CONFESSIONAL STATEMENT IN CRIMINAL TRIALS 1

Utility of Confessional Statement in Criminal Trials

(An Overview)

Kristian Maghinay

Colegio de Iligan
 CONFESSIONAL STATEMENT IN CRIMINAL TRIALS 2

Introduction

An adverse admission relevant to the issues of guilt in a criminal case is known at Common

Law as confession, and the same terminology is employed by the Evidence Act 1990. As

indicated above, confessions represent the most important and most frequently encountered

exception to the rule against hearsay in criminal cases, fundamental changes in

the law pertaining to confessions were introduced by the Evidence Act 1990, but in order to

understand the principles of admissibility of confessions, it is necessary to understand the

principles of admissibility developed at common law to govern the admissibility of confessions.

Apparently, we will summarize the most important aspects of the common law rules, we will

then proceed to examine the new statutory definition and rules of admissibility of confessions.

While the common law recognized that a confession might be both reliable and cogent as

evidence of guilt, and indeed saw no objection to a conviction in cases where a confession was

the only evidence against the accused, the law recognized that a confession could be regarded as

reliable only when given freely and voluntarily. If coerced on forced, reliability of the confession

might be totally compromised and the integrity of the system of administration of justice itself

made to suffer. The exclusion of evidence obtained through torture, force or other coercive

methods was the means of protection of the accused developed by the judges during the

eighteenth and nineteenth centuries, when the memory of an age when such methods were

commonplace still lingered. Its significance may be gauged by the fact that in English law, the

rule that a confession obtained by oppression, in circumstances likely to render it unreliable must

be excluded, is the only instance of the mandatory exclusion of illegality or unfairly obtained

evidence. The classic statement of the common law rule as to admissibility of confession was

that of Lord Sumner in Ibrahim .V. R1

“It has been established that no statement by an accused is admissible in evidence against him

unless it is shown by the persecution to have been voluntary statement, in the sense that it has not

been obtained from him either by fear, or prejudice or hope of advantage exercised or held out by

a person in authority”.

In common parlance, ‘voluntary’ meant simply of one’s free will’. That test of voluntariness,

as defined by Lord Sumner was supplemented by Lord Parker C.J in Callis .V. Gunn2, when he

(1914) A C 559, 609

(1964) IQB 495, 501 added the requirement that a confession must not have been obtained in

‘an oppressive manner’, his observation was, strictly speaking, obiter – the case involved the

admissibility of fingerprint evidence. But when the Judges’ Rules appeared in revised form in

1964, the introduction started that the rules did not affect the principle, which was overriding and

applicable in all cases that:

… It is a fundamental condition of the admissibility in evidence against any person equally of

any oral answer given by that person to a question put by a police officer and of any statement

made by that person, that it shall have been voluntary in the sense that it has not been obtained

from him by fear of prejudice or hope of advantage, exercise or held out by a person in authority.

Interestingly, Lord Sumner’s phrases fear of prejudice’ and ‘hope of advantage’ are habitually

spoken of as ‘threats and ‘inducements’ respectively. It give rise to some problems in the

application of the rules of admissibility at common law. In particular, the suggestion of some

deliberate act in the words ‘threats’ and ‘inducements’ for a time led the courts to concentrate on

the mind of the questioner, rather than on the mind of the suspect. As the problem may recur,

despite the apparently clear wording – of the 1990 act, it is worth pursuing briefly. In R .V.
 CONFESSIONAL STATEMENT IN CRIMINAL TRIALS 4

Iseguilla 3, the court of Appeal concluded that:

(1975) I. W. L. R. 716,721-2

“… Under the existing law the exclusion of a confession as a matter of law because it is not

voluntary is always related to some conduct on the part of authority, which is improper or

unjustified. Included in the phrase ‘improper or unjustified’ of course must be the offering of an

inducement, because it is improper in this context for those in authority to try to induce a suspect

to make a confession”.

This view of the law would have left the accused without recourse in a case where without

any improper intent and perhaps even without realizing it, the questioner created some fear of

prejudice or hope of advantage in the mind of the suspect.’ In such a case, the resulting

confession might well be involuntary, but under the Isequilla rule, would nonetheless be

admissible. In D.P.P .V. Ping Lin4, the House of Lords was called upon to decide whether it was

the state of mind of the questioner or that of the suspect which was to control the question of

voluntariness. The House firmly held that it was the latter that governed the question of whether

or not the confession was voluntary, and that should therefore also control the question of

admissibility.

