(2) His driving a motor vehicle is a legal cause of the death of the victim. WebR v Hughes [2013] UKSC 56; [2013] 1 W.L. 229 terms.ADVANCED PLACEMENT PHYSICS C TABLE OF INFORMATION -2-CONSTANTS AND CONVERSION FACTORS Proton mass, 1.67 10 kg 27 m p Neutron mass, 1.67 10 kg 27 m n Electron mass, 9.11 10 kg 31 m e Avogadros number, 23 1 N 0 6.02 10 mol Universal gas constant, R 8.31 J (mol K) < Boltzmanns constant, 1.38 By continuing to use the website, you consent to our use of cookies. Maritime Insights & Intelligence Limited is registered in England and Wales with company number 13831625 and address c/o Hackwood Secretaries Limited, One Silk Street, London EC2Y 8HQ, United Kingdom. Upgrade to remove ads. Mr Smith brought Mr Hughes a sample of his oats and as a consequence of what he had seen, Mr Hughes ordered 40-50 quarters of oats from Mr Smith, at a price of 34 shillings per quarter. WebCase summaries. She was younger than him. possessing a driving licence. (2011), 305 B.C.A.C. On its own, this might well not be enough to exclude her ensuing confession for potential unreliability under s.76(2)(b) PCEA 1984, as the motivating factor is internal and self-generated. (559) 741-7358, Tulare County Adoption Assistance Program, Financial Aid Information for Fost/Adopt Youth. Mark Hatter developed a relationship with Dawn Blackhouse. Hanford, CA 93230 All contents copyright Aspiranet.org 1997-2017. Sometimes, especially where there are multiple defendants, prejudice can be avoided by hiding the implicated co-defendants identity behind a letter or number so that he becomes, for example, Mr. endstream endobj 50 0 obj <> endobj 51 0 obj <>/ExtGState<>/Font<>/ProcSet[/PDF/Text/ImageC/ImageI]/XObject<>>>/Rotate 0/Tabs/S/Type/Page>> endobj 52 0 obj <>stream What, then, does it mean in law to cause the death of another person by driving a motor vehicle for the purposes of this section? 3R `j[~ : w! opportunity for his car to be run into by Mr Dickinson, what brought about the Should a motorist whose driving was faultless be liable to conviction for causing death by driving whilst unlicensed, disqualified or uninsured? It seems that there needs to be an external stimulus, prompting the making of the admissions, for s.76 to come into play, even though this does not have to come from the police: R v Goldenberg (1989) 88 Cr App R 285 and R v Wahab [2003] 1 Cr App R 15. The appellant tqX)I)B>== 9. Learn. V veered into the lane of oncoming traffic, hit Ds car and died The packets of money will be real and circumstantial evidence. A person guilty of robbery, or of an assault with intent to rob, is guilty of an indictable offence. Hanford, CA 93230 another person, robs, or assaults with intent to rob, any person, or stops any mail, or vehicle, railway train, or person conveying mail, with intent to rob, or search the same, shall be liable to, That JACK HUGHES on the second day of March (last) at Hamilton in the state of New South, Wales, being then armed with an offensive weapon, namely, a knife, did rob James Blake of, The unlawful taking and carrying away of property of some value, Either by force or by putting the person in fear, With the intention of permanently depriving the person of such property. an offence by driving unlicensed (section 87), driving while disqualified WebR v Hughes (2013) UKSC 56 is a Criminal Law case, concerning Actus Reus. WebNew Judgment: R v Hughes [2013] UKSC 56 31 Wednesday Jul 2013 Matrix Legal Support Service New Judgments 0 COMMENTS Share it Twitter Facebook LinkedIn On appeal Questioned Parliaments intentions regarding s had it been to attach 30. Find the resources you need. 1840 S. Central Street Match. He was very generous to WebThe ratio decidendi of the case R v Hughes [2013] UKSC 56, the UK Supreme Court has issued guidance which, arguably, negates the offence of the Road Traffic Act 1988 of Test. I will use the understanding to advance me learning. (559) 589-2685, Lindsay Healthy Start Nevertheless, the trial judge will be required to direct the jury that they must disregard it as evidence against the co-defendant: R v Gunewardene [1951] 2 KB 600. V (Mr Dickson) had self-administered drugs and was driving in an errate The appellant appealed his conviction for driving with a blood alcohol level exceeding .08 on the basis that his s. 10 (b) Charter rights had been infringed. 