The overarching criterion for admission of a statement was fairness, and the major factor in determining fairness was the voluntary nature of the statement. If a statement was voluntary, that was a strong reason for admitting it, notwithstanding a breach of Practice Note (CCA: Judges' Rules) (1964) 1 WLR 152. However, the court could still refuse to admit a statement made voluntarily if it would be unfair to admit it.

[2006] UKPC 5