As with any meal worthy of repeated eating, this curry proves itself time and time again when left to simmer gently over a period of hours, rather than minutes (which is an excellent rule of thumb when cooking any meats). And while confidently spicy, it avoids falling victim to an overabundance of chillies, relying instead upon the effective blend of spices, minimal preparation and a long cooking time to intensify the final dish. Try it out for yourself, and I guarantee that you’ll love it almost as much as I do.
Ingredients (Serves 4)
400g of Lamb Shoulder Steaks (Diced)
4 Tbsps of Olive or Sunflower Oil
Medium Onion (Finely Chopped)
4 Garlic Cloves (Peeled and Grated)
1” of Fresh Ginger (Peeled and Grated)
400g Tin of Chopped Tomatoes
Tbsp Tomato Purée
Tbsp Garam Masala
Tsp Ground Cumin
0.5 Tsp Ground Turmeric
100ml Natural Yoghurt
Fresh Chilli Pepper (Seeded and Finely Chopped)
25g Pack of Fresh Coriander (Finely Chopped)
How to Cook
1. Heat the oil in anon-stick chef pan (or similar) and then gently fry the chopped onion and garlic, stir-frying until the onions are lightly browned.
2. Add the ginger, ground cumin, turmeric and chopped chili, stir-frying for 1-2 minutes before adding the diced lamb, yoghurt, tomato purée and salt.
3. Mix well, add the chopped tomatoes and water, and gently simmer covered for 1 hour before adding the freshly chopped coriander.
4. Mix everything well, and simmer uncovered for a further 15-20 minutes, while the sauce thickens and reduces, and the lamb becomes soft and tender to the touch.
If you find that you’re not a huge fan of lamb, then this recipe works equally well with diced pork or beef, and is best served with natural yoghurt and steaming plain basmati rice, or even stuffed inside warm buttered chapatis with a topping of Indian salad.
The intention to bequeath when drafting a well organised and thoroughly considered will remains the deciding authority of the testator, and so when perhaps vital elements to that redistribution are left wanting, the power falls to the court to compel the wishes of the deceased in as full a manner as possible, as was found in this potentially convoluted suit.
Having given tremendous thought to the lifetime of his estate, and the unavoidable dilemma of untimely deaths, the deceased had made express stipulations as to the execution of his legacy should his immediateprogeny die, while this caveat was made clear by the words:
“[I]n case my son and daughter should both of them die without leaving lawful issue, then for the said estates to be disposed of as shall be hereinafter mentioned (that is to say), the longest liver of my two children shall have power, by a will, properly attested, in writing, to dispose of all my real and personal estates amongst my nephews and nieces or their children, either all to one of them, or to as many of them as my surviving child shall think proper.”
And so in the sad event that his two children were unable to live long enough to bear children, or oversee the disposition of his estate as he had wished, the matter was presented to the Court of Chancery, so as to establish if when dying, the power to assign to those in vivo was relinquished, or if the estate was to remain in trust for the benefit of those now dead.
After much deliberation, and a reinvestigation of a number of arguable precedents, the court turned to Brown v Higgs, in which it was held that within circumstances where those granted executory powers have passed, the will itself becomes a mere trust, and therefore:
“[T]he trustee having died without executing it, or transgressing it, or refusing to execute it, shall not prevent its being held an absolute benefit for the objects, with a power to give a preference.”
Thus the court held that where a will or codicil is deliberate enough to provide express use of its power, the court is granted proper authority to ensure that its instructions are followed both with judicial impartiality and honest justiciability, therefore the will was enforced and the proper class of beneficiaries shown due privilege, while the court also held that:
“[W]hen there appears a general intention in favour of a class, and a particular intention in favour of individuals of a class to be selected by another person, and the particular intention fails, from that selection not being made, the Court will carry into effect the general intention in favour of the class.”
The importance, if not imperative demonstration of causation lies at the heart of a case in which a jury was led to believe that manslaughter by way of robbery was unquestionably evident, when in fact the circumstances behind the event were such that prevented any reasonable direction, or sustainable conviction thereafter.
