The Court of Criminal Appeal lacks jurisdiction under s 2(h) of the Criminal Appeal Act 1912 to hear an appeal from a refusal to award costs in the summary jurisdiction of the Land and Environment Court, because 'any order for the payment of' costs does not encompass a refusal to make such an order. A s 10 dismissal without conviction remains a permissible sentencing option for strict liability environmental offences where the accused could not, as a practical matter, have done anything to avert the event, even though such orders will rarely be appropriate for offences of this character.
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