9.11.2017
A & Ors v Secretary of State for the Home Department [2004] EWCA Civ 1123 (11 August 2004)
vouchsafes the result for which he contends. In particular, the principle must be one which, by force of
its constitutional or fundamental nature, subordinate legislation such as Rule 44(3) cannot lawfully
override in the absence of express or at least specific authority: see for example such cases as Simms.
244. In what might such a principle consist? Mr Emmerson has two candidates. First he submits that the
admission by SIAC of evidence which may have been obtained by torture would by the common law
amount to an abuse of process. He says that this principle of abuse of process is independent of the
common law rule relating to the exclusion of improperly obtained confessions. Whether that latter rule
depended on the need to exclude unreliable admissions or more generally on the law's repugnance to
torture, the condemnation of abuse of process is distinctly based on the common law's refusal to
tolerate arbitrary or oppressive conduct by State authority. It amounts to a constitutional fundamental,
and it would be violated by SIAC's receiving evidence which may have been obtained by means of
torture or other violation of Article 3.
245. Mr Emmerson's second argument on this part of the case was that the reception of evidence of the kind
objected to would constitute a violation of ECHR Article 6(1); and the court should read Part IV of
ATCSA so as to avoid such a result, and so hold that such evidence should be excluded. I should say at
this stage that in developing his case both on the common law and Article 6 Mr Emmerson was at
pains to muster the support of CAT Article 15 which, in both contexts, was he said "an important
source of guidance".
246. Mr Emmerson also advanced a subsidiary argument. It took a little teasing out, and that was done with
the assistance of further written submissions supplied after the close of the hearing. It was, as in the
end I understood it, as follows. (1) Admission of evidence of the kind objected to would violate the
United Kingdom's obligations under CAT Article 15. But (2) compliance with our international
obligations (other than those arising under ECHR) is a condition of a lawful derogation under ECHR
Article 15. (3) We should therefore construe ATCSA as not permitting the admission of such evidence;
it is to be presumed that the derogation was lawful, and the statute should be interpreted (so far as
possible) to promote that result.
The Common Law – Abuse of Process
247. Mr Emmerson placed substantial reliance on recent leading cases dealing with abuse of the process in
the criminal jurisdiction: Ex p. Bennett, R v Mullen (in which the judgment of the Court of Appeal
Criminal Division delivered by the Vice President contains substantial citations from their Lordships'
opinions in Bennett), and in particular R v Looseley in their Lordships' House. With respect I need
consider only the reasoning in Looseley. There were two cases before their Lordships. Both involved
entrapment or alleged entrapment; in each the accused had supplied heroin to undercover police
officers. I need say nothing more about the facts. Lord Nicholls said this:
"1. My Lords, every court has an inherent power and duty to prevent abuse of its process.
This is a fundamental principle of the rule of law. By recourse to this principle courts
ensure that executive agents of the state do not misuse the coercive, law enforcement
functions of the courts and thereby oppress citizens of the state. Entrapment, with which
these two appeals are concerned, is an instance where such misuse may occur. It is simply
not acceptable that the state through its agents should lure its citizens into committing acts
forbidden by the law and then seek to prosecute them for doing so. That would be
entrapment. That would be a misuse of state power, and an abuse of the process of the
courts. The unattractive consequences, frightening and sinister in extreme cases, which
state conduct of this nature could have are obvious. The role of the courts is to stand
between the state and its citizens and make sure this does not happen."
Lord Nicholls proceeded to discuss earlier learning, not least their Lordships' decision in R v Sang in
which the House affirmed that, aside from admissions and confessions, the court was not concerned
with how evidence was obtained. Then at paragraphs 11 and 12 he considered s.78 of the Police and
Criminal Evidence Act 1984, and continued:
"12. … Most recently in R v Shannon [2001] 1 WLR 51, 68, para 39 Potter LJ, as I read
his judgment, accepted that evidence may properly be excluded when the behaviour of the
http://www.bailii.org/ew/cases/EWCA/Civ/2004/1123.html
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