Scottish Criminal Procedure and Evidence Law

The provided document is an academic work that delves into various aspects of Scottish criminal procedure and evidence law. It includes references to notable cases such as Fox v HMA 1998 S.L.T. 335, Lockwood v Walker [1937] 127 Fla 20, and McTear v Imperial Tobacco Ltd No 1 [2005] CSOH 69. The work also touches upon the 1971 Misuse of Drugs Act and its classification of cannabis. Furthermore, it discusses the importance of process values in reforming Scottish criminal procedure. The document is likely part of a larger academic project or research paper that explores the complexities of Scottish criminal law and procedure.

Running head: EVIDENCE LAW
Evidence Case Assignment
Name of the Student
Name of the University
Author Note

1EVIDENCE LAW
Memo: 2nd April 2018
From: ABC, Junior Advocate Depute
Respected Sir/Madam,
I am hereby appointed as a Junior Advocate to deal with the case of Tony Arnott and Peter
Dunn. Both of them are charged under certain provisions laid down under Criminal procedure
(Scotland) Act 1955. It is my duty to write down the facts of the case so that it may be
understood that whether the duo can be proceed in the High Court with the provisions alleged
against them.
i. In this current case, the Criminal Procedure Act 1955 has empowered the accused party
to submit defense statement within the specific period of 14 days and this date is
calculated before the preliminary hearing of the case. This provision is laid down under
section 70A of the Criminal procedure (Scotland) Act 19551. It has also been stated by
the provision that the accused may place any changes, whatever he wants to do within
seven days before the commencement of hearing.
ii. There are certain particulars that the defense party must include in their statement. These
particulars can be categorized as nature of the defense and those facts that the accused
person disagrees with the plea made by the prosecution. The defense statement must also
required to include those provisions that can make his ground strong and all the other
information that the defense party wants to disclose through the prosecution2. The
1 'Criminal Procedure (Scotland) Act 1995' (Legislation.gov.uk, 2018)
<https://www.legislation.gov.uk/id/ukpga/1995/46> accessed 2 April 2018.
2 Semmler, Carolyn, and Jessica Hurst. "The Impact of State and Trait Anger on Processing of Evidential
Inconsistencies." Psychiatry, Psychology and Law 24.4 (2017): 594-604.

2EVIDENCE LAW
defense party is required to mention the ground and reason of his trust on those
documents. He also has to clarify the grounds and nature of the information before the
court.
iii. Two types of productions are present that assist the defense party to present their prayer
before the court. These productions are named as labeled production and documentary
production. There are certain differences present in between them. Documentary
productions are more reliable compared to the labeled production. An expert report or
any reliable books can be considered as the documentary evidence3. On the other hand,
labeled production assists to identify the witnesses at the trial section. Labeled production
is a form of articles that are required to be labeled. The labels are attached to the articles
by the police officers or by other investigating officers and the seals attached there are
required to be broken before open or produce the articles before court4.
iv. The documentary productions can be categorized as interview memo, statements of the
witnesses of this case such as the statements of Sandra Mitchell, DC Bell, DC Vernon,
Alfred Fredericks, James Horsburgh and Rosa Inness. Apart from the witness statement,
there are two expert reports from the department of packaging and design and the
forensic authority submits the other.
v. The labeled production includes keys of the locker, an adhesive tape, interview recording
tapes, a brown parcel ceased by the investigating officers to this effect and certain
membership cards.
3 Ogilvie, Astrid EJ. "Documentary Evidence of Changes in Climate and Sea-Ice Incidence in Iceland During the
Last Millennium." Polar Climate and Environmental Change in the Last Millennium, Nicolaus Copernicus
University, Torún, Poland, 24-27 August 2015. 2015.
4 Bäckström, Ylva, et al. "Integrating isotopes and documentary evidence: dietary patterns in a late medieval and
early modern mining community, Sweden." Archaeological and anthropological sciences (2017): 1-20.

