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BASSETERRE, ST. KITTS — The Eastern Caribbean Supreme Court has dismissed a constitutional and judicial review claim brought by prison officer Jonard Ramplin, who sought to stop Acting Senior Magistrate Her Honour Yasmine Clarke from presiding over the continuation of his drug case. However, in a significant rebuke, the High Court found that the defendants failed to fully satisfy their duty of candour to the court.

The judgment, delivered by Justice Tamara Gill on June 12, 2026, arose from Ramplin’s attempt to obtain an order prohibiting the Acting Senior Magistrate from proceeding with what the parties described as a retrial on charges of possession of cannabis and possession of cannabis for the purpose of supply. Ramplin, a prison officer employed at His Majesty’s Prisons since 2016, was arrested and charged on October 4, 2022.

According to the judgment, Ramplin’s trial originally began before Magistrate Fitzroy Eddy on September 11, 2023. Prosecution witnesses were examined and exhibits were tendered, but the matter was adjourned and never completed. Magistrate Eddy later demitted office, leaving the case unresolved.

Ramplin was later informed that the matter would proceed before Acting Senior Magistrate Clarke. His claim centered on whether the Magistrate had allegedly ruled that he was not entitled to a transcript of the earlier proceedings before Magistrate Eddy. Ramplin argued that such a ruling, if made, would undermine due process and his constitutional right to the protection of the law.

The High Court accepted that access to a transcript is an important safeguard for fairness where a matter must begin again before a new judicial officer. Justice Gill noted that if the Acting Senior Magistrate had ruled that Ramplin was not entitled to a transcript, such a ruling would have been unlawful.

However, the court found that the evidence was unclear as to whether such a ruling had actually been made. Justice Gill said there remained “genuine uncertainty” on that point and emphasized that the claimant had the burden of proving the factual basis of his challenge.

In a pointed finding, the court ruled that the defendants — the Acting Senior Magistrate and the Attorney General — had breached the duty of candour because their evidence did not clearly explain what happened in court on the critical date. The court was especially concerned that the affidavit evidence failed to clearly state what position, if any, the Magistrate had taken on the transcript issue.

Despite that breach, the High Court declined to grant Ramplin the relief he sought. Justice Gill found that the transcript of Magistrate Eddy’s notes had since been located, prepared and provided to Ramplin’s counsel in March 2025. The court held that this substantially reduced the practical prejudice originally alleged.

The court also found that Ramplin had not first applied to the Acting Senior Magistrate for recusal, which Justice Gill described as the ordinary and adequate remedy where a litigant believes a judicial officer should not continue presiding over a matter. The court held that granting prohibition without first pursuing recusal would be premature and disproportionate.

Ramplin had also initially sought a declaration that the mandatory minimum sentence attached to the drug supply charge was unconstitutional and could amount to inhuman treatment. That issue fell away after it was accepted that the relevant mandatory minimum provision had already been struck down in earlier litigation.

In the end, the High Court refused all three forms of relief sought by Ramplin: the order prohibiting Magistrate Clarke from proceeding, the declaration concerning the mandatory minimum sentence, and the declaration that a retrial before the Acting Senior Magistrate would likely breach section 10 of the Constitution.

Justice Gill made no order as to costs.

The ruling represents a mixed but consequential outcome: Ramplin’s bid to halt the proceedings before the Acting Senior Magistrate failed, but the State received a clear judicial warning that public authorities in judicial review proceedings must place full, clear and accurate information before the court.

The case now leaves Ramplin free to pursue a recusal application before the Magistrate, while the criminal proceedings remain alive.