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Companion Website
Blackstone's Criminal Practice 2009
April 2008
April Update 2008
Updates to Blackstone's Criminal Practice 2008 are produced by Michael Hirst, Professor of Criminal Justice, De Montfort University, Leicester, and Laurence Eastham, Editorial Co-ordinator, Blackstone's Criminal Practice.
The April update primarily covers developments occurring or reported in March 2008.
- Part A: General Principles of Criminal Law
- Part B: Offences
- Part D: Procedure
- Part E: Sentencing
- Part F: Evidence
- Appendices
- New Legislation
PART A GENERAL PRINCIPLES OF CRIMINAL LAW
A1 Actus Reus
A1.27 Novus Actus Interveniens
Pagett (1983) 76 Cr App R 279 and Le Brun [1992] QB 61 were considered in Ogunbowale [2007] EWCA Crim 2739. The appellant struck the deceased a violent blow on the back of the neck. Before falling to the ground and suffering fatal brain damage as his head hit the pavement, the victim turned towards the appellant as if intending to retaliate, and it was argued that this required the judge to direct the jury to consider whether the victim’s behaviour amounted to a novus actus interveniens, so that the blow struck was not the real cause of his fatal fall. The Court of Appeal disagreed.
In our judgment, the jury were entitled to hold that the blow did contribute to the fall which caused the death. On the evidence to which we have referred, they were amply entitled to hold that there was no break in the chain of causation; on the basis of the directions they were given. We have cited the direction that they had to be sure that the blow had contributed significantly to the death and that was sufficient upon the facts of this case.
A6 Inchoate Offences
A6.25 Conspiracy to Defraud
Prior to the commencement of the Enterprise Act 2002, a price-fixing ‘cartel’ agreement could not amount to conspiracy to defraud unless combined with other elements such as deliberate misrepresentation (Norris v Govt of the USA [2008] UKHL 16). A cartel agreement is now a statutory offence and would be prosecuted as such under the Enterprise Act 2002, s. 188.
PART B OFFENCES
B1 Homicide and Related Offences
B1.58 Causing or Allowing the Death of a Child or Vulnerable Adult
The offence created by the DVCVA 2004, s. 5, was examined along with associated procedural provisions (notably s. 6(4)) by the Court of Appeal in Ikram and Parveen [2008] EWCA Crim 586.
The two appellants were charged with the murder of I’s 16-month-old child, T, who was found to have suffered numerous injuries before her death. They were also charged with an offence under s. 5. Both gave evidence denying all knowledge or responsibility. At the close of evidence the prosecution dropped the murder charge against I (anticipating submissions of no case to answer) but not that against P, whose own submission was rejected. P’s counsel then applied to recall her so that she could contadict her original evidence and testify that I had physically abused both her and T. Permission to recall P was refused, and both were convicted of offences under s. 5. P was acquitted of murder or manslaughter, a verdict which indicated that the jury were not sure who had in fact killed T. Both appealed against conviction and against their sentences of nine years’ imprisonment.
Dismissing both appeals, the court held that it was right and proper for the prosecution to drop the murder charge against I having once concluded that the evidence against him did not support such a charge. It was not, contrary to P’s submissions, an abuse of process. The effect of s. 6(4) was that the timing of any submission of no case was deferred to the close of evidence, rather than the close of the prosecution case.
The Court of Appeal also upheld the judge’s refusal to let P testify again, because to allow it would have offended against general principles (see Cook [2005] EWCA Crim 2011, Hakala [2002] EWCA Crim 730 and D16.10, below) and would have undermined the policy behind the 2004 Act. As Sir Igor Judge P explained:
The purpose of the procedural changes introduced by section 6 of the 2004 Act, and in particular section 6(4), is that all the evidence should be completed before the question whether there is a case to answer comes to be addressed. Parveen's application to be recalled, if permitted, would have allowed her to give a new account, inculpating her co-defendant as the individual responsible for the death of the child after it had become inevitable that he would be acquitted of murder/manslaughter. If it is indeed possible to envisage any special situation in which the defendant should not be allowed to offer two contradictory defences in the same trial, one of the least likely would be a trial to which the provisions of section 6(4) applied. To allow it would effectively negative the entire purpose of this particular and specific legislation.
