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Regina v Spence; CACD 24 May 1999

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References: Times 24-May-1999, [1999] EWCA Crim 808, [1999] RTR 353
Links: Bailii
Ratio: A private company car park, where there was no proof of use by the public, was not a public road, and a driver could not be convicted of dangerous driving whilst in it. There must be evidence that the public actually utilised premises before a court can conclude that they are a ‘public place’. It is not sufficient to say that the public could have access if they were so inclined.
Statutes: Road Traffic Act 1988 2
This case is cited by:

  • Cited – May v Director of Public Prosecutions Admn (Bailii, [2005] EWHC 1280 (Admin))
    Whether the car park where the driving took place was a ‘public place’ within the meaning of section 3.
    Held: ‘In the present case there are no restrictions whatever upon the access of members of the public generally to the inner park during . .

(This list may be incomplete)

Last Update: 03-Sep-16
Ref: 85567

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