In June of 1989, the appellant was driving a vehicle with two passengers when a hitch-hiker attempted to obtain a lift to Glastonbury Festival. Having entered the car, the now deceased was subjected to what was held as a pre-meditated robbery attempt, during which he threw himself from the vehicle at speed, an action that resulted in severe head trauma and his subsequent death.
Upon indictment to the Bristol Crown Court, the appellant and the co-defendants were accused of threatening the victim so as to take all of his money, whereupon he had reluctantly offered to pay a nominal sum to the appellant rather than risk suffering possible violence while travelling inside the car.
Despite a lack of causative evidence aside from the witness testimonies of the three men accused, the presiding judge explained to the jury that:
“[W]hat he was frightened of was robbery, that this [money] was going to be taken from him by force, and the measure of the force can be taken from his reaction to it. The prosecution suggest that if he is prepared to get out of a moving car, then it was a very serious threat involving him in the risk of, as he saw it, serious injury.”
And so when reaching a verdict, the jury held that two of the men were guilty of manslaughter, with the appellant found to have been the one threatening the victim shortly before his death, a decision which was challenged in the Court of Appeal on grounds of misdirection and lack of causation between the actual threat and subsequent death.
Here the court turned to R v Roberts, in which the Court of Appeal had held that:
“[I]f of course the victim does something so “daft,” in the words of the appellant in this case, or so unexpected, not that this particular assailant did not actually foresee it but that no reasonable man could be expected to foresee it, then it is only in a very remote and unreal sense a consequence of his assault, it is really occasioned by a voluntary act on the part of the victim which could not reasonably be foreseen and which breaks the chain of causation between the assault and the harm or injury.”
While in R v Mackie, the court had further held that:
“Where the injuries are fatal, the [escape] attempt must be the natural consequence of an unlawful act and that unlawful act ‘must be such as all sober and reasonable people would inevitably recognise must subject the other person to, at least, the risk of some harm resulting therefrom, albeit not serious harm’….”
A fact that on this occasion, was far from proven, but instead relied upon the urgency of the judge when directing the jury. This translated that the court was unable to sustain the previous verdict of either count, as neither robbery nor manslaughter had been proven beyond any reasonable doubt, therefore the appeal was allowed in full, while the court held that in matters of manslaughter:
“[T]he nature of the threat is of importance in considering both the foreseeability of harm to the victim from the threat and the question whether the deceased’s conduct was proportionate to the threat….”
English history suggests that when faced with litigation, each party must rely upon, and thus retain, the services of a qualified legal advocate, whether by way of barrister, or as is now more common, a practising solicitor equipped with a modicum of experience in the legal field at hand; however in the tail end of the 1960s, the playing field was somewhat levelled by a case involving two former immigrants, both left fighting to dissolve what was clearly a dysfunctional and abusive marriage.
Having arrived in Great Britain from Jamaica in 1956, the now appellant husband had at the point of the original hearing, fathered six children with his respondent wife, who herself had settled with him there in 1957. In 1965, the respondent initiated divorce proceedings on grounds that the appellant had subjected her and their five remaining children to repeated molestation and inhumane treatment throughout the course of their relationship, while the appellant cited his own cruel treatment at the hands of the respondent.
In the first instance, the Lambeth magistrate’s court held that the appellant was to cease his molestation and depart the family home, to which the appellant acquiesced, only for the respondent to later cite further cruelty and adultery, while the appellant also claimed adultery on the part of the respondent, an action which had left her pregnant and requesting a psychiatric referral for a hysterectomy on grounds that she was now depressed and suffering prolonged emotional stress.
While the matter itself became increasingly complex, the appellant was unexpectedly denied his previously administered legal aid, and so when the trial began in 1969, he was found without legal representation. To remedy this obvious dilemma, the previous solicitors assigned a young Australian barrister to escort and attend the numerous court sessions, while occasionally offering notes and verbal guidance as the appellant attempted to argue his position in a matter that the judge himself had later expressed was:
“[Q]uite a difficult case, quite apart from the difficulties of communication which are inevitable because of the rapidity and the sometimes inaudible way in which the evidence was given on both sides….”
