On Thursday 23 July 2026 the Caribbean Court of Justice heard the matter of a criminal appeal originating from Guyana (Wazir Ali v DPP). No5’s Philip Rule KC, leading Mikhail Charles, appeared as an amicus curiae to the Court, which sits in Port of Spain, in the Republic of Trinidad and Tobago.
The hearing was presided over by the seven-strong full Court (The Hon. President Mr Justice Anderson, Mme Justice Rajnauth-Lee, Mr Justice Barrow, Mr Justice Jamadar, Mme Justice Ononaiwu, Mr Justice Eboe-Osuji and Mr Justice Bulkan).
The Court invited the assistance of amici curiae on the question of the effectiveness of the various developments to the doctrine of recent complaint seen in the common law across the many Commonwealth jurisdictions. Of particular interest to the Court at the hearing were criteria of admissibility as to timing of a complaint, the proper use to which the evidence should go, whether as hearsay exception or more limited consistency, and the judicial directions required.
The Court is the apex court for appeals from the nations of Barbados, Belize, Dominica, Guyana, and St. Lucia. The CCJ also serves as an international tribunal with an original jurisdiction interpreting the Revised Treaty of Chaguaramas for all CARICOM member states.
Philip Rule KC is a King’s Counsel of the English Bar and an attorney of the Saint Vincent and the Grenadines Bar, as well as having appeared and acted in matters in the Cayman Islands, Turks and Caicos Islands, and British Indian Ocean Territory, amongst others. He provides expert advice and representation on appeals in public law, criminal, extradition, and civil matters.
Mikhail Charles is counsel at 5 Pump Court, and at Baptiste & Co. Law Firm Inc., Kingstown, Saint Vincent and the Grenadines. He practises in criminal appeals, financial crime and proceeds of crime, and cross-border commercial, chancery and trusts disputes, and is admitted in England and Wales and most Commonwealth Caribbean jurisdictions.
