In R v Boal, the Criminal Division of the Court of Appeal has overturned the conviction of an assistant manager of a bookshop for offences of breaching fire safety legislation. In considering the extent of criminal liability imposed on "managers" and other similar officers by s.23 of the Fire Precautions Act 1971, the Court of Appeal ruled that since the appellant did not have overall managerial control of the company for which he worked, he did not fall within the scope of s.23.
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