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Williams v R

2014

COURT OF APPEAL (CRIMINAL DIVISION)

United Kingdom

CORAM

  • LORD JUSTICE FULFORD
  • MR JUSTICE GRIFFITH WILLIAMS
  • MR JUSTICE NICOL

Areas of Law

  • Criminal Law and Procedure
  • Evidence Law

AI Generated Summary

This is a Court of Appeal decision (Fulford LJ, Griffith Williams J, Nicol J) refusing the applicant’s renewed application for leave to appeal his murder conviction arising from the killing of Steven Grisales in Edmonton on 31 August 2011. The court’s focus was the admissibility and handling of hearsay evidence of alleged confessions by Danele Smith, including a recorded conversation with the applicant’s mother, Sandra Espeut, and a later voice note to “witness B”. The trial judge had required that, absent Smith, Espeut should testify to provide context and reliability, and rejected multiple hearsay via police. The court upheld that discretion, found no improper prosecutorial tactics, and rejected attempts to use cross-examination or re-examination to introduce inadmissible hearsay. It held witness B’s voice note was ambiguous, admitted Smith’s denial appropriately, upheld bad character rulings, and found the summing-up directions—including hearsay caution, identification guidance, section 34, Lucas, and self-defence—were proper. The application was accordingly refused.