It is the second of these issues, and particularly the decision to bring the criminal test for dishonesty into line with the civil one, which has attracted the most attention. In a much-publicised recent case, the Supreme Court has considered two issues: first, whether it is necessary to prove dishonesty in order to make out an offence of cheating and second, what the test for dishonesty should be. Its 21st century equivalent, the Gambling Act 2005, creates a rather more prosaic offence of 'cheating at gambling'. It is, arguably, still perfectly creditable drafting. The Gaming Act of 1664 imposed a forfeit on anyone who won a wager or prize, if they did so by means of 'fraud, shift, cousenage, circumvention, deceit or unlawful device, or ill practice whatsoever'. Genting Casinos (UK) Ltd t/a Crockfords UKSC 67
When and how dishonesty needs to be shown following Ivey v.
