Citation – Nguidjol [2015] EWCA Crim 2073

Date – 18th June 2015

Keywords – False passport, s31, Guilty plea

Overview – Appeal allowed on a guilty plea on a false passport case 

Summary – N came to UK on 16th January 2009 with a false passport from Cameroon. The previous year he had claimed asylum in Switzerland, but withdrew this to go home as he was told it was safe to return. This was incorrect, so he left with his family to Nigeria, then France (with the help of an agent) where he stayed for 10 days, before flying to Spain for a 2 day stay, then to the UK. He was intending to go to Canada to claim asylum.

When challenged at the airport, he claimed asylum. His solicitor advised him that the stay in France excluded him from the defence. 

He was granted asylum in July 2010.

The appeal would be allowed in light of the above. 


(1) A straightforward application of the current law on s31.

Judges – Laws LJ, Blair & Holroyde JJ

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