What is the test for a confession to a person in authority?

Manitoba, Canada


The following excerpt is from R. v. Beaulieu (S.F.), 1996 CanLII 18225 (MB QB):

The classic statement of the test for the admissibility of a confession to- a person in authority is that of Lord Sumner in Ibrahim v. R., [1914} A.C. 599, at 609: "It has long been established as a positive rule of English criminal law, that no state ment by an accused is admissible in evi dence against him unless it is shown by the prosecution to have been a voluntary statement, in the sense that it has not been obtained from him by fear of prejudice or hope of advantage exercised or held out by a person in authority."

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