Regina v Patel (Nitin): CACD 11 Nov 2004

The defendant appealed his conviction under the 1977 Act.
Held: The judge directing a jury must require a finding that the different acts complained of had a sufficient connection with each other to form a ‘course of conduct’ within the Act. For a number of incidents to constitute a course of conduct, they must be related in type and in context.

Judges:

Maurice Kay LJ, McCombe J, David Clarke J

Citations:

Times 29-Nov-2004, [2005] 1 Cr App R 440

Statutes:

Protection form Harrassment Act 1997 2(1)

Jurisdiction:

England and Wales

Citing:

CitedLau v Director of Public Prosecutions QBD 29-Mar-2000
Two alleged incidents might be sufficient to be seen as a course of conduct and found an allegation of harassment under the Act, but any distance in time between them might suggest that they could not be seen as one course of conduct. Here a . .
CitedPratt v Director of Public Prosecutions QBD 21-Jun-2001
Whilst the law clearly allowed prosecutions under the Act after no more than two incidents of harassment, nevertheless, prosecutors should look to the reality of whether the acts complained of did in fact amount to a course of conduct under the Act. . .

Cited by:

CitedJames v Crown Prosecution Service Admn 4-Nov-2009
The appellant was receiving care and support from social services. He was found to have abused and threatened the team leader in telephone calls to her. He appealed against a conviction under the 1997 Act, saying that his calls did not amount to a . .
Lists of cited by and citing cases may be incomplete.

Crime

Updated: 06 May 2022; Ref: scu.220241