| 
R (Bhoti) v Home Secretary | 
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| Issue:  | 
Whether the criminal standard of proof applied to factors relevant to penalty as well as the substantive charges in disciplinary proceedings under the Police (Discipline) Regulations 1985 | 
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| Court:  | 
Court of Appeal | 
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| Reference:    | 
C2001/0531 | 
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| Neutral Citation:    | 
[2001] EWCA Civ 2016 | 
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| Judge(s):  | 
Schiemann and Clarke LJJ and Wall J | 
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| Date:  | 
20 December 2001 |