Question juridique clé
Whether the civil judgment of 9 May 2001 was a new and relevant fact justifying revision of the maintenance-neglect convictions.
Solution extraite
The civil judgment was not legally relevant for revising the criminal judgments, because the criminal courts had to rely on the civil order in force at the time; the new fact would not have led to a substantially more favorable result.
Motifs extraits
Under Art. 397 CP, revision requires a new fact or evidence that could have changed the original criminal judgment. The later civil ruling did not alter the binding effect of the divorce judgment while it remained in force, and the appellant had stopped paying before seeking civil relief.