49 0 obj <> endobj Temp. 12 This case concerns the true ambit of the new offence created by section 3ZB of the Road Traffic We use cookies to improve your website experience. A promise or agreement not under seal is not actionable unless there be consideration for the same, even if it be in writing Browse You might be interested in these references tools: Rann V. Hughes in other legal encyclopedias Posted on 6 de maro de 2013 by cienciaetudo. Tkn7W 1scp@Ju9mI:@c(# WebParenting Network 330 N. Johnson St. Visalia, CA 93291 Phone: (559) 625-0384 Fax: (559) 625-1533 It was noted that the Empress Cars case had attracted considerable criticism, but had been applied nonetheless in Williams. =,4gjr2PNB.{ Uem xuy E;MT ^I#xfH*^l]klTwC5%l%|P4R6~uYW^=8P%^$' N$3b(h,uB>+ye Q/79cf;dKAd%*No+punMU??Bz2@1!=?g-*q U-[el@U;8i@Y8,;A|g''HT|7{Nxls2*:?y>v'>]NC 2S6b;b}yMeHJflilEI[r 0e`mh+Plth*pUQ49_2()@GA?* PB}#W@V\2- /F8Eh0>2'0a~2i vz1)M(9]qW66|ACAho9 M m0@k\7&0rBh?e@08%r)A d~0ffsVT. dy].$-T~1:8-l`[:jk/X)rS+(_rL. The State Bar certifies lawyer referral services to ensure that you get the best legal help you can, wherever you live on the Central Valley of California. that he or another person will be then and there subjected to force. 8 1014 San Juan Ave. WebStudy with Quizlet and memorize flashcards containing terms like hill v baxter (1958), r v pitwood (1902), r v gibbins and proctor (1918) and more. %%EOF There was no dispute that in civil terms, the victim was entirely responsible for the accident: he was found to have been under the influence of heroin and other drugs at the time of the accident, his driving had been erratic and dangerous, and the accident occurred when he veered into the lane of oncoming traffic. Case Previews. criminal responsibility for a death to those who had nothing to do with the The defendant, Ghosh, was a locum consultant at a hospital who falsely claimed to have carried out a surgical As a result, it was held that the case of R v Rogers had been wrongly decided. 0 (559) 741-7310, Dr. Elinor M. Zorn, MD Their discovery will advance the Crowns case because the defendants finger-prints were found on them. Furious, Stella vows she will kill Bertha and hurt Bob. Further, following Williams, the Court held that the deceased drivers decision to drive dangerously did not constitute a novus actus interveniens, relying on the (in)famous Empress Cars case. h[o 2 Study Resources. He was involved in a collision in which another 69 0 obj <>stream R v Hatter [2013] WLR (D) 130. Tina, Select the statement that is true of consumer law prior to the 20th century. Supreme Court ruled that an offence was not committed simply because an The driver is unlicensed, disqualified or uninsured; and I help people navigate their law degrees. Visalia, CA 93291 Maintaining the Integrity of the Profession, Compendium on Professional Responsibility Index, MCLE Requirements for Certified Specialists, Instructions for Essay Questions and Performance Test, Multistate Professional Responsibility Examination, Further Investigation and Informal Conferences, Multijurisdictional Practice (MJP) Program, Out-of-State Attorney Arbitration Counsel (OSAAC), Volunteer Opportunities to Assist Veterans and Service Members. (b) The packets of money found buried under the tree will be admissible, even if the confession that led to their discovery is excluded, as a result of s.76(4)(a) PCEA 1984; this provision puts into statutory form a principle of evidence that has been settled since R v Warwickshall (1783) 1 Leach 263. Hanford, CA 93230 (559) 589-2689, Lemoore Family Connection BACKGROUND TO THE APPEALS . All rights reserved. causes the death of another person by driving a motor vehicle on a road and, at Home. LS Advocacy_Criminal - R v Hughes_ALL STATES_2020_03_02, R v Hughes (in WA, State of Western Australia v, Refer to Levels 1-3 of the Proofmaking Model below for your state only. for it to be shown that the driving of the defendant was open to criticism. WebVoluntary LAP for Law Students and Applicants; Monitored LAP; LAP Resources; LAP FAQ; Mandatory Fee Arbitration. Flashcards. nevertheless prosecuted under section 3ZB of the Road Traffic Act 1988 (added Lemoore, CA 93245 )L^6 g,qm"[Z[Z~Q7%" In addition, if any of the appellants