R v Hedges

R v Hedges

The evidence of Dr Marsden was careful, cautious, and in line with modern practice. He did not claim positive identification or uniqueness of dentition, but only inclusion or exclusion based on unusual features. The science of forensic odontology is sufficiently robust for a qualified expert to opine on whether a mark is a bite mark and whether a suspect can be included or excluded as the biter. The trial judge was right to admit the evidence, and the conviction was not unsafe.

Parties
Respondent: Rex; Applicant: Sian Hedges
Jurisdiction
England and Wales
Judgment Date
08 January 2025
Procedural Posture
Criminal Appeal / Renewed Application for Leave to Appeal Against Conviction
Outcome
Leave to appeal against conviction refused
Legal Topics
Admissibility of Expert Evidence, Forensic Odontology, Bite Mark Evidence, Reliability of Scientific Evidence
Criminal Law Evidence Admissibility of Expert Evidence Forensic Odontology Bite Mark Evidence Reliability of Scientific Evidence

Case Brief

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Parties

Rex

Respondent

Sian Hedges

Applicant

Procedural Posture

Criminal Appeal / Renewed Application for Leave to Appeal Against Conviction

Legal Issues

  1. 1 Whether expert forensic odontologist evidence as to bite marks was sufficiently reliable to be admitted at trial
  2. 2 Whether Dr Marsden was competent to give expert evidence
  3. 3 Whether the conviction was unsafe due to admission of bite mark evidence

Ratio Decidendi

The evidence of Dr Marsden was careful, cautious, and in line with modern practice. He did not claim positive identification or uniqueness of dentition, but only inclusion or exclusion based on unusual features. The science of forensic odontology is sufficiently robust for a qualified expert to opine on whether a mark is a bite mark and whether a suspect can be included or excluded as the biter. The trial judge was right to admit the evidence, and the conviction was not unsafe.

Court Disposition

Leave to appeal against conviction refused

Orders

  • Leave for this judgment to be cited in future cases