The court considered what might be oppressive behaviour by an investigating officer.
Held: ‘oppression’ must be given its ordinary dictionary meaning of ‘the exercise of power or authority in a burdensome, harsh, or wrongful manner, the unjust or cruel treatment of subjects, inferiors etc. or the imposition of unreasonable or unjust burdens. ‘Oppression’ in the sub-section would be almost bound to entail some impropriety on the part of the interrogator. The ambit of section 76(2)(b) is wider than that in section 76(2)(a), so that a confession could be invalidated under that paragraph even when there had been no impropriety under the latter provision.
Judges:
Lord Lane CJ
Citations:
[1987] 1 QB 426
Statutes:
Police and Criminal Evidence Act 1984 76(2)
Cited by:
Cited – Regina v Dhorajiwala CACD 9-Jun-2010
The defendant appealed against her conviction for theft. She had been accused of stealing money over many months from the till at the pharmacy where she worked. She said that a confession in interviews conducted by civilian investigators should not . .
Lists of cited by and citing cases may be incomplete.
Criminal Practice
Updated: 02 May 2022; Ref: scu.416721