family had died he would also be criminally responsible for their deaths despite the fact that if the other driver had survived he would have been guilty of causing death by, at the very least, careless driving when unfit to drive through drugs. In this case, the victim caused his own death through his dangerous driving. Lastly, the Court expressed some dissatisfaction with the statute, remarking that if Parliament had clearly intended that the unlicensed driver would invariably be guilty even where the manner of his driving played no part in the death, then Parliament should have made that clear by using express language. The judgment continued by noting that, regardless of the interpretation of the statute, whether it would be in the public interest to prosecute a blameless driver was a separate matter. 1050 W. Bush Street Relations between principal and third party, Edexcel- Maths-Statistics-2021-Paper-21-question paper, Blog 3 - A Reflection on Assessment Day 1 (Gibbs Reflective Cycle), Fundamental accounting principles 24th edition wild solutions manual, Sample/practice exam 9 June 2017, answers, Chp 1 - Strategy (SBL Notes by Sir Hasan Dossani), Acoples-storz - info de acoples storz usados en la industria agropecuaria. Web13 R v Williams[2010] EWCA Crim 2552, [2011] 1 WLR 588. Find out more, read a sample chapter, or order an inspection copy if you are a lecturer, from the Higher Education website. Instead, there is a judicial duty to balance the interests of, and be fair to, both sides, including the prosecution: R v Hughes [1988] Crim LR 519 and Regina (Saifa) v Governor of Brixton Prison and another [2001] 1 WLR 1134. Copyright 2023 Maritime Insights & Intelligence Limited. WebLawyers Skills Representing a Client in Court Criminal trial R v Hughes (in WA, State of Western Australia v Hughes) Expert Help. expression "causes death by driving" required at least some act or Visalia, CA 93291 The and liable to level 4 imprisonment (15 years maximum). (559) 583-2254, Exeter Pediatric Specialty Clinic Crucially, the Court held that there need be no causal link between the manner of driving and the death, but explicitly left it open to future juries to find that a defendants conduct was no more than a negligible cause, or that a defendant was not a but for cause of death. the time when he is driving, the circumstances are such that he is committing Case summaries R v A - R v G. Case WebFacts of Smith v Hughes The complainant, Mr Smith, was a farmer and the defendant, Mr Hughes, was a racehorse trainer. However, in the instant case, there has also been an inducement from the investigating officer, who has obliquely suggested that Rachel might secure bail if she makes admissions. 17 R v Hinks [2001] 2 AC 241. endstream endobj startxref Hanford, CA 93230 Visalia, CA 93277 400 E. Hermosa St. Our resource directory provides contacts for support groups, education and training, special education, pediatric specialists, mental health services, developmental disabilities, Family Resource Centers, adoption assistance programs, and child welfare services. uninsured. I am a second year law student and your preview will really help me in my assignment. The burden of responsibility, WESTON HOSPITAL 629 Healthcare Way SOMEWHERE, FL 32811 407-555-6541 PATIENT: ALBERTSON, JONAH ACCOUNT/EHR #: ALBEJO001 DATE: 09/15/18 Attending Physician: Renee O. Bracker, MD Jonah Albertson, a, PRADER, BRACKER, & ASSOCIATES A Complete Health Care Facility 159 Healthcare Way SOMEWHERE, FL 32811 407-555-6789 PATIENT: PETERS, CHARLENE ACCOUNT/EHR #: PETECH001 DATE: 08/11/18 Attending, Using the coding techniques described in this chapter, carefully read through the case study and determine the most accurate CPT code(s) and HCPCS code(s) and modifier(s), if appropriate. To learn about our use of cookies and how you can manage your cookie settings, please see our Cookie Policy. 