3EVIDENCE LAW
vi. It is to be considered that the statement made by the witnesses are falls under the
definition of hearsay evidence and therefore it is required to be examine whether the
statements are considered under the category of exception or they will be less competent
to be produced regarding the case.
vii. After the production of those documents, certain issues can be cropped up that will help
the court to understand the admissibility of those attached documents. The issues can be
categorized as follows:
 Whether the statement of the witnesses are laid down under the inadmissible
ground of hearsay evidence or not;
 Whether the statement will fall under the category of exception to the rule of
hearsay evidence or not;
 Whether the audio recording that are produced as an evidence is admissible or
not;
viii. Hearsay evidence is those statements that collected from the outside of the court and
produced before the court to act as evidence to support or goes against the plea of either
the prosecution or the defense parties. However, in general meaning, hearsay evidence is
not evidence though there are certain exceptions to this rule5. These evidences are
testifying both the oral as well as the documentary statements.
ix. Under the Criminal Procedure (Scotland) Act 1955, there are certain exceptions to this
rule of hearsay evidence. All these rules are engraved under the section of 259 of the Act.
It has been stated by the rules that in case of any of the following, the evidences will be
5 Ross, Margaret L., et al. Walker and walker: The law of evidence in Scotland. Bloomsbury Publishing, 2015.

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treated as admissible6. According to the Act, if any statement has been derived from any
person who has been died before the execution of trial proceeding, any statement that has
been made before the accused person and statement regarding the identification of the
accused person. Under the Criminal Procedure (Scotland) Act 1955, res gastie has been
treated as an example of hearsay evidence7. According to this rule, any words that are
included under the part of the physical act or anything that reflects the state of mind of
anyone should be treated as admissible though the nature of the those statements are
hearsay.
x. It has been stated under the provision of section 259 of the Act that the court has the
discretion to allow the admissibility of hearsay evidence after considering certain
grounds8. The presiding officer of the court can consider oral statement of any competent
witness, evidence that has been derived from any documents that is important to the case
or any statement made by the expert as admissible9.
xi. The admissible ground of the hearsay evidence is a matter of conflict. An interpretation
of section 259 reveals the fact that a prior approval is required to precede with the
statements made by co-accused of a case. However, the same rule has been quashed in
the historic case of Brand v HMA [2011] and the court in that case was pleased to
6 Campbell, Liz. "Organised Crime and the Criminal Justice and Licensing (Scotland) Act 2010." Edinburgh Law
Review 18.2 (2014): 225-244.
7 Pandey, D. C. "020_Principles of Evidence." (2015).
8 Thanawalla, Hanishi K. "022_Development and Liberisation of Hearsay Doctrine." (2015).
9 Spencer, John R. Hearsay evidence in criminal proceedings. Bloomsbury Publishing, 2014.

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observe that statement made by the co-accused can be treated as admissible by court and
that will fall under the provision of section 259 of the Act10.
xii. Certain rules are stated under the Evidence law of Scotland for the presiding officer of a
court. The presiding officer could not refuse any statement that made under section 259
of the Act11. In this case, he could not exercise his discretionary power. The judge may
disallow evidence in case the outcome of the admissibility will deny the principle of
justice.
xiii. The nature of the evidence that has been provided under the Act will be divided into three
parts such as real evidence, documentary evidence and oral evidence. According to this
Act, the term real evidence denotes physical evidence that is tangible in nature12. By
documentary evidence, the Act has provided the example of testimony of the expert or
any kinds of documents or report that are relevant to the fact of the case13. Oral evidence
means the statement of the eyewitnesses of the matter and the statements that come under
the exceptions to the hearsay evidence14.
xiv. Certain restrictions are provided under the Law regarding the testimonies given by the
witnesses of a case. If the testimony of a witness may lead to false statement, he will be
charged under the provision of perjury. Further, no one can create pressure to make other
liable for a criminal offence. No one is allowed to make contempt of court.
10 HCJAC 74.
11 Ferguson, Pamela R. "Reforming Scottish Criminal Procedure: In Search of Process Values." Bergen Journal of
Criminal Law & Criminal Justice 4.2 (2017): 167-195.
12 Shiels, Robert S. "The Scottish Criminal Trial and Judicial Intervention in a Public Controversy." (2016).
13 Kjeldsen, T. R., et al. "Documentary evidence of past floods in Europe and their utility in flood frequency
estimation." Journal of Hydrology 517 (2014): 963-973.
14 Campbell, Liz. "Organised Crime and the Criminal Justice and Licensing (Scotland) Act 2010." Edinburgh Law
Review 18.2 (2014): 225-244.

