R v Blastland
Evidence that another man had made statements showing knowledge of a murder before it was publicly known was inadmissible hearsay, because the relevant inference depended on the truth of his statements.
Facts
Mr Blastland was charged with the murder of a boy. His defence was that another man, Mark, had committed the murder. He wished to call evidence that Mark had made statements to several people, before the body had been found, showing that he knew about the murder. The judge excluded the evidence as hearsay, and Mr Blastland was convicted.
Legal principle
The House of Lords dismissed the appeal. Lord Bridge said that the statements were relevant only if they showed Mark's state of mind, namely his knowledge of the murder, and that this was not directly relevant to the question whether Mr Blastland had committed it, because Mark could have acquired his knowledge in many ways, including by witnessing the murder. To the extent that the statements were relied on as evidence that Mark had committed the murder, they were hearsay, and confessions by third parties were not admissible at common law. The judge had rightly excluded the evidence.
Related cases on hearsay
- Al-Khawaja and Tahery v United Kingdom (2012) 54 EHRR 23
- Myers v Director of Public Prosecutions [1965] AC 1001
- R v Andrews [1987] AC 281
- R v Horncastle [2009] UKSC 14, [2010] 2 AC 373
- R v Kearley [1992] 2 AC 228
- R v Riat [2012] EWCA Crim 1509
- R v Y [2008] EWCA Crim 10
- Ratten v The Queen [1972] AC 378
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