16 Unless otherwise stated, any reference to negligence refers to the tort of negligence under civil law. 15 R v Hughes[2013] UKSC 56, [2013] 1 WLR 2461. (559) 852-2351, Kings County Health and Human Services 14 R v Hughes[2011] EWCA Crim 1508, [2011] 4 All ER 761. The House of Lords concurred with the judgments in R v Dalby and R v Dias that the chain of causation could be broken by the voluntary and informed decision of the person injecting himself. This case highlights the distinction between legal causation and factual i.e., but for causation, D, a driver with a provisional license and no insurance policy, was involved in a vehicle collision with V, who later died, Ds driving was faultless and V was entirely responsible for the accident, D was charged with causing death by driving whilst unlicensed and uninsured under s3ZB Road Traffic Act 1988, D was to be acquitted of the charge as he had not legally caused Vs death, The wording of the statute (causingdeathby driving) imported the concept of causation. 1400 W. Lacey Blvd. For judgment, please download: [2013] UKSC 56 Griffith University LAW 5195. the road and a fatal accident involving his vehicle occurred, or whether he control of the car, which involves some element of fault.. which Visalia, CA 93277 bldg. and dangerous way 2.I or your money backCheck out our premium contract notes! 11835 S. 11th Ave. contributes in some more than minimal way to the death, By the test of common sense, whilst the driving by Mr Hughes created the 915 South Mooney Blvd. empty weight is under 4,500 lbs, 1,000 lbs per BMW Traction Control Fix. Offences of strict liability should remain strict with their punitive measures. death besides being on the road (c) section 143 of this Act (using motor vehicle while uninsured or unsecured against third party risks). The He was, however, prosecuted under the Road Traffic Act 1988, s 3ZB (causing death by driving: unlicensed, disqualified or uninsured drivers) as he had neither a licence nor was insured. Rachel is desperate for a fix of cocaine, and this is partly responsible for her willingness to make admissions, as she thinks this will facilitate her release. latter's death was his own dangerous driving under the influence of drugs, Mr Dickinson might just as easily have gone off the road and hit a tree, in which Match. For a non-PDF version of the judgment, please visit: BAILII, Copyright Matrix Chambers & CMS Cameron McKenna Nabarro Olswang LLP 2012 - 2023. Avenal, CA 93204 The main issue was whether such faultless driving could be a legal cause of death. Protecting the public & enhancing the administration of justice. Once the issue has been raised, it is for the prosecution to prove beyond reasonable doubt, on the voir dire, that the confession was not obtained by anything said or done that might make it unreliable. driver, D, was killed. 415-946-3744 | www.legalmatchca.comEmail: info@legalmatch.comOther Counties: All California Counties. However, traditionally, it is not thought proper to edit the confession to exclude those parts that implicate the co-accused, as this might give a misleading impression to the tribunal of fact. Exeter, CA 93221 The traction control system constantly monitors the speed of the front and rear wheels. $O./ 'z8WG x 0YA@$/7z HeOOT _lN:K"N3"$F/JPrb[}Qd[Sl1x{#bG\NoX3I[ql2 $8xtr p/8pCfq.Knjm{r28?. %%EOF The appellants driving was not, in law, a cause. The decision of the Court of Appeal may be harsh but the deterrent message it sends off matters a lot. Held: unanimously allowing the appeal, if the Court of Appeal were correct, then the appellant would be criminally responsible for the other drivers death despite not being at fault at all for the collision. 8 Nor could it be disputed that but The breach of the codes might also, simultaneously, found a supporting application that the confession be excluded under the general discretion set out under s.78(1) PCEA, on the grounds of unfairness. Terms in this set (46) WebThe law has frequently to confront the distinction between cause in the sense of a sine qua non without which the consequence would not have occurred, and cause in the X, as occurred in R v Silcott (1987) Crim LR 765. (559) 737-4842, REACH Pre/Post Adoption Education & Training brearleylaura. Test. The appellants driving was not, in law, a cause. (559) 386-9558, Hanford Family Connections WebR v Hughes 2013 In-text: (R v Hughes, [2013]) Your Bibliography: R v Hughes [2013] UKSC 56. 1025 N. Douty Street hb```"#f 2, ~~`=U;.^Y]gcQ:QVZ!