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xv. The rules regarding the competency of witness has been changed after the abolishment of
the Act of Vulnerable Witness of Scotland in 200415. Ample of power has been given to
the jury and the presiding officer of the court to determine the fact whether the statement
of the witness can be treated as admissible or not.
xvi. Certain rules are prescribed to hold the evidences made by the experts as admissible and
according to the Criminal Procedure (Scotland) Act 1955; the forensic experts are
allowed to give their testimony only if required by the court to that effect. Further, the
evidence or examinations taken by the experts should be based on the organized science
and the evidences must be reliable in nature. In McTear v Imperial Tobacco Ltd No16,
the court has found that in case of a legal proceeding, the statement of an expert will be
admissible if the base point of the evidence is outside the knowledge of normal person
and it becomes necessary to derive the evidence from the experts.
xvii. It has been provided in the case of Allison v London Underground Ltd [2008] EWCA
CIV 71 that the experts are allowed to convey their abilities regarding those matters that
are included under their authorities. They, at any cases, are not allowed to submit any
statements that are exclusively within the authority of the court. Under the Act of
Scotland, the experts are not possessing any special categories. They are treated as a
general person who is making their submission on asking either by parties or by the court.
xviii. Under the Act, the reliability of evidence is based on two facts such as evidence that is
based on material facts that has been known as facta probanda and facts that are reliable
15 Hoyano, Laura. "Reforming the adversarial trial for vulnerable witnesses and defendants." Criminal Law
Review 2 (2015): 107-129.
16 1 [2005] CSOH 69

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but not based on material facts17. These facts are known as facta probantia. Facta
probbantia is established through corroborated evidence. Evidences, which reflect the
nature of the direct evidence is a part of the corroborated evidence. They hold an
important place under the Scottish Criminal Law.
xix. After the production of evidence both under the nature of facta probanda and facta
probbantia, the court will discuss the admissibility of the evidence and in such cases, the
court will establish the critical issues in this regard and it will determine the sufficiency
of the facts18.
xx. In the case of Smith v Lees19, it has been held by the court that the corroboration of the
facts must be depended on the crucial facts. Crucial facts are defined as facta probanda
under the legal maxim. The corroborated evidence supports the direct evidences and the
principle has been laid down under the case of Fox v HMA20. It has also been observed
under Lockwood v Walker21; the court will not be able to consider the relevancy of
evidence until the same is based on the crucial facts as a whole. An important note has
been made in the case of Meredith v Lees22. It has been found in the case that the
statements that are confessed by the accused must be based on critical facts and in the
absence of this, the conviction could not be pronounced.
xxi. The defense parties may take the plea under the provision of “no case to answer”. It is a
well-known provision of the British Criminal law where the defense can take the plea of
17 Woolf, Howard Shane. The doctrine of unconscionability as an independent exception to the doctrine of
independence in documentary credit practice. Diss. University of Johannesburg, 2014.
18 Naidoo, Kamban, and M. G. Karels. "Prosecuting." Journal for Juridical Science 41.1 (2016): 65-82.
19 1997 SCCR 139
20 1998 S.L.T. 335
21 [1937] 127 Fla 20
22 [1992] JC 127A

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acquittal without submitting any defense. This principle has been established in Lipkin
Gorman v Karpnale Ltd23. In case the evidences that are produced against the accused
are tenuous in nature or the facts of the case are opaque in nature, the court may acquit
the accused under this plea. However, the prosecution is allowed to make an objection to
this effect under section 107A of the Criminal Procedure (Scotland) Act 195524.
xxii. Besides the provision of “no case to answer”, the accused can take several other steps to
avoid the court proceedings. The steps include the process of plea-bargaining, where the
defense party can confess the crime with an intention to reduce his penalties25.
xxiii. Considering the facts of the case, it can be stated that the locker where the accused person
has kept the drug should be enlisted under the primary evidence. Therefore, the
statements made by Rosa Inness should be regarded as important evidence, as she kept
the keys of the locker. It has further been observed that she had identify all the accused,
as lender of the locker. According to her testimony, it can be stated that both the persons
were came to her and kept the brown envelop in the locker from where the alleged drugs
has been found. She also stated that Tony Arnott and Tony Evans is the same person.
Considering the position of Rosa, her statements should be treated as important and
reliable, as she was in the charge of the locker.
23 [1987] 1 WLR 987
24 'Criminal Procedure (Scotland) Act 1995' (Legislation.gov.uk, 2018)
<https://www.legislation.gov.uk/id/ukpga/1995/46> accessed 2 April 2018
25 Hoyano, Laura. "Reforming the adversarial trial for vulnerable witnesses and defendants." Criminal Law
Review 2 (2015): 107-129.

