R v Phipps [2005] EWCA Crim 33 – RTA.
- abuse of process – double jeopardy.
- Connelly extended Elrington principle, that D should not be charged again on same facts in more aggravated form, to “the same or similar facts”.
- save in special or exceptional circumstances, P should not bring second proceedings arising out of “same incident” as first proceedings after first proceedings concluded.
- burden on [P] to identify special or exceptional circumstances.
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