The Court of Appeal has upheld Philip Doyle’s manslaughter conviction and 11-year prison sentence over the death of his partner’s infant son, rejecting all grounds of appeal.
Doyle was convicted after a trial held between 16 April and 15 June 2012. The trial judge withdrew the murder charge from the jury, ruling there was insufficient evidence of the additional intent required for murder. Doyle was convicted of manslaughter and sentenced on 31 July 2012.
The appeal challenged the admission and treatment of medical expert evidence, the trial judge’s directions to the jury, and the refusal to direct an acquittal. The prosecution case was that the baby’s injuries were inflicted and occurred while Doyle was alone caring for him. The defence said the injuries resulted from an accidental fall while Doyle was carrying the child, together with subsequent handling and medical treatment. The Court of Appeal stressed that the prosecution had to disprove that explanation beyond reasonable doubt.
The court found no error in allowing paediatricians to give opinion evidence about whether the injuries were consistent with non-accidental injury. It said the trial judge was not required to give a special warning about medical experts in this case. The jury had to assess the weight of the experts’ evidence alongside the other evidence, and the judge had discretion over the directions needed in the circumstances.
The appeal court also rejected complaints about the judge’s handling of differences in expert testimony, the possibility that some bruising resulted from medical treatment, the evidence about a possible coagulation problem, and the summaries of the defence case and the accused’s explanations for lying. It said the judge had given a fair account of the relevant evidence and adequate directions on the presumption of innocence and reasonable doubt.
The court concluded that the trial was satisfactory and the conviction safe. The appeal therefore failed. The judgment records no change to the sentence, which remained 11 years’ imprisonment.