The defence of duress was excluded when as a result of the accused's voluntary association with others engaged in criminal activity he foresaw or ought reasonably to have foreseen the risk of being subjected to any compulsion by threats of violence. A confession within the meaning of the Police and Criminal Evidence Act 1984 s.76 did not include a statement intended by the maker to be exculpatory or neutral and which appeared to be so on its face, but which became damaging to him at trial because, for example, its contents could then be shown to be evasive or false or inconsistent with the maker's evidence on oath.

[2005] UKHL 22