ABSENCE OF TURNBULL DIRECTION

Generally speaking, a Turnbull direction had to be followed if a conviction in an identification case was to be held to be safe; but whilst the failure to follow particular directions might render a verdict unsafe, that was by no means an immutable rule. Ultimately, the test remained whether a verdict was safe or unsafe bearing in mind all the material before the court.

[2008] EWCA Crim 2981