R v Firth

(1990) 1 Med LR 411

COURT OF APPEAL

Lord Lane LCJ, Mr Justice ROSE, and Mr Justice MORLAND

Criminal law — Evasion of liability by deception — Consultant gynaecologist — Alleged evasion of liability to National Health Service in respect of private patients — Consultant's failure to inform hospital of patients” private status in respect of antenatal and hospital treatment — Whether consultant correctly found guilty of evasion of liability by deception where acts were of omission not commission — Whether offence could be committed in respect of a future liability