Professional Ethics pre-reading (to include student materials for the 1st small group session)

INTRODUCTION TO EVIDENCE:
PRELIMINARIES AND PROOF



A. INTRODUCTION TO THE LAW OF EVIDENCE
1. Evidence and procedure distinguished

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  The law of evidence regulates the way a fact is proved in court, including: which party has to prove a fact; the degree of certainty which must be reached before a fact can be treated as proved; what types of evidence can and cannot be used to prove facts.
  

• 
  The law of procedure regulates the general conduct of parties contemplating or involved in litigation, including: how the police investigate a case; how court proceedings are started in criminal or civil cases; the extent to which a party to any proceedings must disclose its case to the other side; how weak cases can be stopped before coming to trial; how the courts manage cases; the order of proceedings in court; etc.
  
  
  
• 
  The laws of evidence and procedure are frequently interconnected: for example, if a police officer breaches the procedural rules regulating the way she collects evidence (e.g. the conduct of an identification procedure) it might result in the judge making an evidentiary ruling excluding the evidence in court.
  

2. The paradigm of the criminal case: The Queen v Mr Small

The paradigm of the criminal case in the consciousness of many criminal lawyers is of the little man (Mr Small) being plucked from his home by the forces of the state and prosecuted under the full weight of the law. A civil dispute frequently involves a dispute between private individuals.

Since the peculiar vulnerability of defendants in criminal cases has strongly influenced the way the evidential and procedural rules of the criminal courts have developed, reflect on that vulnerability for a moment:

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  In the paradigm criminal case it is Mr Small versus The State.
  
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  There is extreme inequality between the parties.
  
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  If Mr Small loses the case, he loses his reputation and possibly his liberty. There is no equivalent loss if the State loses the case.
  

Since Mr Small in the criminal case is in a particularly vulnerable position he has traditionally been afforded many important rights: the right not to answer questions when arrested by the police; the right not to give evidence in court; the right that he should only be convicted if the prosecution has proved its case against him beyond reasonable doubt; etc.

According to the paradigm Mr Small is entitled to say and do nothing from the moment of his arrest onwards and in effect say to the prosecution: “You prove beyond reasonable doubt to this jury that I did it – otherwise let me go”.
Though Mr Small’s position has come under attack in recent years, the paradigm explains some important differences between the law governing the procedure and evidence in the criminal and civil courts. Note in particular the following:

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  The use of trial by jury in many criminal cases – even in relatively “trivial” cases - contrasted with the rare use of juries in civil cases.
  

This has had an important impact on the development of the law of evidence. Whether evidence is allowed to go before the court in criminal cases (i.e. whether it is “admissible”) is regulated to a far greater extent than in civil cases, partly because of the prevalent use of lay juries who, it has traditionally been felt, need to be ‘protected’ from certain types of evidence which they don’t have the expertise to properly to assess (e.g. hearsay evidence).

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  The fact that in civil cases the parties are expected to co-operate far more extensively with each other and the court than in criminal cases.
  

The second bullet point is illustrated by the following table:

CIVIL CASE	CRIMINAL CASE
Pre-action disclosure: Requirement on parties to be open about their case and to try to reach a settlement. Failure of party to co-operative may be punished in costs.	Pre-action disclosure: Generally, no requirement on defendant to assist the state at all before charge. Defendant generally cannot be punished for saying nothing (though may have evidential consequences).
Failure to defend: If the defence do not file a defence, or file an inadequate one, the claimant can apply for judgment in default or summary judgment	Failure to defend: If the defendant remains silent in the face of the accusation the prosecution must prove its case by calling evidence in a trial.
Pre-trial disclosure: Parties must disclose Witness statements and all other evidence relied upon Documents which undermine their case/assist the other side	Pre-trial disclosure: Prosecution must disclose Witness statements and all other evidence relied upon Documents which undermine their case/assist the defence The defence do not have to disclose any of the above (though there is a limited duty of disclosure, failure to comply with which may have evidential consequences)

3. What is “evidence”?
“Evidence is information. It is information that provides grounds for belief that a particular fact or set of facts is true.”
Dennis, The Law of Evidence (5^th Edn).

