R v Smith (Alec) [2020] 4 WLR 128

“The case was concerned with a historic sex allegation and involved multiple hearsay about a supposed confession by the alleged perpetrator when confronted with the allegation nearly half a century beforehand. The contentious evidence was adduced before the jury despite the prosecution having served no hearsay notice and the arguments on the appeal prompted the court to consider not only the operation of the multiple hearsay provisions but also to emphasise the importance of compliance with the Criminal Procedure Rules in relation to hearsay evidence, in order to ensure properly considered and articulated submissions and a structured decision on what can be complex and, in the words of the Court of Appeal, ‘tricky’ questions of procedure or evidence …”

ADDED Monday 23rd November 2020