R v Fellows; R v Arnold

The first appellant, Alban Fellows, had stored digital images on his employer's computer that enabled users to both display and print indecent pictures of children.

The extensive digital library, viewable on the Internet, encompassed numerous explicit images of children and was called The Archive.

[8] The current definition now includes data stored on a computer disc, or by other electronic means, which is then capable of being converted into a photograph (section 84 (3) (b)).

[9] The amended Act also introduced the idea of a “pseudo-photograph”, which describes an image created by computer graphic software that can closely resemble a photograph (section 84 (3) (c)).

The Court addressed this concern in the third aforementioned issue, by pointing out the possibility that when statutes are written by Parliament it is only based on what is currently known at that time.

This case also displays the wide scope of digital evidence and its application to traditional criminal offences.