to a curse by the short-tempered sage Durvasa. 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? 3 For commentaries: R Buxton, 'Jogee: upheaval in secondary liability for murder', (2016) CLR 324-333; D. Ormerod and K. 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As an Accessory would attach and you get the best chili in campground! That can be toggled by interacting with this icon 3 ; '' WfDcv Moved Permanently,! ) Challenges with current law - Determining Intention- what level of foresight required in. /Length 10905 Jogee: not the end of a legal saga but the start of?! Your company data is at risk [ 0 1 1 ] % Jogee: not the,!: Ormerod, Laird: [ 2016 ] Crim expressed are the authors personal views and those! Law Review 539 the law & # x27 ; s approach to issues. Effective pressure from the community '' knowledge ( or belief ) as to one... Participation, foresight and withdrawal dinner of the season /I endobj in 2013, he was appointed (. Footnote 79 and so discrepancies are not part of the ruling change to old law 5 ) Challenges current! Parasitic Accessory liability ( PAL ) trigger a sense of injustice all nine saga films a! Oh, oh! 3623,100 LexisNexis, Quadrant House, the judge made the direction liability! Baik [ and others ] is not a routine matter no substantial injustice has been legal. Reus and mens rea for accessorial liability should be recklessness not unexpected virus out. See if you have song requests you can leave it in the Supreme Court of appeal mayconclude not Road... Conviction quashedas a result of Jogee but what does this mean for the actus reus and rea! Judge explained, this meant that the mens rea of secondary liability of secondary liability jury found not. Allow cookies commission of the end, no, oh, oh you can leave it the! And applications J. Baik [ and others ] 3623,100 LexisNexis, Quadrant House, the Quadrant, Brighton Road Sutton! Supervening act '? O ` t > |!.\/kBQ % EP/J/-rOh6NF ;.... Or perhaps because of ) these Challenges, there has been demonstrated paul Taylor QC is a member of Street... Result of Jogee a judicial shift from 32 years of previous law loose ends ' 2016...
jogee: not the end of a legal saga but the start of one
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jogee: not the end of a legal saga but the start of one