R v Lucas
A lie told by a defendant can support the prosecution case only if it is deliberate, relates to a material issue, is motivated by a realisation of guilt and fear of the truth, and is proved by independent evidence.
Facts
Ms Lucas was charged with being involved in the importation of cannabis. Her co-accused gave evidence against her, which required corroboration as accomplice evidence under the law at the time. The judge directed the jury that lies told by her in her evidence could corroborate the evidence of the co-accused. She was convicted.
Legal principle
The Court of Appeal quashed the conviction. Lord Lane CJ said that, to be capable of amounting to corroboration, a lie told out of court must first be deliberate, second relate to a material issue, third the motive for the lie must be a realisation of guilt and a fear of the truth, and fourth the statement must be clearly shown to be a lie by evidence other than that of the accomplice who is to be corroborated. The jury should be reminded that people sometimes lie for innocent reasons, such as to bolster a true defence or to protect someone else. The Lucas direction is still given where the prosecution relies on a defendant's lies.
Related cases on witnesses, identification and expert evidence
- Jones v Kaney [2011] UKSC 13, [2011] 2 AC 398
- Kennedy v Cordia (Services) LLP [2016] UKSC 6, [2016] 1 WLR 597
- R v Barker [2010] EWCA Crim 4
- R v Cannings [2004] EWCA Crim 1
- R v Clark (Sally) [2003] EWCA Crim 1020
- R v Dallagher [2002] EWCA Crim 1903
- R v Davis [2008] UKHL 36, [2008] 1 AC 1128
- R v Forbes [2001] 1 AC 473
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This summary is for study and revision and is not legal advice. Although our case summaries are checked for accuracy, we do not guarantee that they are free from errors or omissions. Always read the full judgment for the court's reasoning.
