The Privy Council handed down judgment in the matter of Greene v Half Moon Bay Hotel (Antigua & Barbuda) [2009] UKPC 23 on 2nd June 2009. The case concerned an appeal by Mr. Greene against a decision of the Eastern Caribbean Court of Appeal. Mr. Greene claimed the Court of Appeal had refused to give reasons for having dismissed his appeal.

Commenting generally and having discussed English v Emery Reimbold & Strickland Ltd (Practice Note) [2002] 1 WLR 2409, the Council stated that succinct oral reasons could suffice in cases where the appeal was clearly hopeless. However, where in cases such as Mr. Greene’s where the appellant is a litigant in person, courts should ensure that the reasons were clearly and concisely explained even if the claim was misguided. Further, the court may consider it beneficial to explain what the requirements for making an appeal from such a decision were to such a litigant. However, as Mr. Greene’s appeal did not contain any arguable issue of law, the appeal was dismissed.