Ratio Decidendi
Evidence obtained from a mentally disordered or mentally vulnerable suspect interviewed without an appropriate adult present, as required by PACE Code C, is likely to be excluded under s.76 or s.78 PACE 1984 as unreliable or unfair.
ข้อเท็จจริง
Aspinall, who suffered from schizophrenia, was interviewed without an appropriate adult. He made admissions which formed the basis of the prosecution case. He appealed on the ground that the interview breached PACE Code C.
สรุปคำพิพากษา
The Court of Appeal held that the requirement for an appropriate adult is an important safeguard for vulnerable suspects. The breach of Code C rendered the confession unreliable and it should have been excluded. The conviction was quashed.
คำกล่าวสำคัญ
"The purpose of the appropriate adult is to assist the suspect to understand the significance of what is happening and to facilitate communication."
— Roch LJ
การอ้างอิงภายหลัง
Applied in subsequent cases involving vulnerable suspects and the appropriate adult requirement.