9EVIDENCE LAW
xxiv. In this case, the alleged locker has been labeled as “A1”. The main key of the locker was
kept with Rosa. The defense counsel that Rosa has certain ocular problem has stated it.
According to their submission, Rosa had not wear any eye gear at that point of time and
therefore, her statement could not be reliable in nature. Further, according to her
description, the person who came to her that day was tall and handsome and on that basis,
she had identified the accused. The defense counsel that if the statement of Rosa can be
taken, the accused can be anyone who is tall and handsome and there is no strong
evidence that the accused were present at that time has considered it.
xxv. However, according to the identification system26 of the case, it can be stated that Rosa
was quite sure about the physic of the accused and she had identified the accused in spite
of wearing any eye gear. Therefore, it can be stated that the statement made by Rosa is
admissible as she is one of the primary eyewitness in this case.
xxvi. While nurturing with the oral statement made by Bell, the Detective Constable of the
case, it can be considered that he was quite familiar with the accused and he has previous
knowledge that they are engaged with drug peddling. Therefore, there are certain grounds
by which it can be proved that the statement made by DC Bell is admissible.
xxvii. Under the Criminal Act, the defense prosecution is required to prove the good character
of the accused and in this case, it has been observed that the accused has certain previous
criminal history and therefore, they had failed to meet the requirement mentioned under
section 270 of the Criminal Procedure (Scotland) Act 199527.
26 Valentine, Tim, and Josh P. Davis. "Forensic facial identification." Forensic facial identification: theory and
practice of identification from eyewitnesses, composites and CCTV (2015): 323-347
27 Monaghan, Mark. "Drug Policy Governance in the UK: Lessons from changes to and debates concerning the
classification of cannabis under the 1971 Misuse of Drugs Act." International Journal of Drug Policy 25.5 (2014):
1025-1030.

10EVIDENCE LAW
xxviii.It has also been observed that both the accused has certain previous history and both of
them were charged before. According to the police report, Tony Arnott was a pimp who
trafficked the teenager girls to the strip club and Peter Dunn was nabbed under the
provisions of the Misuse of Drugs Act before. The police officials had supported these
facts too and this made the validity of the statement made by DC Bell more prominent.
xxix. There are certain possible grounds of questions made by the defense counsel regarding
the admissibility of statement recorded during the interrogation room at the police station.
One of the very common question that can be made by the defense counsel that the
accused had confessed their guilt or stated certain adverse statement due to nervousness
or due to pressure. However, under the law of Scotland, it can be stated that the statement
made before the police official will be held as admissible evidence. This statement has
been established by section 261ZA of the Criminal Procedure (Scotland) Act 1995.
xxx. Certain hindrance has been made during the statement given by James Horsburgh. After
completing certain research about James, it has been come to my knowledge that James
was previously known to accused (Peter Dunn) and he had certain previous criminal
history too. Further, he was not physically present at the time when the police was chased
Peter. Additionally, he is unaware of the facts that Peter is peddling drug and he has also
no knowledge regarding the alleged brown packet. It can be assumed that the statement
made by him has been tampered and therefore, the prosecution could be impeding if his
statements were admitted by the court.
xxxi. From the list of prosecution, it can be understood that Sandra Mitchell is manager of
Terant’s Bar and all her statements were based on the fact she had heard at the bar.

11EVIDENCE LAW
According to her, she was not quite sure that Tony is the real culprit or not. She is also
not sure that the keys of the locker were within the custody of Tony or not. It has further
been stated by her that she did not see the keys at all. All her statement clarified the fact
that her statement will impede the process and thereby ought to be inadmissible in nature.
xxxii. According to the general rule of the Evidence Act, hearsay evidence is no evidence
unless certain exceptional requirements have been met28. The witness should be the prime
witness in this case. Further, he or she is required to experience the relevant facts of the
case physically. However, those requirements were not getting fulfilled in case of Sandra
and therefore, all the statements made by her should not treated as valid witness.
xxxiii. Detective Constable Bell had, in his statement, highlighted the name of two bars and
Alfred Fredricks is one of the managers of the bar. According to the rules, the evidences
given by he is quite admissible as he is working under the supervision of Tony Arnott,
one of the accused in this case and he met him at the day when the alleged offence has
been taken place. Further, according to the submission made by Sandra, Alfred was
physically present at the bar with Tony and he had also submitted the fact that tony had
suspiciously avoid the question regarding the authority of the keys of the locker. All these
facts ensure his position that she is a vital witness regarding this case and his statements
fall under the category of exception of the hearsay evidence29.
28 Thanawalla, Hanishi K. "022_Development and Liberisation of Hearsay Doctrine." (2015).
29 Spencer, John R. Hearsay evidence in criminal proceedings. Bloomsbury Publishing, 2014.

