CriminalRobbery - judge failing to direct jury as to dishonesty - conviction not automatically unsafe despite breach of convention right R v Williams: CA (Lord Justice Dyson, Mr Justice Sachs and Mr Justice Stanley Burnton): 14 March 2001 The defendant was convicted of robbery.

He appealed against conviction on the ground that, since the judge had failed to direct the jury as to dishonesty, he had not been proved guilty 'according to law' for the purposes of article 6(2) of the European Convention on Human Rights, given effect by the Human Rights Act 1998, and so his conviction must automatically be unsafe.

David Kelly (assigned by the Registrar of Criminal Appeals) for the defendant.

Gerald Hendron (instructed by the Crown Prosecution Service, Bradford) for the prosecution.Held, dismissing the appeal, that a failure to give a direction did not render a conviction automatically unsafe; that 'safety' had a broad meaning and, even though there had been a breach of article 6(2), the court should ask itself whether, if there had been an appropriate direction, the jury might have acquitted the defendant; and that the answer to that question was in the negative.