B6 Falsification, Forgery and Counterfeiting
B6.90 Scope of Offences under Trade Marks Act 1994, s. 92
On a charge of applying a false trade mark to goods, it is no defence that the defendant informed his immediate client that the goods were counterfeit: the focus must be on the appearance of the goods themselves, and how they might later be perceived by consumers (Morgan [2006] EWCA Crim 1742).
B12 Offences Relating to Weapons
B12.141 Manufacture, Sale and Hire of Offensive Weapons
The Violent Crime Reduction Act 2006 (Commencement No. 5) Order 2008 (SI 2008 No. 791) inter alia brings s. 43 of the Act (sale etc. of knives and other weapons) fully into force on 6 April 2008.
The Criminal Justice Act 1988 (Offensive Weapons) (Amendment) Order 2008 (SI 2008 No. 973) adds a samurai sword to the list of weapons contained in the principal Order. A samurai sword is a sword with a curved blade of 50 cms or more in length.
B14 Offences Against the Administration of Justice
B14.29 Perverting the Course of Justice
A remarkable feature of many reported cases in which false allegations of rape, etc, have been made is the extreme leniency shown to those who admit or are proved guilty to such falsity. In some cases, offenders are cautioned or reprimanded. This may be because the complainant was young, emotionally disturbed or mentally ill; but as the Court of Appeal pointed out in C [2008] Crim LR 394; sub nom C-J [2007] EWCA Crim 2551 at [26], false complaints of rape can do enormous damage and must be treated as a serious matter. A caution or reprimand cannot ordinarily be a suitable response to such a serious offence. Sir Igor Judge P said:
A false allegation can have dreadful consequences, obviously and immediately for an innocent man who has not perpetrated the crime. But also, and this is not to be overlooked, because every occasion of a proved false allegation has an insidious effect in public confidence in the truth of genuine complaints, sometimes allowing doubt to creep in where none should in truth exist. There cannot be very many cases … where the offence of attempting to pervert the course justice, on the basis of a false allegation of rape, certainly one which is set out in detailed formal form statement or pursued to the door of the court, should not be prosecuted for what it is. It is only in the rarest of cases that a police caution sufficiently addresses either the criminality of a false allegation of serious sexual crime or (and this is no less important) the possibility of the need for appropriate treatment which will address the problems which have led the complainant to fabricate the allegations she has made.
PART C ROAD TRAFFIC OFFENCES
C3 Offences relating to Driving Triable on Indictment
C3.38 Dangerous Driving: Sentencing
In recent years, the sentence for causing death by dangerous driving has been raised again and again, but there has been no corresponding increase in the maximum penalty for dangerous driving itself. Where, however, dangerous driving results in the malicious infliction of grievous bodily harm, contrary to the OAPA 1861, s 20, there is no reason why the driver should not be charged with and sentenced for the latter offence, as the Court of Appeal confirmed in Stranney [2007] EWCA Crim 2847, following Bain [2005] EWCA Crim 07.
Where the vehicle was used as a weapon, even more serious charges are of course possible, including offences under the OAPA 1861, s 18, or attempted murder. See also A-G’s Ref (No 19 of 2007), Holroyd [2007] EWCA Crim 1312.
PART D PROCEDURE
D8 Assets Recovery
D8.1 General
Serious Crime Act 2007 (Commencement No. 2 and Transitional and Transitory Provisions and Savings) Order 2008 (SI 2008 No. 755) brings into force, inter alia, all the provisions of the Act relating to the abolition of the Assets Recovery Agency and the transfer of its functions to SOCA and the National Policing Improvement Agency, insofar as they are not already in force, on 1 April 2008. This includes the relevant repeals. The Order includes various transitional provisions relating to the abolition and transfer. The Order also brings into force, on 6 April 2007, ss. 75(1) to (3), 76(1) to (3) and 78 to 84, sch. 10, paras. 1 (in part), 2 to 13 and 24 to 28, and sch. 11 (all of which relate to asset recovery and proceeds of crime).
The Assets Recovery Agency (Abolition) Order 2008 (SI 2008 No. 575) provides that, with effect on 1 April 2008, the Agency shall be abolished and that the various statutory responsibilities of its Director shall end.D13 Juries
D13.24 Police Officers and Others as Jurors
Abdroikov [2007] UKHL 37 (which partially reverses the Court of Appeal’s earlier ruling in Abdroikov [2005] 1 WLR 3538 and is noted in the November 2007 update) was applied in Khan [2008] EWCA Crim 531. The fact that a police officer sitting on the jury in one of the three conjoined cases had himself taken part in operations involving the same type of offence with which the defendant was charged (drug dealing) did not of itself give rise to any appearance of bias on the part of the police officer. Most police officers were likely to have had experience of most of the common types of criminal offence. Nor, in the second case, could there be any possible objection to a member of the CPS sitting as a juror in a case which was being prosecuted not by the CPS but by the DTI.
