Regina v Pawlicki; Regina v Swindell: CACD 3 Jun 1992

P had driven to an auctioneer’s showroom, parked outside and locked the car. He left three sawn-off shotguns inside, and went into the auction house and stood a few feet from S. Police officers had been alerted to the possibility of a robbery and arrested them both. P and S were convicted inter alia of having firearms with intent to commit robbery contrary to section 18.
Held: The defendant was properly convicted of having a firearm with intent to rob despite the gun being in a car 50 yards away from the offence. The phrase ‘having with him a firearm’ is to be construed purposely. The section imported an element of propinquity which is not required for mere possession. The emphasis was on the accessibility of the guns to those embarking on committing an indictable offence, rather than on the exact distance between them and the guns.
Gazette 03-Jun-1992, Gazette 26-Aug-1992, [1992] 1 WLR 827
Firearms Act 1968 18(1)
England and Wales

Updated: 29 July 2021; Ref: scu.87533