R v Foxley
Legislation
s.24 Criminal Justice Act 1988
Keywords
Documentary evidence
Counsel
Mr Roy Amlot, QC, Mr Christopher Sallon,QC, Mr Victor Temple, QC, Mr Warwick McKinnon
Solicitor:
unknown
Judge:
Roch LJ, Curtis J and Stuart White J
Court:
Court of Appeal, Criminal Division
Reported:
[1995] Crim.L.R. 636
Summary:
Documents were admitted in evidence in criminal proceedings under s.24 Criminal Justice Act 1988. The documents were purported to emanate from three foreign companies and were produced by an investigating officer who had received them in this country following letters of request to the appropriate authorities in the countries concerned.
The purpose of s.24 is to enable a document to speak for itself if
- the document was created in the course of trade, and
- the information in the document was supplied by a person who had personal knowledge of the matters dealt with.
Oral evidence is not required from a person who was either the creator or the keeper of the document, or the supplier of the information in the document, or from the officer who had seized the document, or from an officer of the relevant company to prove that they were documents created in the course of business, although it may be desirable.