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xxxiv.Apart from the previously mentioned witnesses, there are certain other witnesses. After
considering the investigation report, it becomes quite clear to me that two experts who
had stated their views related to this case. According to them, the brown paper, in which
the alleged cocaine was present, was wrapped with an industrial tape. According to them,
the quantity of drugs that had been found in the paper was good and it can be presumed
that a drug peddler supplied the stuff. They have further observed it that part of the tape
that is specifically known as the grizzled tape has been found in the place of Tony.
Moreover, it has also been stated that Tony is suspected to pack the paper. However, the
amount of tape found from the place of the accused is not enough to prove the fact that he
had packed the paper and therefore, certain questions had come into the light regarding
the admissibility of their statement. First, there are certain limitations in their statement.
The Criminal procedure (Scotland) Act provides certain limitation to the powers of the
experts, they are restricted to act as a fact finder, and they could not interfere into the
fields that are particularly engaged with the judges or the jury. In addition to this, it can
be stated that the experts are liable to reveal the facts that are particularly embedded with
them and no one has any knowledge on the matter. Therefore, they are also restricted to
give any statement regarding the fact where the other person has any knowledge.
xxxv. Expert evidence is required in this case as the nature of the case come under the shadow
of the narcotic substances Act and it is also required to know about the category of the
drugs found in the paper. These topics are basically outside the knowledge of general
people and expert evidence is required in this case. According to the evidence collected
from the expert, it has been found that the drugs found in the brown paper are laid under

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the “Category A” drugs as mentioned under the Misuse of Drugs Act30. It has also been
ensured by them that only the drug peddler can supply that amount of drugs. It is to be
mentioned in this case that amount or quantity of drugs plays an important role and it is
not possible for an ordinary man to evaluate the right amount of drugs. Therefore, the
statements of the experts are quite reliable in this case.
xxxvi.It has further been observed by the experts that the tape that has been used for packaging
the paper is of industrial in nature and they are used to secure the products from any
outside interaction. According to the experts, certain amount of the tape has been found
from the place of Tony. However, this could not be proved the fact that Tony is liable for
that or he had wrapped the package.
xxxvii. In case of considering the admissibility of the expert evidence in this case, it is to be
stated that the statements should be based on critical facts and corroborated with the other
essential statements that can prove the relevancy of the examination done by the experts.
However, it is the duty of the court to analyze the critical facts of the case. the court can
ask the experts regarding their source or process by which it can be proved that who are
the main culprit in this case.
xxxviii. Apart from all these things, it can be stated that there are certain loopholes in the
statement made by the experts. The experts had failed to prove the fact that it was Tony
Arnott, who had packaged the paper. Further, the tape found in Toni’s place is a part of
the tape wrapped on the paper. Therefore, it has been observed that the findings made by
the experts had failed to give answer of the questions.
30 Monaghan, Mark. "Drug Policy Governance in the UK: Lessons from changes to and debates concerning the
classification of cannabis under the 1971 Misuse of Drugs Act." International Journal of Drug Policy 25.5 (2014):
1025-1030

14EVIDENCE LAW
xxxix.However, certain assumptions can be made after considering the statements of the
experts. Tony can be held as the investor of the drugs or he can be regarded as the
member of the chain. Further, Peter Dunn can be held as the supplier of the drugs. He can
be acted as the medium in between the supplier and the receiver.
After considering the facts, one thing is very clear to me that the prosecution has
much opportunity to succeed the case. Court is required to find out the critical facts and
in that case, the court is required to analyze each of the particulars of the statement and
best evidences. Further, it has been observed that there are certain possibilities, where it
can be proved that both the accused are guilty of the offence. Therefore, the charges can
be proceeded against them. The interview tapes are used as rhetoric device in this case
that are quite admissible in nature. However, it is clear from the statement made by DC
Bell that Tony had not accepted that he was present in the bar where he had met Alfred
Fredricks. However, this statement has later on proved false and therefore, it can be
presumed that certain vulnerability can be present in the part of the accused and this
made the case more potential to this effect.
Yours Faithfully,
ABC
Junior Advocate Depute
Crown Office

