Joyce v. Director of Public Prosecutions
United Kingdom House of Lords
[1946] A.C. 347 (1946)
- Written by Emily Pokora, JD
Facts
William Joyce (defendant) was born an American citizen. From 1921 to 1939, Joyce resided in England. In 1933, Joyce applied for a British passport for holiday travel, claiming that he was born in Galway and therefore British by birth. In 1945, Joyce was arrested, charged, and found guilty of treason after it was discovered that he was working as a German news radio announcer assisting Britain’s enemy in broadcasting propaganda. Evidence showed that Joyce’s British passport remained valid while Joyce resided in Britain for 24 years. The passport was issued in 1933, valid for five years, then renewed in 1938 and 1939 when Joyce traveled to Germany to work as a broadcaster. Upon Joyce’s arrest, the passport was not able to be located, and no evidence was presented to confirm the timing of the German broadcasts. Joyce appealed the guilty verdict, arguing that his actions were outside the jurisdiction of Britain when committed and that, therefore, he could not be charged with treason.
Rule of Law
Issue
Holding and Reasoning (Jowitt, C.J.)
Concurrence (Wright, Macmillan, J.J.)
Dissent (Porter, J.)
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