However, for reasons best known to himself, the judge soon ordered the young barrister to remove himself from the appellant’s side, on grounds that unless the man’s name appeared on the court records, he was to remain unable to participate in the proceedings in any way, a decision which left the appellant alone and thus unable to fully comprehend what was being said, and how best to assert his own opinions before the court.
Having lost the case, the appellant then challenged the judgement before the Court of Appeal on grounds that the removal of the barrister was in many respects an obstruction of justice, and that by doing so, the judge had erred in his decision, while the appellant also argued that he had been denied his right to present his own claim of adultery against the respondent.
Here, the court turned to Collier v Hicks, in which Tenterden CJ had concisely explained that:
“Any person, whether he be a professional man or not, may attend as a friend of either party, may take notes, may quietly make suggestions, and give advice…”
Thus the court unanimously upheld the appeal and ordered a new trial, while also holding that:
“[L]itigants should be seen to have all available aid in conducting cases in court surroundings, which must of their nature to them seem both difficult and strange.”
A decision that has since altered the landscape of countless court hearings, while granting those daunted at the prospect of judicial scrutiny, and unable to retain a legal representative, the perfect opportunity to bolster their argument and thereby presence by the hand and words of a learned supporter, should they see fit.
Most likely uncertain to many members of the general public, the difference between assault and battery are markedly different, as was established in a case involving a uniformed policewoman and a suspected prostitute, judged to be loitering for the purposes of unlawful solicitation.
In the summer of 1982, the now respondent was driving in her patrol car when herself and her colleague observed what appeared to be two prostitutes standing around in the street whilst conversing with two men for what was determined to be a negotiation of solicitation, upon which the respondent requested that the now appellant enter the car so they could question her, to which the appellant lawfully refused and proceeded to walk away.
It was at this point that the respondent left the vehicle and attempted to question the appellant again while in pursuit, to which the appellant told her unceremoniously to ‘fuck off’, a statement that caused the respondent to physically grab the appellant by the forearm so as to restrain her from walking further, and which in turn resulted in the appellant shouting again ‘just fuck off copper’ and scratching the respondent’s forearm with her fingernails; an action that led to the appellant’s arrest and subsequent charge of assaulting a police officer in the line of duty.
Having contended the offence before the then Metropolitan Stipendiary Magistrate presiding in the Marylebone office, London, the appellant argued that the respondent was at the time of her physical exertion, acting beyond the scope of her police powers, while the respondent countered that she had acted lawfully under the Street Offences Act 1959, in which s. 1(1) which read that:
“It shall be an offence for a common prostitute to loiter or solicit in a street or public place for the purpose of prostitution.”
And s. 3, which further reads that:
“A constable may arrest without warrant anyone he finds in a street or public place and suspects, with reasonable cause, to be committing an offence under this section.”
To which the magistrate held the appellant guilty of the offence of assault, and fined her £50 under s. 51(1) of the Police Act 1964 while holding that:
“[I]n the circumstances the placing of her hand on [the defendant’s] arm to restrain her from moving away, yet again, was within her duty and was not unreasonable.”
A decision which the appellant challenged in the High Court, holding as before that the respondent had acted unlawfully when attempting to deny the appellant her freedom to leave when questioned.
Here, the court first looked to Cole v Turner, in which the Court of the Kings Bench had held that:
“The least touching of another is battery.”
Which was a principle later expanded upon in William Blackstone’s ‘Commentaries on the Laws of England’ (1830), in which it was stated clearly that:
“[T]he law cannot draw the line between different degrees of violence, and therefore totally prohibits the first and lowest stage of it; every man’s person being scared, and no other having a right to meddle with it, in any the slightest manner.”