4. When will a court hear evidence?
When there is a dispute about a factual issue which must be resolved in order for the court to determine the legal consequences
In criminal trials the tribunal of fact has to reach a conclusion as to what happened in order to decide whether or not D is guilty. But it is rarely the case that every single essential fact is in dispute. For example, in a domestic burglary case the prosecution must prove that D entered the property as a trespasser and stole therein. But if the defence is ‘alibi’ it may not be disputed that there was a burglary: the only fact in dispute being who did it.
When facts in a trial are not in dispute then one of two things will happen.

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  The parties will make admissions as to the agreed facts to avoid the necessity of calling evidence.
  

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  The party wishing to establish the fact will present its evidence on that fact and the other side will not challenge it, either in cross-examination or by calling contradictory evidence.
  

5. The facts which the court must resolve: the “facts in issue”
A court is only concerned with determining the material facts of the case (usually called “the facts in issue”). It will only hear evidence that is directly or indirectly relevant to those facts.
In a criminal case the facts in issue are determined by reference to the elements of the offence charged and any defence raised. The case may be fascinating for all sorts of other reasons but the court will confine itself to evidence which relates to those facts.
So in the burglary case referred to above (in which, say, some money was stolen) the facts in issue are:

1. 
   The defendant (i.e. the prosecution must prove who did it)
   
2. 
   Entered a building
   
3. 
   As a trespasser and
   
4. 
   Appropriated therein
   
5. 
   Property
   
6. 
   Belonging to another
   
7. 
   With the intention permanently to deprive the owner thereof
   
8. 
   Dishonestly
   

In most cases D’s defence will simply involve denying being the perpetrator or disputing one or more elements of the offence. So the defence might be run as follows:

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  “It wasn’t me” (fact 1); or,
  
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  “I admit I stole the cash, but it wasn’t a burglary - the guy invited me into his house” (fact 3); or
  
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  “It was my ex-wife’s house: I just broke in to get what was rightfully mine” (fact 8).
  

Sometimes the defence will raise a specific defence which then becomes an additional “fact in issue”. If, for example, D’s defence is that he committed the burglary under duress, then “duress” becomes a fact in issue.

NOTE: the phrase ”fact in issue” is somewhat misleading because very often a “fact in issue” won’t be disputed. That’s why some people prefer to refer to them as the “material facts”.

6. The resolution of facts in issue: admissibility of evidence
The journalist/ historian can look at any sources in order to build up a picture of what happened.
A court, applying the rules of evidence, will exercise a much greater control over what evidence it will hear. It can refuse to hear evidence which is relevant to a fact in issue on the grounds that such evidence is “inadmissible”.
There are different rules as to admissibility in civil and criminal cases. Broadly, there are fewer restrictions on allowing certain types of evidence to be presented to a civil court (for example, hearsay evidence). The differences stem largely from the historic use of juries in criminal cases and the desire to protect vulnerable defendants facing criminal charges from the possible prejudices, irrationality, or inexperience of jurors.

7. The overarching principle of admissibility: relevance
As just indicated, there are rules of law restricting the admissibility of evidence (the rule against hearsay, etc). But those rules are not engaged at all unless the evidence is relevant. To be admissible, evidence – looked at alone or with other evidence - must be directly or indirectly relevant to a fact in issue, in the sense of making that fact more likely.

Relevant evidence “is evidence which makes the matter which requires proof more or less probable.” Per Lord Simon of Glaisdale in DPP v Kilbourne [1973] AC 729 at 756.

Direct and indirect evidence of a fact in issue
If the evidence is direct evidence of a fact in issue there can be no argument about its relevance:

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  A witness to a robbery gives evidence of seeing D strike V and take his watch.
  
• 
  a rape victim gives evidence that she did not consent to intercourse.
  

If the evidence is indirectly relevant to a fact in issue (i.e. is ‘circumstantial’) then the party calling the evidence must always be prepared to argue why it is relevant – i.e. how it makes a fact in issue more likely.

Be aware that many cases rest wholly or substantially on circumstantial evidence. In many murder cases, for example, the only person who could have given direct evidence of the crime is dead.
NB A large proportion of legal arguments in criminal cases are concerned with ‘relevance’.

8. Can a court exclude evidence that is relevant and otherwise admissible?
In other words, does a court have a discretion to say to a party which has relevant and admissible evidence: “You can’t call it”?

