According to the Full Code Test, the four factors that were relevant to the public interest in the case of Sally Challen are as follows:
1. Seriosity of the Offence: Sally was found culpable in the murder of her abusive husband, Richard Sally. The murder shows a commitment of serious harm to Richard's life and endangered public safety if it remained unchecked. Sometimes, the abused becomes the abuser.
2. Culpability Level: Sally was adjudged culpable in the murder of Richard, having been directly involved in the act. She premeditated and planned the murder. But there was no history of any previous convictions in her case.
3. Circumstance and Harm: The circumstance in which Sally killed her husband was not considered in her conviction. Sally had suffered unabated abuses in the hands of her husband for many decades. According to her, the husband made her behave abnormally.
4. Societal Impact: The murder was bound to influence other women to give similar treatments to their abusive husbands if not checked by the court conviction. In the same way, the overturning of her earlier conviction from murder to manslaughter influenced victims of abusive husbands to seek redress. Every unlawful use of force against a person attracts public interest.
Interestingly, Sally Challen's conviction for murder was eventually commuted to manslaughter after her appeal, which determined that Richard Challen must have subjected Sally to coercive control.
According to Professor Evan Stark, coercive control involves the erosion of a person's self-esteem through constant humiliation, intimidation, punishment, and other abusive assertions of power. The aim of coercive control is to isolate the victim and make dependent on the perpetrator. A victim of coercive control is often deprived of basic needs while their daily routine is subject to total control.
Thus, according to the Full Code Test, after passing the evidential stage, prosecutors must subject the case to the public interest stage before determining whether or not to proceed with the prosecution.
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