*R (on the application of AR) v Chief Constable of Greater Manchester Police and another

Police – Disclosure of information. The lower courts had correctly held that the information contained in an Enhanced Criminal Record Certificate (ECRC) issued in respect of the appellant (AR) under s 113B of the Police Act 1997, which had included details of a criminal charge, for which AR had been tried and acquitted, had not breached his rights under art 8 of the European Convention on Human Rights. The Supreme Court ruled, among other things, that the admitted interference with AR's private life, involved in the disclosure, had been justified. The court further held that it was not necessary or appropriate, as a matter of domestic law or under art 8, for those responsible for an ECRC to conduct a detailed analysis of the evidence at the trial. Consideration was also given to the proper role of the appellate courts in reviewing a judge's finding of proportionality under the Convention.

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