The extent of the judge’s discretion to exclude evidence in criminal cases will be considered in several contexts during this module. Suffice it to say here that in criminal cases

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  The judge can exclude relevant and admissible prosecution evidence in the interests of “fairness”
  

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  The judge has no discretion to exclude relevant and admissible defence evidence
  

Prosecution evidence
At common law there is a discretion to exclude

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  Evidence which is “more prejudicial than probative.”
  

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  Evidence of admissions and confessions and other evidence obtained from the defendant himself after the commission of the offence by improper or unfair means and which might operate unfairly against him
  

So using her common law powers a judge might exclude photographs of injuries caused by child cruelty where the injuries can be proved in a less inflammatory manner (e.g. by oral evidence from a pathologist): there is a danger that the prejudice caused by the photographs will far outweigh the simple fact of the injuries which they are intended to prove. And she might exclude an admission made by the defendant in the back of the police car where he was questioned aggressively without being cautioned, without a solicitor present, and without the conversation being recorded.

The common law discretion has been largely superseded by s.78 of the Police and Criminal Evidence Act (PACE). Under s.78 the judge can exclude relevant and admissible prosecution evidence if:
“having regard to all the circumstance, including the circumstances in which the evidence was obtained, the admission of the evidence would have such an adverse effect on the fairness of the proceedings that the court ought not to admit it.”
N.B. Section 78 is probably the most frequently cited section of any criminal statute. You should know it word for word.
Defence evidence
The judge has no discretion to exclude defence evidence which is logically probative.

9. Categories of evidence
a) Direct and circumstantial evidence of material facts
For the distinction, see 7 above.
b) Evidence of background to material facts
It is unhelpful to state facts in meaningless isolation. You’ve got to be able to fill in the background circumstances and events for a jury to make sense of it. The amount of context evidence required to make sense of an allegation is usually a matter of common sense. A judge will be quick to intervene if she thinks the parties are introducing irrelevant background.
c) Evidence of collateral facts
Collateral facts are facts which help in assessing evidence which is relevant to the material facts.

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  Facts which affect a witness’s credibility
  
• 
  Facts which affect the admissibility of evidence
  

d) Hearsay evidence
A big subject dealt with later in the course.
One of the characteristics of the adversarial system is the giving of oral evidence before the judge/jury, and the examination and cross-examination of the witnesses.
It has traditionally been considered important that the judge/ jury should be able to see the witness give evidence and the other side should have the opportunity to “test” the evidence by robust cross-examination. That way the fact finder (it is felt) is best able to assess the truthfulness and reliability of the evidence.
It follows that if a party wants to rely on a particular witness’s evidence that party must produce the witness at court, rather than simply read out a statement made by that witness or get someone else to say what that witness would say. Evidence of what a witness included in a written statement or said to someone else is likely to be classified as “hearsay”. There is a general rule that hearsay evidence is not admissible.


10. Forms of evidence
a) Oral evidence (testimony)

Evidence of a witness from the witness box in court

b) Real evidence

“Material from which the court may draw conclusions or inferences from using its own senses.” (Murphy)

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  The gun
  
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  The demeanour of a witness
  
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  Photographs and films
  
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  Bloodstained shoes
  

Often real evidence cannot be produced in court (for example, a stolen car). In that case the court might have to make do with oral evidence, describing the thing in question.

Whilst it may not be possible to bring the thing to court, it may be possible to take the court to the thing – in other words, for the court to up sticks and go and look at it.

This most commonly happens where the court is persuaded that the tribunal of fact would be helped by having a view of the place where the offence took place (still called by lawyers the “locus in quo” – (Latin for “place in which”). If it is a jury trial, then the jury together with the judge, defendant, counsel, and shorthand writer will attend the place (at any time before the summing-up has finished).

c) Documentary evidence

The word document includes “anything in which information of any description is recorded” (s.13 CEA 1995 and s.134 CJA 2003).

This includes books, letters, newspapers, computer printouts, video film.

11. Assessment of evidence
a) Credibility v Reliability
It is for a tribunal of fact to assess the credibility and reliability of witnesses

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  Credibility – how honest is the witness?
  
• 
  Reliability – how accurate is the witness?
  
