The ingredients of the offence were an essential part of summing-up where there was an issue as to whether the ingredients had been proved. When a person was charged on indictment of a s.4 Protection from Harassment Act 1997 offence, a direction on the alternative offence under s.2 of the 1997 Act should routinely be given.

CA (Crim Div) (Pill LJ, Brian Smedley J, Crane J)


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