The decision in R. v Conway (David Patrick) (1980) 70 Cr. App. R. 4 was not to be regarded as binding authority on the procedure required to be adopted in applications or appeals based on evidence of alleged retractions or inconsistent statements. What constituted the best and fairest procedure had to be determined on a case-by-case basis.
ADMISSIBILITY OF FRESH EVIDENCE FOLLOWING POST-TRIAL RETRACTION OF ALLEGATIONS
 EWCA Crim 159 February 21, 2013