• 
  
  

“Credibility” is often used to mean “reliability” – so be careful.
b) Weight
Weight of a piece of evidence refers to any or all of the following

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  The degree to which it helps to prove a material fact
  
• 
  The degree to which it is credible
  
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  The degree to which it is reliable
  

12. Do facts always have to be proved by evidence?
In a criminal court if a defendant pleads not guilty then that plea puts all of the elements of the offence in issue and they must all be proved.
If a defendant serves a defence statement indicating that certain matters won’t be in issue during the trial that defence statement is not a formal admission. The facts must still be proved. (Defence statements are described in the Criminal Procedure Outline document.)
The prosecution (or defence) can ask the other side to make a formal admission under s.10 CJA 1967. This will normally be in writing, though if made on behalf of a defendant it can be made orally in court by her counsel or solicitor. Once made the admission is conclusive evidence of the fact admitted, and permission to resile from the admission will rarely be given.
Alternatively – as more frequently happens – the party can just call the evidence and it will become apparent from the cross-examination which facts are admitted and which aren’t.

B. BURDEN AND STANDARD OF PROOF
1. Introduction

A judge or jury faced with the task of deciding what happened may get it wrong. That

cannot be allowed to prevent them from reaching a conclusion of fact. So we must have rules for judges and juries which say, in effect, provided you are x% satisfied that this happened then you must find that it happened; and if you are not x% satisfied that it happened then you must find that it didn’t happen.

2. The burden and standard of proof in criminal cases
The general rule as to the standard of proof
The general rule in criminal cases is that D cannot be convicted unless the court is ‘sure’ or ‘satisfied beyond a reasonable doubt’ that each element of the offence has been proved by the evidence. Whilst the “beyond reasonable doubt” test is legally correct, judges have been warned against using it in jury trials. The Bench Book (used by judges in preparing their summing-up to the jury) suggests telling the jury they must be “sure” of guilt. This tends to prevent awkward questions coming from them as to what amounts to a “reasonable doubt”.
The general rule as to the legal burden of proof
Because it is the prosecution who will lose if the court is not so satisfied it is said that the prosecution bears the legal burden of proof.

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  Whether or not the prosecution has discharged the legal burden of proof
  

depends on the whole of the evidence - not only the prosecution evidence.

Sometimes the prosecution case is strengthened when the defendant gives evidence, particularly if the jury thinks he is clearly lying.

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  The legal burden of proving a fact in issue remains on the prosecution throughout the whole of the case.

  Just because the defendant goes into the witness box does not mean that the burden of proof shifts to him.

  
  

3. The evidential burden

As just seen, to secure a conviction the prosecution must prove each element it is required to prove beyond reasonable doubt. This is called the “legal burden of proof”.

But sometimes it turns out that in relation to one or more such element, the prosecution’s evidence is either non-existent, or so weak that no reasonable jury could convict on it. If that is so, then the judge will stop the case and direct the jury to acquit. So, the prosecution has to get the case past the judge before the jury is allowed to decide guilt or innocence. This requirement to “pass the judge” is referred to as the “evidential burden.” It is not a burden of “proof”. It is a much lighter burden. It is a burden to call sufficient evidence that a reasonable jury could convict.

To take a practical example. Imagine D is charged with burglary. His defence is alibi. The prosecution have strong evidence that the house was burgled (indeed, it is not in dispute). But to prove it was D who did it they rely upon one eyewitness who purported to recognize the burglar as he ran away from the scene. But unfortunately it was dark and the prosecution witness was drunk. Once the prosecution has called all of its evidence during the trial the defence may submit that there is no case to answer on the issue of ID – i.e. that the prosecution have failed to discharge the evidential burden. The judge will probably agree that no reasonable jury could convict on that evidence and direct the jury to acquit.

Now imagine the same scenario, except the prosecution call the additional evidence that D’s fingerprint was found on the front door of the property. Now the judge may allow the case to go to the jury. It may be that the defendant has offered the police an innocent explanation for the fingerprint. But on the evidence of the ID plus the fingerprint a reasonable jury could convict. The evidential burden is discharged and the judge will allow the jury to decide the matter. Of course, the jury may still acquit if they are not sure of guilt – in that case the prosecution will not have discharged the “legal burden”.

