[2013] EWHC 72 (Admin)

In claims for compensation under the Criminal Justice Act 1988 s.133 brought by persons whose convictions had been quashed, a useful formulation for identifying whether the claim fell within category 2 identified in R. (on the application of Adams) v Secretary of State for Justice [2011] UKSC 18, [2012] 1 A.C. 48 was "has the claimant established, beyond reasonable doubt, that no reasonable jury or magistrates properly directed as to the law could convict on the evidence now to be considered?" The court gave guidance as to how the secretary of state should approach such claims and how courts should approach applications for judicial review of the secretary of state's decisions.

QBD (Admin) (Beatson LJ, Irwin J)

25/01/2013