There was no conflict between the duty of the Crown to make disclosure under the Magistrates' Court (Advance Information) Rules 1985 and the duty of disclosing material under the Criminal Procedure and Investigations Act 1996. In "summary only" cases, a failure to furnish the defence with statements of prosecution witnesses did not necessarily mean that the trial was unfair in terms of the European Convention on Human Rights.

QBD (Buxton LJ, Collins J)

08/02/1999