15EVIDENCE LAW
Bibliography:
Allison v London Underground Ltd [2008] EWCA CIV 71
Bäckström, Ylva, et al. "Integrating isotopes and documentary evidence: dietary patterns in a late
medieval and early modern mining community, Sweden." Archaeological and anthropological
sciences (2017): 1-20.
Brand v HMA [2011]
Brunner, Richard, and Gil Pradeau. "Public service reform and participatory budgeting: How can
Scotland learn from international evidence?." (2017).
Campbell, Liz. "Organised Crime and the Criminal Justice and Licensing (Scotland) Act
2010." Edinburgh Law Review 18.2 (2014): 225-244.
'Criminal Procedure (Scotland) Act 1995' (Legislation.gov.uk, 2018)
<https://www.legislation.gov.uk/id/ukpga/1995/46> accessed 2 April 2018
Ferguson, Pamela R. "Reforming Scottish Criminal Procedure: In Search of Process
Values." Bergen Journal of Criminal Law & Criminal Justice 4.2 (2017): 167-195.
Ferguson, Pamela R. "Reforming Scottish Criminal Procedure: In Search of Process
Values." Bergen Journal of Criminal Law & Criminal Justice 4.2 (2017): 167-195.
Fox v HMA 1998 S.L.T. 335
Hoyano, Laura. "Reforming the adversarial trial for vulnerable witnesses and
defendants." Criminal Law Review 2 (2015): 107-129.

16EVIDENCE LAW
Kjeldsen, T. R., et al. "Documentary evidence of past floods in Europe and their utility in flood
frequency estimation." Journal of Hydrology 517 (2014): 963-973.
Lipkin Gorman v Karpnale Ltd [1987] 1 WLR 987
Lockwood v Walker [1937] 127 Fla 20
McTear v Imperial Tobacco Ltd No 1 [2005] CSOH 69
Memon, Amina. "Eyewitness research: Theory and practice." Psychology and Law. Routledge,
2017. 65-78.
Meredith v Lees [1992] JC 127A
Monaghan, Mark. "Drug Policy Governance in the UK: Lessons from changes to and debates
concerning the classification of cannabis under the 1971 Misuse of Drugs Act." International
Journal of Drug Policy 25.5 (2014): 1025-1030.
Naidoo, Kamban, and M. G. Karels. "Prosecuting." Journal for Juridical Science 41.1 (2016): 65-
82.
Ogilvie, Astrid EJ. "Documentary Evidence of Changes in Climate and Sea-Ice Incidence in
Iceland During the Last Millennium." Polar Climate and Environmental Change in the Last
Millennium, Nicolaus Copernicus University, Torún, Poland, 24-27 August 2015. 2015.
Pandey, D. C. "020_Principles of Evidence." (2015).
Pentieva, Kristina, et al. "Evidence from a Randomized Trial That Exposure to Supplemental
Folic Acid at Recommended Levels during Pregnancy Does Not Lead to Increased

17EVIDENCE LAW
Unmetabolized Folic Acid Concentrations in Maternal or Cord Blood, 2." The Journal of
nutrition 146.3 (2016): 494-500.
Ross, Margaret L., et al. Walker and walker: The law of evidence in Scotland. Bloomsbury
Publishing, 2015.
Semmler, Carolyn, and Jessica Hurst. "The Impact of State and Trait Anger on Processing of
Evidential Inconsistencies." Psychiatry, Psychology and Law 24.4 (2017): 594-604.
Shiels, Robert S. "The Scottish Criminal Trial and Judicial Intervention in a Public Controversy."
(2016).
Smith v Lees 1997 SCCR 139
Spencer, John R. Hearsay evidence in criminal proceedings. Bloomsbury Publishing, 2014.
Spencer, John R. Hearsay evidence in criminal proceedings. Bloomsbury Publishing, 2014.
Thanawalla, Hanishi K. "022_Development and Liberisation of Hearsay Doctrine." (2015).
Valentine, Tim, and Josh P. Davis. "Forensic facial identification." Forensic facial identification:
theory and practice of identification from eyewitnesses, composites and CCTV (2015): 323-347.

18EVIDENCE LAW