In the third case, a mere suspicion that a juror might, by reason of having been employed as a prison officer in a prison where the defendant was held on remand, have acquired knowledge of that defendant's bad character could not, of itself, lead an objective observer to conclude that the juror had an appearance of bias. Investigation had shown that the juror had no knowledge of the defendant.
The Court of Appeal did however issue this general advice, which ‘should receive attention without any delay’:
It is essential that the trial judge should be aware at the stage of jury selection if any juror in waiting is or has been, a police officer or a member of the prosecuting authority, or is a serving prison officer. Those called for jury service should be required to record on the appropriate form whether they fall into any of these categories, so that this information can be conveyed to the judge. We invite all of these authorities and Her Majesty's Court Service to consider the implications of this judgment and to issue such directions as they consider appropriate.
D15 Trial on Indictment: the Prosecution Case
D15.52 Submission of ‘No Case’ in Relation to Death of a Child
The DVCVA 2004, ss. 5 and 6 were examined by the Court of Appeal in Ikram and Parveen [2008] EWCA Crim 586. See B1.58 and D16.10.
D16 Trial on Indictment: the Defence Case
D16.10 The Accused as a Witness
In Ikram and Parveen [2008] EWCA Crim 586, I and P were charged with the murder of P’s child (T) and with causing or allowing the death of a child, contrary to the DVCVA 2004, s. 5. Each denied that the child had been abused and claimed that her injuries were accidental. Under s. 6(4) of that Act, any decision as to whether there was a case to answer was postponed until the defence evidence had been heard, and at that point the prosecution (anticipating such a submission) decided to drop the murder charge against I. The question that then arose was whether P could be recalled to resile from her original testimony and accuse I of killing the child and abusing her. It was submitted that the interests of justice required that once P had fully appreciated the implications of I's evidence, she had been moved to tell the truth, and should be allowed to do so. The trial judge disagreed and the Court of Appeal supported him. Sir Igor Judge P considered Cook [2005] EWCA Crim 2011 and Hakala [2002] EWCA Crim 730 said:
Although the defendant cannot be deprived of the opportunity to give evidence in her own defence, and to advance whatever case she wishes, the opportunity to give her full and complete account of relevant events is only available once. It is difficult to imagine circumstances – unless bizarre in the extreme - in which the defendant should be granted the privilege of giving evidence twice in order to advance contradictory defences at the same trial. Naturally, a judge may be inclined, as a matter of discretion and in the interest of justice, to allow a defendant to be recalled to clarify some feature of his evidence or to address a possible source of misunderstanding, or for example, to allow the first defendant, faced with new allegations by the second defendant which for one reason or another were not put to him when he was cross-examined, to be given the opportunity to answer such allegations. However the defendant cannot seek to be recalled after the conclusion of the evidence of the other defendant, or indeed after the close of the evidence, in order to give evidence in support of a new defence which contradicts the evidence he has already given. That would normally constitute an abuse of process.
In Cook, Smith LJ summarised the principles relating to the discretionary power of the judge to allow the recall of a witness or a defendant after the conclusion of his evidence, and before the summing up, and said:
A judge will permit a defendant to be recalled only to deal with matters which have arisen since he gave evidence if he could not reasonably have anticipated them and if it appears to be in the interests of justice that he should be recalled.
A judge should never permit a defendant to be recalled so that he may resile from evidence already given and advance a new version of events where that version was available to him when he was first in the witness box.
The court in Ikram broadly agreed , but warned that “never say never” is a valuable working principle, because it is impossible to be sure that a situation in which the interests of justice may require such an unusual course could never arise.
D24 Anti-social Behaviour Orders
D24.6 Application Procedure
The Violent Crime Reduction Act 2006 (Commencement No. 5) Order 2008 (SI 2008 No. 791) brings into force inter alia s. 59 of the Act (limitation period for anti-social behaviour orders).
D30 Public Funding and Costs
D30.3 Grant of Right to Representation
The Criminal Defence Service (Financial Eligibility) (Amendment) Regulations 2008 (SI 2008 No. 723) increase financial eligibility limits with effect from 7 April 2008.
