CRIMINAL LAW ; ;Legal advisers deficiencies in conduct of trial not flagrant incompetence or breach of right to fair trial ;R v Nangle: CA (Roch LJ, Turner and Pitchford JJ): 1 November 2000 ;The appellant was convicted of robbery. He appealed against conviction, relying principally on the claimed incompetence of his legal advisers at trial, alleging in particular that: (i) there had been a failure to serve an alibi notice; (ii) it had not been ensured that certain witnesses gave their evidence live at court; and (iii) the issue, of whether the jury might be permitted to draw an adverse inference in light of the appellants no comment interview, had been handled incompetently. The hearing of another ground of appeal was adjourned. ;Stephen Batten QC and Campaspe Lloyd-Jacob (assigned by the Registrar of Criminal Appeals) for the appellant. Derwin Hope (instructed by the Crown Prosecution Service, Wiltshire) for the Crown. ;Held, that the relevant deficiencies did not approach, let alone amount to, flagrant incompetence, which might also no longer be the appropriate measure of whether the court would quash a conviction; that since article 6 of the European Convention on Human Rights, scheduled to the Human Rights Act 1998, required the hearing of the charges to be fair, the court might be compelled to intervene if the conduct of legal advisers was such that that objective was not met; but that was not the case here and it was unnecessary to consider what level of incompetence would have to exist before the court could be satisfied that there had been a relevant breach of the provisions of article 6(1). ; ; ;