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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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