Bowman vs. Fels Court Case Comments

921 Words2 Pages

CASE COMMENTS
Bowman v Fels [2005] EWCA Civ 226, [2005] 1 WLR 3083 It has been stated that “a person commits an offence if he enters into or becomes concerned in an arrangement which he knows or suspects facilitates (by whatever means) the acquisition, retention, use or control of criminal property by or on behalf of another person.” In Bowman v Fels, the courts concluded that this section of the act was not interpreted in a way by which it intended to cover or affect the ordinary conduct of litigation by legal professionals, which was the issue that arose here. The facts of the case are somewhat straightforward. Jennifer Mary Bowman, the claimant, lived with the defendant, William John Fels, over a span of ten years between the period of May 1993 and April 2003. The premise they were residing in was registered in the defendant’s sole name. After the relationship between the claimant and the defendant ended, the claimant asserted a right to a beneficial interest in the said property they had jointly occupied. The claimant held that she rightly had an authority over the house as before it was purchased, the defendant had expressly agreed to share the purchase of the premise with her. This argument was brought before the House after the defendant had gone back on his word, to which legal proceedings started. In preparing for the trial, Bowman’s solicitors had suspicions that Fels had wrongly included certain expenses to be business costs in his accounts as well as VAT returns carried out at the premises. Bowman’s solicitors notified the National Criminal Intelligence Service (NCIS) of this by their assumed obligation under section 328 of the Proceeds of Crime Act 2002, but consequently had to seek to delay the trial as the... ... middle of paper ... ... be caught by this section. The chance that an authorised disclosure would arise by the defence of privilege to a statutory legal profession is quite unlikely. In conclusion, I think that the court was justified in upholding the order of Judge Cowell and dismissing the appeal made. Although there remain some grey areas which the case has not solved, it remained correct in affirming that it should not indeed cover or affect the ordinary conduct of litigation by legal professionals. For the courts to conclude anything otherwise would lead to a plethora of unwelcome criticisms and result in problems that the drafters of the statute would not have anticipated otherwise. In adopting the orders made in this case, I think that it would have affirmed the position of this statute and will be able to act as a point of reference for the other courts in cases to follow.

Open Document