The Gazette 1971

the Court certified that a point of law of general public importance was involved and granted the Crown leave to appeal to the House of Lords. [Regina v Hudson; Regina v Taylor; Court of Appeal; The Times, 19th March 1971.] National Insurance stamps issued pursuant to the regulations made under the National Insurance Act, 1965, of the United Kingdom were held to be "valuable securities" and "docu- ments evidencing the title of any person to any interest in any public fund of any part of her majesty's dominions" within the meaning of Section 2 of the Forgery Ordinance, Cap. 209, of Hongkong. Their Lordships allowed an appeal on a point of law by the Attorney General of Hongkong against the judgment of the Supreme Court of Hongkong. [Attorney General of Hongkong v Pat Chiuk-wah and others; Privy Council; The Times, 23rd March 1971. After dismissing an appeal by Arthur Selby, coin dealer, of Ben Jonson Road, E., against conviction under the Coinage Offences Act, 1936, their Lordships certified that the meaning of "intent to utter" in Section 5 (3) was a point of law of general public importance and gave leave to appeal to the House of Lords. The appellant had been found guilty at Inner London Sessions (deputy chairman: Mr. Murray Buttress) last Sept. on a charge of having in his possession forty-five false or counterfeit coins resembling current gold coins, knowing them to be false or counterfeit, and with intent to utter or put off the coins or any of them. [Regina v Selby; Court of Appeal; The Times, 2nd April 1971.] Reasons were given for the dismissal on February 23rd of an application by Daniel Twomey, aged twenty-eight, for leave to appeal against conviction at Warwickshire Assizes (before Mr. Justice Lawton) of the murder of James Reed. Their Lordships had heard oral evidence from a witness in accordance with Section 23 (2) of the Criminal Appeal Act, 1968, which provides that the Court of Appeal "shall" exercise its power of receiving tendered evidence if "(b) . . . satisfied that . . . there is a reasonable explanation for failure to adduce it" at the trial. [Regina v Twomey; Court of Appeal; The Times, 11th March 1971.] Criminal Injuries (Before Lord Parker, the Lord Chief Justice, Lord Justice Widgery and Mr. Justice Bridge) A woman bystander who was injured when an arrest was being attempted was held to be entitled to compensation from the Criminal Injuries Compen- sation Board. It was not necessary that the bystander should be participating in the arrest. [Regina v Criminal Injuries Compensation Board; Q.B.D.; 1st April 1971.] Damages The Court increased to £62,183 from £45,757 an award of damages made to a plaintiff gravely injured in a road acci- dent. Their Lordships rejected the plaintiffs contentions (which would have resulted in an award of over £90,000) that account ought to be taken of the likelihood of inflation continuing, and, further, that the damages ought to be assessed by actuarial calculation instead of by the conventional method of multiplicand and multiplier. [Mitchell v Mulholland and Another; Court of Appeal; The Times, 19th March 1971] Evidence Contemporary hospital notes made by doctors and nurses about- a patient in 1965 defeated a claim for damages by a plaintiff seriously injured in a car accident who pleaded that for thirty- two days after it he was a person under the disability of unsoundness of mind such as to render him incapable of managing his affairs, and that therefore time should not run against him under the Limitation Acts. [Penrose v Marsfield; Court of Appeal; The Times, 19th March 1971.] See under Crime; Regina v Twomey; Court of Appeal; The Times, 11th March 1971. Family Lloyd-Jones J., in the first defended divorce suit in which Sec- tion 2 (1) (a) of the Divorce Reform Act, 1969, had been construed, held that in that sub-section, which empowers the

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