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R. v Paris (Anthony)

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Sweet & Maxwell is part of Thomson Reuters. © 2012 Thomson Reuters
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Positive or Neutral Judicial Treatment

R. v Paris (Anthony)
R. v Abdullahi (Yusuf)
R. v Miller (Stephen Wayne)
Court of Appeal (Criminal Division)
16 December 1992

Case Analysis
Where Reported

(1993) 97 Cr. App. R. 99; [1994] Crim. L.R. 361; Times, December
24, 1992; Independent, December 17, 1992

Case Digest

Subject: Criminal evidence
Keywords: Admissibility; Confessions; Police interviews
Summary: Confession; oppression; whether obtained by oppression; whether admissible
Abstract: It is oppressive for interviewing officers to shout, bully and hector the suspect in interview. An interview obtained in oppressive circumstances is unreliable and not admissible. M was charged, with four others, with the murder of a prostitute. The main evidence against M was his confession evidence which was ruled admissible at trial. M, and two other defendants implicated by M 's confession, were later convicted of murder. All three appealed on the ground that the confession had been obtained in oppressive circumstances which rendered it unreliable and therefore inadmissible under the
Police and Criminal Evidence Act 1984 s.76(2) .
Held, allowing the appeals, that the tenor and length of the interviews was oppressive for someone of normal mental capacity and M had been adjudged to be on the borderline of mental handicap. The interviewing officers could not have acted in a more hostile and intimidating manner. Interviewing for 13 hours over 19 tapes, they had made it clear to M that they would continue to question him



Cited: L.S.G. 2009, 106(15), 6 Police and Criminal Evidence Act 1984, s.76 - admissibility of Crim. L.R. 1994, May, 361-363 Confession obtained by oppression. J. Crim. L. 1994, 58(1), 39-40 Books

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