4. An evidential burden on the defence in criminal cases
Generally speaking the prosecution has the legal and evidential burden in relation to every element of the offence. And the general rule is that the defendant does not have to call any evidence in support of his defence. He can say nothing; he can attack the prosecution’s case in cross-examination; and he can, if he wishes call evidence to contradict the prosecution. But there is generally no requirement on him to produce or point to evidence which positively supports his case.
However, sometimes the law places on the defendant an “evidential burden” in relation to his defence. This can occur usually when the defence runs something like this: “it may be that you can prove the actus reus against me; but something was operating on my mind at the time which means that no moral blame attaches to my action.”
For example, the defendant may say, “I accept I assaulted him, but I was acting in self-defence.”
Where the law places an evidential burden on the defendant he must point to some evidence of the thing that was operating on his mind. Unless he can point to some evidence which raises the defence as a live issue, the judge will not allow the jury to consider it. If he does manage to raise the defence on the evidence (i.e. he discharges the evidential burden), it then falls to the prosecution to disprove his defence beyond reasonable doubt.
Two important things to note when D carries the evidential burden:

• 
  That evidence may come from defence or prosecution witnesses
  

For example, D may say in his police interview that he was acting in self-defence. The evidence as to what he said in interview will be given by a police officer as part of the prosecution case. But the defendant can point to that in order to say that the evidential burden has been discharged and the defence has been raised. If he said nothing in his police interview, then probably the only way he could discharge the evidential burden would be to call defence evidence (which may simply mean giving evidence himself).

• 
  Provided the defendant discharges the evidential burden it is for the prosecution to disprove the defence raised beyond reasonable doubt.
  

There are a number of defences developed by the common law which give rise to an evidential burden on the defence. The important one for BPTC purposes in self-defence. Others include:

• 
  Loss of self-control
  
• 
  Duress
  
• 
  Intoxication
  
• 
  Automatism
  

5. A legal burden on the defence in criminal cases

In part 4 we looked at circumstances in which the defence bear an evidential burden. If discharged, the legal burden is on the prosecution to disprove the defence beyond reasonable doubt.

However, there are some instances in which the defendant bears not only an evidential burden, but also the legal burden in relation to his defence. In other words, to be acquitted he must prove his defence.
Whenever a defendant bears the legal burden of proving his defence, the standard of proof is “on the balance of probabilities”. In other words, he must establish that it is more likely than not that his defence is a true defence. If the jury is left thinking that there is a 50-50 chance that his defence is true then they must convict: he has failed to tip the balance of probabilities in his favour.
Common law defence of insanity
Whenever D says, “I am not guilty because I was legally insane at the time of the offence”, D must prove insanity.
Statutory defences where the legal burden is explicitly placed on D.
Some statutes creating criminal offences state (in effect) that “XYZ circumstances amount to a defence and it’s for D to prove that he falls within those circumstances”.
In such cases, the prosecution is required by the statute to prove certain material facts beyond reasonable doubt. If the prosecution does so then the defendant must prove the defence (on the balance of probabilities). If he fails, he is convicted. Look, for example, at the offence of having an offensive weapon contrary to s.1(1) of the Prevention of Crime Act 1953. Work out what the prosecution has to prove and what the defence would have to prove:

s.1 (1) Any person who without lawful authority or reasonable excuse, the proof whereof shall lie on him, has with him in any public place any offensive weapon shall be guilty of an offence.

6. Defence legal burdens and the Human Rights Act
Article 6(2) European Convention on Human Rights
Everyone charged with a criminal offence shall be presumed innocent until proved guilty according to law.
In every case where a defendant is required to disprove a fact which is an integral part of alleged criminal conduct there is an apparent conflict with the presumption of innocence. In the case of an offensive weapon, the defendant is doing nothing criminal if he confiscated a flick-knife from his son and was carrying it to the police station when arrested. But if that’s why he had the flick-knife then he has to prove it. If he fails to prove it, he will be convicted. On the face of it, that appears to conflict with the presumption of innocence.
What is more, given the standard of proof placed on the defendant, he might be convicted even where the jury is 50% convinced he is telling the truth (see above).
There have been challenges to the legality of these “reverse onus clauses” under the HRA 1988. But the UK courts, in line with the ECtHR, has found that reverse onus clauses are not necessarily incompatible with Article 6(2) provided they operate within reasonable limits. Where Parliament has placed a legal burden of proof on D the courts will ask whether the statute is pursuing a legitimate aim (in our example, it is – the protection of the public from weapons made or intended to cause injury to the person). If it is, the courts will analyse whether or not the use of a reverse burden clause is a proportionate response in pursuit of that aim. The principles which the courts have developed in answering that question are beyond the scope of this course.


