Court of Appeal (Civil Division).

Potter and Mance LJJ and Sir Martin Nourse.

Judgment delivered 3 July 2001.

Value added tax – Appeal – Penalty – Evasion of tax – Conduct involving dishonesty – Imposition of penalty – Right to fair and public hearing – Applicability of European Convention on Human Rights – VAT civil evasion penalties – Whether penalty involved criminal charge – Value Added Tax Act 1994, s. 60 – European Convention on Human Rights, art. 6(1).

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