Rasul v Regina (Criminal Appeal No. 324 of 1953)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
An advocate cannot add grounds of appeal or file a second petition by letter to the Registrar months after conviction. When a petition of appeal under section 350 of the Criminal Procedure Code has been filed, the advocate may argue only those grounds stated in the petition. To raise additional grounds requires a motion to amend the petition, which is at the court's discretion and may be refused if filed long after the appeal period or if grounds relate only to questions of fact not raised at trial. Motion allowed in the special circumstances of this case.
Outcome
Motion allowed; appellant permitted to amend petition of appeal
Facts
The appellant was convicted of arson and other offences on 11 May 1953. His advocate filed an appeal on the same day. Three months later, on 7 August 1953, a different advocate addressed a letter to the Registrar proposing to argue further grounds in addition to or alternative to those in the original petition. The advocate claimed this was usual practice. The Attorney-General objected. The appellant's advocate then filed a formal motion seeking an order to amend the petition of appeal by adding further grounds. The Crown opposed the application.
Issues
- Whether an advocate may add grounds of appeal by letter to the Registrar three months after filing the original petition of appeal.
- Whether the Court should exercise its discretion to allow amendment of a petition of appeal by addition of further grounds filed long after the original petition.
Orders
- Motion to amend petition of appeal by addition of further grounds allowed.
Rules and key headnotes
Legislation cited (5)
- Criminal Procedure Code s.350
- Criminal Procedure Code s.353
- Penal Code s.327(a)
- Penal Code s.394
- Penal Code s.308/390
Cases cited (1)
- Gray v Regina (1906) 2 EALR 40
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.