The Criminal Defence Service (General No. 2) (Amendment) Regulations 2008 (SI 2008 No. 725) extend the definition of criminal proceedings to include proceedings under the Serious Crime Act 2007, ss. 19 to 21 and 24 (serious crime prevention orders in the Crown Court and appeals relating thereto).
D30.43 Applying for a Representation Order
The Criminal Defence Service (General No. 2) (Amendment) Regulations 2008 (SI 2008 No. 725) inter alia increase financial eligibility limits for advice and assistance by amending reg. 5 so that for the figures of £95 and £201 the amounts of £99 and £209 are substituted.
D31 Extradition
D31.9 Extradition Offence
It was argued in Norris v Govt of the USA [2008] UKHL 16 that the test for determining what is or is not an extradition offence for the purposes of the Extradition Act 2003, part 2, should be one that focuses on that part of the conduct which constitutes the foreign offence, not the other parts which are extraneous to it but which may be alleged in documents supporting the extradition request. On that basis, the English court can have regard only to such conduct as would prove the essential ingredients of the foreign offence, and nothing more. This is generally referred to as an ‘offence test’, in contrast to the ‘conduct test’ that characterised the Extradition Act 1989.
The House of Lords rejected that argument:
The committee has reached the conclusion that the wider construction should prevail. In short, the conduct test should be applied consistently throughout the 2003 Act, the conduct relevant under Part 2 of the Act being that described in the documents constituting the request (the equivalent of the arrest warrant under Part 1), ignoring in both cases mere narrative background but taking account of such allegations as are relevant to the description of the corresponding United Kingdom offence.
PART E SENTENCING
E21 Confiscation Orders
E21.1 General
Serious Crime Act 2007 (Commencement No. 2 and Transitional and Transitory Provisions and Savings) Order 2008 (SI 2008 No. 755) brings into force, inter alia, all the provisions of the Act relating to the abolition of the Assets Recovery Agency and the transfer of its functions to SOCA and the National Policing Improvement Agency, insofar as they are not already in force, on 1 April 2008. This includes the relevant repeals. The Order includes various transitional provisions relating to the abolition and transfer.
The Assets Recovery Agency (Abolition) Order 2008 (SI 2008 No. 575) provides that, with effect on 1 April 2008, the Agency shall be abolished and that the various statutory responsibilities of its Director shall end.
E23 Exclusions and Disqualifications
E23.3 Football Banning Orders
In DPP v Beaumont [2008] EWHC 523 (Admin), the Divisional Court rejected the argument that an offence committed by football supporters on a train when returning from watching a Premier League fixture could be ‘related to a football match’ only if proved to have been committed within one hour of the end of that match. A one-hour limit does apply for certain purposes under the Football Spectators Act 1999, notably where it is alleged that things were done during ‘a period relevant to a football match’ (see s. 1(8)) but this limit has no application to whether the offence in question was related to such a match. The court expressly agreed with counsel’s submission that:
To treat the two expressions ‘period relevant to a football match’ and ‘offence related to football matches’ as having the same meaning would be to create a redundancy and would be plainly a mistaken interpretation of the provision.
PART F EVIDENCE
F6 Examination in Chief
F6.21 Recent Complaints: Statutory Extension of the Principle
The CJA 2003, s. 120(7) was considered by the Court of Appeal in K [2008] EWCA Crim 434. The two appellants, who were brothers, were convicted of a series of sexual offences committed against children and teenagers, primarily girls (eg, nieces) within their extended families. One of the issues that arose on appeal was whether the trial judge had been justified in admitting evidence of statements made by the complainants concerning the alleged offences. Some of these complaints had been made years after the alleged offences – a much longer gap that the four months in O [2006] 2 Cr App R 405.
The court held that the complaints were in any event admissible under s 120(2) (on the basis that they tended to rebut defence allegations of subsequent fabrication by the complainants). As to s. 120(7):
The extended families to which each of the complainants belonged, or were attached, and the complications arising from that, was a factor to be taken into consideration. . . . Belonging, as they did, to an outwardly respectable and close-knit family, there were considerable pressures on each of them, including self-imposed pressures, to keep events to themselves. Of course, it was for the jury to reach conclusions as to the reasons for the delay in complaining, and the implications of that.
