Confessions and Evidence Obtained Unlawfully
Chief Justice Lord Parker added to this test the terms ‘in an oppressive manner’. This was deﬁ ned prior to the Police and Criminal Evidence Act 1984 (PACE) coming into force in R v Priestly (1965) 51 Cr App R 1 as:
Judgment ‘. . . something which tends to sap, and has sapped . . . [the] free will which must exist before a confession is voluntary . . . the elements [of oppression] include such things as the length of time of any period of individual questioning, whether the accused person had been given refreshment or not, and the characteristics of the person who makes the statement’.