R (Adams) v Secretary of State for Justice
[2011] UKSC 18
Ratio Decidendi
The right to compensation for miscarriages of justice under s 133 Criminal Justice Act 1988 requires the applicant to show that a newly discovered fact shows beyond reasonable doubt that there has been a miscarriage of justice, meaning the applicant is clearly innocent.
Fakty
Mr Adams was convicted of murder but his conviction was quashed on appeal. He applied for compensation for miscarriage of justice.
Podsumowanie orzeczenia
The Supreme Court held (by majority) that compensation is only available where the new fact shows the applicant is clearly innocent, not merely where the conviction is unsafe.
Kluczowe cytaty
"A miscarriage of justice for the purposes of section 133 means that a new or newly discovered fact shows conclusively that the evidence against the person at trial has been so undermined that no conviction could possibly be based on it."
— Lord Phillips
Późniejsze zastosowanie
Defines the threshold for compensation for wrongful conviction.