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All Cases
Evidence
Court of Appeal
1995

R v Makanjuola

[1995] 1 WLR 1348

Ratio Decidendi

Following the abolition of mandatory corroboration warnings by the Criminal Justice and Public Order Act 1994, it remains open to a judge to give a warning about the reliability of a witness where appropriate, but such warnings are discretionary, not mandatory.

Facts

Appeals were heard concerning the proper approach to corroboration warnings after the 1994 Act abolished the mandatory requirement.

Judgment Summary

The Court of Appeal held that judges retain discretion to warn about unreliable witnesses but are no longer required to give mandatory corroboration warnings for complainants in sexual offences or accomplice evidence.

Key Quotes

"It is a matter for the judge's discretion what, if any, warning he considers appropriate in respect of such a witness."

Lord Taylor CJ

Subsequent Treatment

Good law

Standard authority on the discretionary corroboration warning post-1994 Act.