That being so, further analysis of the time factor under s.120(7)(d) becomes unnecessary. We are conscious of the very considerable passage of time in the case of such complaint. Had the circumstances, including the defence to be run, been different, a decision to admit could have been erroneous. However, for reasons given, we are not prepared to hold that the judge's decision was erroneous.
The court did not, however, give general approval to the practice (as adopted by the trial judge in that case) of making rulings under s. 120(2) or (7) at the beginning of a trial, before any evidence has been heard. There will be cases, said the court, in which fairness requires that the decision be deferred until a later stage. The advantage of an early ruling is that the trial is not disrupted by the possibility of repeated submissions as to admissibility and both prosecution and defence will have the advantage of knowing what is to be in evidence when putting theases.
F7 Cross-examination and re-examination
F7.16 Protection of Complainants in Proceedings for Sexual Offences
It was argued in K [2008] EWCA Crim 434 that the YJCEA 1999, s. 41, does not apply to cross-examination concerning an abortion, because this is not sexual behaviour, even though it must result from sexual behaviour. The court in K did not find it necessary to decide the point in the context of that case, because the fact in question was of minimal relevance anyway; but it is submitted that, in some contexts at least, such questioning may be a way of introducing evidence of sexual behaviour by inference, in which case s. 41 would have to apply.F12 Evidence of Bad Character of Accused
F12.12 Evidence of Bad Character Adduced by Prosecution under s. 101(1)(d)
Hanson [2005] 1 WLR 3169 was applied and Z [2006] 3 All ER 882 considered in Ngyuen [2008] EWCA Crim 585, in which it was held: (1) that the Court of Appeal would not interfere with a judge's judgment as to the capacity of prior events to establish propensity unless satisfied that the judge was plainly wrong; and (2) there was no obvious prejudice or injustice arising from the fact that the prosecution had not prosecuted D in respect of one of two alleged incidents in which he had allegedly attacked victims in public houses when drunk and aggressive, but had instead adduced evidence of it in support of a murder charge arising from the other incident as evidence of D’s propensity to violence.
D might not have been any better off if he had indeed been tried in respect of that other incident. The court did however certify that a point of law of general public importance arose, namely:
whether the mere fact that the prosecution chose to rely on relevant bad character evidence which it decided not to make the subject of a criminal charge could of itself have such an adverse effect on the fairness of the proceedings that the court ought not to admit it, under s 78 of the 1984 Act and/or s 101(3) of the 2003 Act.
F17 Confessions
F17.27 Breach of Interview Procedures
Keenan [1990] 2 QB 54 was applied in Coelho [2008] EWCA Crim 627, where the prosecution adduced evidence of admissions allegedly made by C, who was Portuguese, to a police officer who had spoken to him in that language in his police cell, shortly after a formal interview at which he had made no comment.
Quashing C’s conviction, the Court of Appeal noted that there had been various significant breaches of PACE Code C, notably paras 11.4, 11.13 and 13.4. In particular, C had been given no opportunity to sign or correct any record of what he was supposed to have said until two months after the alleged conversation.
F18 Evidence of Identification
F18.16 Dock Identification
The use of dock identification evidence at a summary trial was considered in Smith v DPP [2008] EWHC 771 (Admin). It was ‘common ground’ in this case that the district judge had been wrong to ask the principal prosecution witness, who had said she recognised ‘John Smith’ as the offender, whether she had ‘seen him today’. It was also common ground that this amounted to an invitation to make a dock identification, and in the court’s opinion that was either inappropriate or both inappropriate and unnecessary.
With respect, this was far from being a case of ‘dock identification’ in the classic sense and it is hard to see what injustice could possibly have been done by it. As the Court of Appeal observed in Reid [1994] Crim LR 442, and as Professor Birch explained in her comment on it at p 443, recognition cases involve different considerations. When the supposedly offending question was asked, the witness had already said, "John Smith was at the same school as me for a period of time. He lives around the corner from me with his Nan.... I am 100 per cent certain it was him." She had also said that if she saw him she would recognise him. She did not know his middle names but believed he lived at number 2 Burton Road. (He lived in fact at number 12). In those circumstances, the fact that no identity parade, etc was held can hardly have been important. In fleeting glimpse cases, witnesses may sometimes mistakenly identify an offender as someone they know, but putting the latter on an identity or video parade is unlikely to help, because the witness will almost inevitably (if wrongly) identify the acquaintance he thought he saw.