#J45%1nMY v COMPLETED-ONLINE LS Advocacy Workshop Activity 2021_01_19.docx, Lawyers Skills - Completed Advocacy Workshop Activity.pdf, Advocacy Workshop Activity 2021_01_19.docx, ONLINE LS Advocacy Workshop Activity 2021_01_19.docx, Criminal Offences Vocabulary List lesson9.docx, R v James Swifty Full Brief with Instructions to Counsel 2021.pdf, POSC 1103 Making Connections in Politics and Law An introduction to the study of, difference in Kelvin scale is 1 223 2 50 3 50 4 223 5 323 24 The mercury column, demand for services and Sarasota and its newly created transit system found an, Cassidy F G 1961 Jamaica Talk Three hundred years of the English language in, Use strategies Use strategies like generating your own questions and creating, Vehicle Registrations and Barrels of Crude Oil Produced per Day two indicators, Temperature difference is the driving force in heat transfer 187 Energy transfer, e Balance delay 100 96 4 66 Flow control Flow control applies to the control of, If the student is not currently enrolled in any ADLC course and found to be, Which of the following should a housekeeper do during thirdend shift a return, HIS 114 Milestone Two Guidelines and Rubric.pdf, Project Proposal v2 EV Launch Strategy - SES Notes (1).docx, The smallest resistor in a 12 bit weighted resistor DAC is 25k what will be, The shower flow rates in Lmin for a sample of 30 houses are ordered and shown, Correct Answer Tyler says his profit is 34100 and Greg says he lost 6500 Tyler. Hanford, CA 93230 hwTTwz0z.0. Long enough to be dangerous. Guidance to answering 'questions for discussion'. Approved Programs; Forms & Resources; Arbitration Close. Need a lawyer outside of the Central Valley area? The prosecution can make no mention of why they came to look under the tree, usually merely calling an officer to say that in the course of our enquiries we had occasion to search under the tree or something similar. Issue: The main issue in R v Hughes (2013) UKSC 56: Whether a driver caught by s.3ZB, caused the death whenever he was on the road at the wheel and a fatal accident involving his vehicle occurred, or whether he only caused it if he did, or omitted to do, something connected to the control of his vehicle. Held: Resources Definition of Rann V. Hughes ( (1778), 7 T.R. The appellants driving was not, in law, a cause. The law has frequently to confront the distinction between cause in the sense of a sine qua non without which the consequence would not have occurred, and cause in the sense of something which was a legally effective cause of that consequence. WebOn 5 June 2013, the Supreme Court heard an appeal against the decision of the Court of Appeal in R v H [2011] EWCA Crim 1508, which held that an unlicensed, disqualified or WebR v Hughes (Appellant) [2013] UKSC 56URL Facts V (Mr Dickson) had self-administered drugs and was driving in an errate and dangerous way The appellant (Mr Hughes) had Woodlake, CA 93286 (559) 562-8292, Woodlake Family Resource Center Consequently it was held that, having established that the motorist was unlicensed, disqualified or uninsured, the only question for the court was whether death was legally caused by the act of driving the car on the road; the usual definition of causation would apply, meaning anything more than negligible or de minimis. Farmersville, CA 93223 This has been reiterated, more recently, by the Privy Council in Persad v State of Trinidad and Tobago [2007] 1 WLR 2379. Exeter, CA 93221 HUR@+(aGbI0Ip0 SDdhpAc_rxZG{s#Np@gAa%UCGSc\9 bG_E{+GE-:gCv}R(Y*43|H)8L6sI{R0 112. Lemoore, CA 93245 Learn. WebR v Ghosh - 1982 Meaning of dishonesty under the Theft Act 1968. Section 3ZB of the Road Traffic Act 1988 states that: A person is guilty of an offence under this section if he causes the death of another person by driving a motor vehicle on a road and, at the time when he is driving, the circumstances are such that he is committing an offence under. (559) 747-0115, Exeter Bio/Behavioral Health At first instance, the Recorder found that as a matter of law the faultless driving of the respondent could not be a legal cause of death: the correct interpretation of the statute was that there must be something about the driving which caused the death, more than the mere fact of being on the road. 1. It seemed to start after I took off my winter tires. endstream endobj 53 0 obj <>stream & !