Regina v Beedles: CACD 31 Jul 1996

The defendant appealed against his conviction for sexual assault. The issue was whether a note written by the complainant to her teacher was admissible as evidence of recent complaint to corroborate her statement. Similar allegations had been made against him in Scotland, but he had not been convicted. He said that evidence of those complaints should not have been admitted.
Held: The letter constituted a complaint and was therefore admissible as evidence of recent complaint under the exception. The fact that the complaints had been made in Scotland said nothing about the truth or otherwise of them. The issue was their relevance and probative value. Counsel had allowed a tape to be played where the allegations were mentioned and without objection. There was no basis for criticising the judge’s direction. The conviction stood, but the sentence had been based in part on the other allegations, and was reduced.


[1996] EWCA Crim 740


England and Wales


CitedRegina v Lillyman CCCR 1896
Evidence of a contemporaneous complaint by the complainant to her employer was admitted against objections that such evidence ought not to be admitted and the evidence should be confined merely to the fact of the complaint. The evidence of the . .
CitedJones v South Eastern and Chatham Railway 1918
There is a ‘general rule of evidence that statements may be used against a witness as admissions but that you are not entitled to give evidence of statements on other occasions by the witness in confirmation of the testimony.’ . .
CitedGillie v Posho 1939
The court discussed the rule that a witness’ statement outside court may be used against him but not generally to support the truth of his statement. . .
CitedMakin v Attorney-General for New South Wales PC 12-Dec-1893
The accused had been charged with the murder of an infant who had been given into their care by the child’s mother after payment of a fee. They appealed after admission of evidence that several other infants had been received by the accused persons . .
CitedRegina v Brooks CACD 1992
. .
CitedRex v Ball HL 1911
Evidence of sexual acts or advances other than those which are the subject of the charge is frequently adduced to show the true nature of the relationship between the parties, a practice which may be regarded as an acceptable and inevitable form of . .
CitedRegina v Flack CACD 1969
The court admitted evidence of previous indecency with an alleged victim of incest. . .
CitedRegina v Rearden CACD 1984
A series of rapes on a child was regarded as one continuing offence for evidence purposes. . .
CitedRegina v Boardman HL 1974
The defendant appealed the admission of similar fact evidence against him. Acts of buggery were alleged by a schoolmaster with boys in which the accused was the passive partner.
Held: In order to be admissible similar facts must bear a . .
CitedRex v Bond 1906
The court considered the rule excluding evidence of the defendant’s bad character. Kennedy J said: ‘The general rule cannot be applied where the facts which constitute distinct offences are at the same time part of the transaction which is the . .
CitedRegina v Neale CACD 1977
Neale and Burr were jointly charged with arson and manslaughter. N wanted to adduce evidence, either by cross-examining prosecution witnesses or leading evidence himself, that B had admitted that he had started fires himself on four other occasions. . .
CitedRegina v Berry 1963
The defendant appealed a conviction for the violent stabbing of his ex-girlfriend.
Held: Evidence of past incidents should not be regarded as relevant to prove the state of mind with which a particular act (in that case was done. . .
CitedRegina v Fulcher CACD 1995
The previous non-accidental injuries sustained by the baby whom F was alleged to have murdered were relevant to show not only that the child, being in pain, was more likely to be fractious, but also how F was likely to react to the child crying. The . .
CitedRegina v Williams CACD 1986
The defendant was charged with threatening to kill.
Held: Evidence of previous threatening and violent conduct of Williams towards the victim was rightly admitted to establish an intention on the part of the defendant that the victim should . .
CitedRegina v Pettman CACD 2-May-1985
Background evidence is admissible ‘Where it is necessary to place before the jury evidence of part of a continual background of history relevant to the offence charged in the indictment and without the totality of which the account placed before the . .
CitedRegina v Stevens CACD 1995
S was charged with the murder of a woman with whom he had been living.
Held: Evidence of previous occasions on which he had assaulted her were properly admitted as part of the background. . .
CitedRegina v Sidhu CACD 22-Feb-1993
The defendant was accused of explosives offences relating to his promotion of the cause of Sikhism through membership of the Khalistan Liberation Force, which promoted an independent Sikh state. The jury considered a video recording of the appellant . .
Lists of cited by and citing cases may be incomplete.

Criminal Evidence

Updated: 08 October 2022; Ref: scu.148404