The real damage caused by the judge’s question may have arisen from the fact that her answer was that she had seen Smith outside the court and that he had threatened her, saying: “You are going to need witness protection, you fucking grass”. Very damaging, no doubt, but entirely the defendant’s own fault.
NEW LEGISLATION
Safeguarding Vulnerable Groups Act 2006 (Barring Procedure) Regulations 2008 (SI 2008 No. 474)
These Regulations concern the procedure to be followed by the Independent Barring Board established under s 1 of the 2006 Act and the procedure to be followed by an applicant seeking a review of a barring order.
Prevention of Terrorism Act 2005 (Continuance in force of sections 1 to 9) Order 2008 (SI 2008 No. 559)
This Order continues ss. 1 to 9 of the 2005 Act in force until 10 March 2009.
The Assets Recovery Agency (Abolition) Order 2008 (SI 2008 No. 575)
This Order provides that, with effect on 1 April 2008, the Agency shall be abolished and that the various statutory responsibilities of its Director shall end.
Criminal Defence Service (Financial Eligibility) (Amendment) Regulations 2008 (SI 2008 No. 723)
These Regulations increase financial eligibility limits with effect from 7 April 2008.
Criminal Defence Service (General No. 2) (Amendment) Regulations 2008 (SI 2008 No. 725)
These Regulations extend the definition of criminal proceedings to include proceedings under the Serious Crime Act 2007, ss. 19 to 21 and 24 (serious crime prevention orders in the Crown Court and appeals relating thereto). They also increase financial eligibility limits for advice and assistance by amending reg. 5 so that for the figures of £95 and £201 the amounts of £99 and £209 are substituted.
Tribunals, Courts and Enforcement Act 2007 (Commencement No. 3) Order 2008 (SI 2008 No. 749)
This Order brings s. 141 of the Act into force on 6 April 2008. Section 141 provides power for a court to substitute a decision on judicial review.
Serious Crime Act 2007 (Commencement No. 2 and Transitional and Transitory Provisions and Savings) Order 2008 (SI 2008 No. 755)
This Order brings into force all the provisions of the Act relating to the abolition of the Assets Recovery Agency and the transfer of its functions to SOCA and the National Policing Improvement Agency, insofar as they are not already in force, on 1 April 2008. This includes the relevant repeals. The Order includes various transitional provisions relating to the abolition and transfer.
The Order also brings into force ss. 1 to 43 of the Act, bar ss. 24(9) and (10) and 40(4), and schs. 1 and 2 (bar sch. 2, paras. 4 and 18). These provisions relate to serious crime prevention orders. Such orders may be made, subject to transitional provisions, from 6 April 2008.
The following further provisions of the 2007 Act are brought into force on 6 April:
- s. 73 and sch. 7 (data matching) so far as not already in force;
- ss. 75(1) to (3), 76(1) to (3) and 78 to 84, sch. 10, paras. 1 (in part), 2 to 13 and 24 to 28, and sch. 11 (all of which relate to asset recovery and proceeds of crime);
- s. 87 (serious violence: powers to stop and search).
Police and Justice Act 2006 (Commencement No. 8) Order 2008 (SI 2008 No. 790)
This Order brings into force, on 1 April 2008, inter alia s. 39 of the Act and sch. 11, which relate to the forfeiture of indecent photographs of children.
Violent Crime Reduction Act 2006 (Commencement No. 5) Order 2008 (SI 2008 No. 791)
This Order brings into force inter alia the following provisions of the Act:
- on 1 April 2008, s. 43(4) (sale etc. of knives and other weapons), insofar as it inserts new subsections (11D) and (11E) into the Criminal Justice Act 1988, s. 141;
- on 6 April 2008, ss. 43 (insofar as not already in force) and 59 (limitation period for anti-social behaviour orders).
Offender Management Act 2007 (Consequential Amendments) Order 2008 (SI 2008 No. 912)
This Order makes amendments to a wide range of criminal legislation as a consequence of the reorganization of the probation service in accordance with part 1 of the Act.
Serious Crime Act 2007 (Amendment of the Proceeds of Crime Act 2002) Order 2008 (SI 2008 No. 949)
This Order amends s. 280 of the Proceeds of Crime Act 2002 in light of the abolition of the Assets Recovery Agency.
Criminal Justice Act 1988 (Offensive Weapons) (Amendment) Order 2008 (SI 2008 No. 973)
This Order adds a samurai sword to the list of weapons contained in the principal Order. A samurai sword is a sword with a curved blade of 50 cms or more in length.
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