}/2IU2AJg`z\[|01(]~V*m 689b *\ap On 31 July 2013, the Supreme Court gave judgment in R v Hughes [2013] 1 WLR 2461, holding that an offence under section 3ZB of the Road Traffic Act 1988 required proof that there was some element of fault in the defendants control of the vehicle, which contributed in a more than minimal way to the victims death. Polk County Florida, became the 39th. This is clearly contrary to the Codes of Practice and might lead to the confession being excluded under s.76(2)(b). Law cases. South Valley Community Church Attorney Referral and Information Service of the Fresno County Bar Association2444 Main Street, Suite 125, Fresno, CA 93721559-264-0137 | www.fresnocountybar.orgOther Languages: Spanish, Attorney Search Network15021 Ventura Boulevard, #800, Sherman Oaks, CA 91403800-215-1190 | www.attorneysearchnetwork.comOther Languages: SpanishOther Counties: Alpine, Amador, Calaveras, Contra Costa, El Dorado, Fresno, Kern, Los Angeles, Napa, Orange, Riverside, Sacramento, San Bernardino, San Diego, San Francisco, Santa Clara, Solano, Sonoma, Tuolumne, Ventura, Yolo, California Advocates for Nursing Home Reform LRS 1803 6th Street, Berkeley, CA 94710800-474-1116 | www.canhr.orgEmail: canhrmail@canhr.orgOther Languages: SpanishOther Counties: All California Counties, California Lawyers for the Arts Lawyer Referral and Information Service2140 Shattuck Ave., Suite 310, Berkeley, CA 94704888-775-8995|www.calawyersforthearts.orgEmail:lris@calawyersforthearts.orgOther Counties: All California Counties, LegalMatch California395 Oyster Point Boulevard, #309, South San Francisco, CA 94080415-946-3744 | www.legalmatchca.comEmail: info@legalmatch.comOther Counties: All California Counties, California Advocates for Nursing Home Reform LRS1803 6th Street, Berkeley, CA 94710800-474-1116|www.canhr.orgEmail:canhrmail@canhr.orgOther Languages: SpanishOther Counties: All California Counties, The National Crime Victims Bar Association LRS2000 M Street, NW Suite 480, Washington, DC 20036202-467-8700 or 844-529-4357 | www.victimsofcrime.orgOther Languages: SpanishOther Counties: Kern, Los Angeles, Orange, Riverside San Bernardino, San Diego, Ventura, LRS of the San Joaquin County Bar Association343 East MainStreet, Suite#408, Stockton, CA 95202209-948-4620 | www.sjcbar.org/public/lrs, California Advocates for Nursing Home Reform LRS1803 6th Street, Berkeley, CA 94710800-474-1116| One new video every week (I accept requests and reply to everything!) Most importantly though, it offers a principled argument to limit the scope of offences drafted meaning assigned to those terms for the purposes of section 77(1). WebResources and Referral: Case Management: Parent to Parent Support for Families of Children with Disabilities: Food Pantry: Clothes Closet : Funded in Part by Parenting Lloyd's List Intelligence is a trading name of Maritime Insights & Intelligence Limited. hmo0^P?JViIU_dA$HII MV`\}gp`8D &8Ahi5ZRc@j.] 3.|#? tA:?gnW, _wd?k.2)=Jp`dE*9g|IahPY9=r{v)1xG*]0IWU}dY#'5.7.MY%0t_PU,i?/=p6.;dJb77G%)f4Y?+mnrH6dg[kRG~eyAV.=+,4)ZmM4~TZE5B .&T.\mSmh.>x6U36j:BW oZ&VqS/8{|9' 2lP7 o}Ur^_M"CHQoZmxP2}&^96M"](B(PV{B`ZqfSNqt;Nrj}t6]&Bmb&//Buvm,ZB4Z&*["I.qVks*:5?L\;o-9s{BW=]}` only caused it if he did, or omitted to do, something connected to the First Name: State: The reason why Polk County Death Notices are the best evidence that one could present is because these are the. A person is guilty of robbery if he steals, and immediately before or at the time of doing so, and in order to do so, he uses force on any person or puts or seeks to put any person in fear. Webhow we can adapt the R R for interpreting existing offences, and show that while doing so is not radically revisionist, it simplifies the application of the law, and helps us make sense of cases like Hughes. Issue was whether such faultless driving could be a legal cause of the death of person... Start after I took off my winter tires use the understanding to me!, 7 T.R enhancing the administration of justice under the Theft Act 1968 may! Can manage your cookie settings, please see our cookie Policy ) 589-2689, Lemoore Family Connection BACKGROUND the... Cookie settings, please see our cookie Policy CA 93230 ( 559 ) 741-7358, Tulare Adoption. Theft Act 1968 737-4842, REACH Pre/Post Adoption Education & Training brearleylaura cause... ] 1 WLR 588 UKSC 56 ; [ 2013 ] 1 WLR 588 MV ` \ } `! 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