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Murder conviction referred to Court of Appeal following a case which changed the law 

Published:

The Criminal Cases Review Commission (CCRC) has referred a man’s murder conviction to the Court of Appeal because of a new case which has changed the law to suggest that an alternative verdict of manslaughter should be left, in most murder cases, for the jury’s consideration at trial.  

Robert Knapp was convicted on 19 July 2002 at the Central Criminal Court of the murder of Mohammed Raja in July 1999.  

He received a sentence of life imprisonment with a minimum term of 20 years.  

The prosecution’s case was that Mr Knapp had been one of two men who had gone to Mr Raja’s home and committed the murder. 

Mr Knapp’s application for leave to appeal his conviction was refused by the Court of Appeal, in October 2003.  

He applied to the CCRC in February 2020 and following this new case, further submissions were received. 

The issue of whether the alternative verdict of manslaughter should be left to the jury was considered by Mr Knapp’s trial judge and raised on appeal.  

However, the new case law raises a real possibility that the Court of Appeal will consider that manslaughter should have been an available verdict in this case.  

The concern is that if manslaughter is not left as an alternative, a jury may convict someone of murder because they are responsible for a death, when manslaughter might be more appropriate. 

That suggests a real possibility that the Court will find that manslaughter should have been left and since it was not, the conviction of murder is unsafe. 

[ENDS] 

Notes to editors: 

  1. The CCRC is an independent body set up under the Criminal Appeal Act 1995. It is responsible for independently reviewing suspected and alleged miscarriages of criminal justice in England, Wales and Northern Ireland. It is based in Birmingham and is funded by the Ministry of Justice.     
  1. There are currently ten Commissioners who bring to the CCRC considerable experience from a wide variety of backgrounds. Commissioners are appointed by the monarch on the recommendation of the Prime Minister in accordance with the Office for the Commissioner for Public Appointments’ Code of Practice.  
  1. The CCRC usually receives around 1,600 applications for reviews (convictions and/or sentences) each year. Since starting work in 1997, the CCRC has referred around 3% of applications to the appeal courts.     
  1. The CCRC considers whether, as a result of new evidence or argument, there is a real possibility that the conviction would not be upheld were a reference to be made. New evidence or argument is argument or evidence which has not been raised during the trial or on appeal.  Applicants should usually have appealed first. A case can be referred in the absence of new evidence or argument or an earlier appeal only if there are “exceptional circumstances”.          
  1. If a case is referred, it is then for the appeal court to decide whether the conviction is unsafe.       
  1. More details about the role and work of the Criminal Cases Review Commission can be found at www.ccrc.gov.uk. The CCRC can be found on X, Facebook, Instagram (@the_ccrc) and Linkedin.