And so noting that assault is an act that causes another person to ‘apprehend the infliction of immediate unlawful force’ upon them, battery requires the ‘actual infliction of unlawful force’, and so on this occasion the court held that when attempting to restrain the appellant, the respondent had acted outside her official powers when there had in that instance, been no grounds for any arrest, but instead the subjective compulsion to prevent the appellant from exercising her civil rights through the use of battery, thus the appeal was upheld, while the court held that:
“[E]verybody is protected not only against physical injury but against any form of physical molestation”
“[R]easonable force may be used in self-defence or for the prevention of crime.”
Another Thai classic, this is a wonderfully pungent and yet feisty dish that is so simple to make, and yet never fails to impress with those who love their curries with less heat and more sweetness.
Ingredients (Serves 4)
5-6 Tbsps of Vegetable or Sunflower Oil
3-4 Chicken Breasts (Diced)
2-3 Shallots (Finely Sliced)
4 Tbsps Yellow Curry Paste
Tsp Curry Powder
400ml Tin of Coconut Milk
3 Tsps Fish Sauce
Tsp Tamarind Paste
Tsp Brown Sugar
How to Cook
Heat half of the oil in a non-stick chef pan (or similar), add the chopped shallots and gently fry them until they are crisp and golden, after which you can remove the shallots with a slotted spoon and set them aside on one or two paper towels.
Pour half of the coconut milk into the pan, along with the curry paste and remaining oil, and simmer on a low heat while stirring.
Add the diced chicken, fish sauce tamarind paste, sugar and the water, beforesimmering while stirring continuously for 2-3 minutes.
Add the remaining coconut milk, cover and simmer for a further 30-45 minutes before serving with the crispy shallots on top of the chicken and sauce.
As with any Thai curry, this is best served with a plain basmati rice, and it goes very well with a crisp, cold beer to offset against the sweet and delicious sauce (which tastes even better when you combine it with the warm fluffy rice). Simply gorgeous.
The staple meal in any Italian household, only made to our particular tastes, this is a dinner that is well worth the wait, and I would recommend you wear some kind of napkins or kitchen paper over your clothes to avoid any mess. There is no doubt that this is a lip-smacking dinner which wins with children and adults alike, and any leftovers (and there rarely is) can be easily frozen for later use.
Ingredients (Serves 4)
Large Slug of Olive Oil
2 400g Packs of Beef Meatballs
240-300g Pack of Bacon
Medium Onion (Finely Chopped
2 Garlic cloves (Peeled and Grated)
Beef Stock Cube
2 Tsps Tomato Purée
2 Sun-Dried Tomatoes (Finely Chopped)
500g Tomato Passata
3 Whole Tomatoes (Quartered)
Tsp Dried Oregano
Tsp Dried Basil
Tsp Dried Parsley
2 Bay Leaves
Small 187ml Bottle Red Wine
25g Pack Fresh Basil (Finely Chopped)
Tsp Salt and Freshly Ground Pepper
How to Cook
Finely dice the bacon after removing any unwanted fat and then after heating the oil in a non-stick chef pan (or similar), gently fry the onions and garlic until soft and slightly brown.
Add both the meatballs and bacon and brown both meats slowly on a gently heat, stirring occasionally.
Add the oregano, basil, parsley, beef stock cube, salt and pepper, sound-dried tomatoes, tomato purée and sun-dried tomatoes and bay leaves then stir-fry for 1-2 minutes.
Pour in the red wine and tomato passata, stir well and simmer for 3-4 minutesbefore adding the quartered tomatoes, covering the pan and simmering gently for 1 to 1.5 hours, stirring occasionally to prevent sticking.
Just before serving, add the chopped basil and mix well.
It goes without saying that meatballs are best served with spaghetti or linguini, however you can also use penne or fusilli if preferred. In fact, most shaped pastas work equally well, while remembering to grate plenty of freshly grated parmesan or romano (pecorino) cheese over the top (as long as your diners are in agreement) along with extra salt and pepper where required.