HER MAJESTY'S ADVOCATE v. BARRY McLEAN [2000] ScotHC 96 (5th October, 2000)

HER MAJESTY'S ADVOCATE v. BARRY McLEAN [2000] ScotHC 96 (5th October, 2000)

The interview under caution was a distinct and fair process, unaffected by the prior section 172 admission, and its transcript is admissible as evidence. The accused's Convention rights were not infringed by the admission of this evidence.

Citation
[2000] ScotHC 96
Parties
Prosecution: HER MAJESTY'S ADVOCATE; Accused: BARRY McLEAN
Jurisdiction
Scotland
Procedural Posture
Criminal / Ruling on Evidentiary Objection During Trial
Outcome
objection repelled
Legal Topics
Admissibility of Evidence, Self Incrimination, Fair Trial Rights, Road Traffic Act 1988, European Convention on Human Rights

Case Brief

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Parties

HER MAJESTY'S ADVOCATE

Prosecution

BARRY McLEAN

Accused

Procedural Posture

Criminal / Ruling on Evidentiary Objection During Trial

  1. 1 Whether evidence from an interview under caution is admissible when preceded by a self-incriminating reply to a section 172 requirement under the Road Traffic Act 1988
  2. 2 Whether the accused's right to a fair trial under Article 6 of the European Convention on Human Rights was infringed

Ratio Decidendi

The interview under caution was a distinct and fair process, unaffected by the prior section 172 admission, and its transcript is admissible as evidence. The accused's Convention rights were not infringed by the admission of this evidence.

Court Disposition

objection repelled

Orders

  • Transcript of interview under caution admitted as evidence