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(1988) 87 Cr App R 380 (CA). The defendant made a confession admitting his involvment in a robbery, after being denined access to legal advice, in flagrant breach of Code C and s.58 of PACE). He sought to have his confession ruled inadmissible, on the basis that it was rendered unreliable (s.76(2)(b) of PACE). Although this section seeks to prevent the admissibility of an ImproperlyObtainedConfession, and although the Court of Appeal had no doubt that the police had behaved improperly, it held that the impropriety was not the cause of the confession. The defendant was an experienced criminal, familiar with police interviews and well aware of his rights. Thus, the confession was not made unreliable ``by anything said or done'' -- the defendant would have confessed anyway.
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