SAMPLE EVIDENCE MCQs
1. Paula is on trial for a strict liability offence of driving a motor vehicle whilst disqualified. PC Adams arrested Paula after observing her driving a motor vehicle along High Road. In her police station interview, Paula accepted that she was driving the motor vehicle in question but states that she did not realise she was a disqualified driver. At the trial, there is uncertainty as to whether Paula was actually disqualified from driving.

 

Which ONE of the following pieces of evidence is irrelevant for the purposes of Paula’s trial?

[A] The court records, setting out details of Paula's disqualification from driving

 

[B] The tape-recorded interview in which Paula confirms she was the driver of the motor vehicle

[C] Evidence that Paula did not intend to drive whilst she was disqualified.
[D] Evidence from PC Adams confirming that he saw Paula driving a motor vehicle

2. Andrew Jones is on trial at the magistrates' court for an offence of burglary. The police case is based upon DNA evidence: DNA found at the burgled premises matches that of Andrew Jones. At the trial, the magistrates discover that the police did not properly take the DNA samples from Andrew: there were various breaches of the PACE Codes of Practice. As a result there is a risk that the DNA evidence may be unreliable.

Which ONE of the following propositions is correct?

[A].  The DNA evidence is relevant to the issue of identification. It is therefore admissible and must be admitted. The unreliability of the DNA evidence will only relate to the weight that will be attached to it.

[B]  Whilst the DNA evidence is relevant to the issue of identification, it will not be admissible if it was taken in breach of Police and Criminal Evidence 1984 Codes of Practice
[C]  Whilst the DNA evidence is relevant to the issue of identification and potentially admissible, the court will have the power to exclude this evidence under Police and Criminal Evidence Act 1984, s.78.
[D] The DNA evidence is irrelevant to the issue of identification and so is inadmissible.
3. Ashok Sharma has been summonsed to attend Central Magistrates' Court in relation an offence of driving a motor vehicle without a valid policy of motor insurance contrary to the Road Traffic Act 1988 (“the Act”). Section 143(3) of the Act provides that:

“A person …shall not be convicted if he proves – that he was using the vehicle in the course of his employment, and that he neither knew nor had reason to believe that there was not in force in relation to the vehicle such a policy of insurance...”

Ashok now accepts that he was driving the motor vehicle without insurance. However he wishes to raise the defence that he believed his employer (the vehicle owner) had arranged insurance for the car and that Ashok had no reason to believe the vehicle was not insured.
Which ONE of the following propositions is correct in relation to Ashok’s defence under Section 143(3) of the Act?
[A] Ashok will have a legal burden to prove his defence beyond reasonable doubt.
[B] The prosecution will have to disprove Ashok’s defence beyond reasonable doubt.
[C] The prosecution will have the legal burden to disprove his defence on balance of probabilities.
[D] Ashok will have the legal burden to prove his defence on balance of probabilities.

4. You are defending Trevor who is charged with stealing a bicycle from a bike rack in Cabot Circus. Bristol on 15^th June 2015. He was found in possession of the bicycle at his home in Bristol on 4th May 2016. When interviewed by the police he claimed he had bought the bicycle in good faith at a car boot sale on the 4^th April, the month before his arrest. You are considering what legal submissions might be made at Trevor’s trial on behalf of the defence.

What would be the BEST submission for you to make?

A submission:

[A] that the evidence of Trevor’s possession of the bicycle in May 2016 is irrelevant and therefore inadmissible;

[B] that the prosecution have failed to discharge the evidential burden and that there is no case to answer;

[C] that the evidence Trevor’s possession of the bicycle in May 2016 should be excluded as being more prejudicial than probative;

[D] that the evidence of Trevor’s possession of the bicycle in May 2016 should be excluded under s.78 of PACE.

Faculty of Business & Law

The Professional Training Course

Full Time 2016/2017

Part Time 2015/17 (Year 2)

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CIVIL LITIGATION, EVIDENCE AND REMEDIES

PRE-COURSE MATERIALS

STUDENT INSTRUCTIONS

1.