(1976) A. C, 574

Indeed, the rules of admissibility applied only where the fear of prejudice or hope of

advantage was excited or held out, or the oppression created by a ‘person in authority’, The

question of what persons were or were not persons in authority, has, however, settled that a

person in authority must have, or reasonably be thought by the suspect to have, some influence

over his arrest, detention or persecution, or in other words, be of a person from who a threat or

inducement might appear credible. The limitation of the rule in this way was not of great
 CONFESSIONAL STATEMENT IN CRIMINAL TRIALS 5

importance, since the vast majority of confessions are made to police officers and others who are

undoubtedly persons in authority, and it has been abolished expressly by the Evidence Act 1990.

But it remains germane to consider it in the light of the common law rule that the fear of

prejudice or hope of advantage must have been generated by the person in authority, with the

consequence that self-generated fears and hopes would not destroy the voluntariness of the

confessions. However, the result is different under the new statutory rules, even though the

confession is made to a person who previously have been a person in authority.

In addition to the rules governing admissibility, the trial Judge had power to exclude a

confession, in the exercise of his discretion, where it had been obtained by means of or following

a breach of the Judges’ Rules. The Judges’ Rules were rules of conduct and procedure for the

guidance of police officers and others concerned in the arrest, detention and interrogation of

suspects. They were fist promulgated by the judges of the then king’s Bench Division in 1912,

and subsequently revised from time to time. The Rules were not rules of law, and did not affect

the legal principles of admissibility of confession. However, in R. V. May6, Lord Goddard C.J

held that the trial judge might refuse to admit a statement if a breach of the rules occurred. But

the main importance of the rules always lay in the fact that a breach of the rules might provide

evidence that the resulting confession was not voluntary.

Statement of The Problem

Despite increased evidence that confessions may be unreliable, they remain the gold standard

of evidence for police investigations. One reason for the rejection of some confessional

statements is that when confessions are not voluntary there is the danger of the accused falsely

implicating himself. Different countries have different rules governing the admissibility of

confessions. These rules serve to guarantee that wrongful convictions do not occur. They also

serve as a deterrent to abusive interrogation by the police. Some interrogative techniques violate

the defendant’s free-will or procedural rights. In this article, while relying on recent judicial and

statutory authorities, the writer takes a look at what confessions are. He goes further to examine

the relationship between confessions and admissions, the probative value of confessions, the

factors that affect the admissibility of a confessional statement, and other facts related to

confessions. The role of the court in relation to confessional statements is also considered.

Particular attention is given to the position of the law in Nigeria and India, although references

are also made to other jurisdictions. This paper focuses on extra-judicial confessions that will

give my readers an insight to the utility of confessional statement in criminal trials.

Objectives of The Study

At the end of this study, the readers will:

1. Know what is confession and its utility on criminal trials;

2. Can now distinguish admission from confession;

3. Know the probative value of confession on criminal trials;

4. Will know the factors that affect the admissibility of a confessional statement; and

5. Know the rules of the court.

Research Questions

1. What is a confession?

ANSWER: A confession is a free and voluntary admission of guilt by an accused person.

Section 28 of the Nigerian Evidence Act defines a confession as an admission made at any time

by a person charged with a crime, stating or suggesting the inference that he committed the

crime. Confessions, if voluntary, are deemed to be relevant facts against the person who made

them only.

At common law, an informal admission made by an accused person, prior to his trial, to a person

in authority was known as a confession, an expression which included not only a full admission

of guilt but also any incriminating statement.

A confession occupies the highest place of authenticity when it comes to proving beyond

reasonable doubt.

The substantive law of confession is contained in Sections 28-32 of the Nigerian Evidence Act

and Sections 24 – 30 of the Indian Evidence Act.

The Police and Criminal Evidence Act (PACE) of UK in Section 82(1) defines a confession as

“includ [ing] any statement wholly or partly adverse to the person who made it, whether made to

a person in authority or not and whether made in words or otherwise.” It is hearsay and its

admission is by way of exception to the hearsay rule.

Section 25 of the Kenyan Evidence Act defines confessions as words or conducts, or a

combination of words and conducts, from which whether taken alone or in conjunction with

other facts proved, an inference may reasonably be drawn that the person making it has
 CONFESSIONAL STATEMENT IN CRIMINAL TRIALS 9

committed an offence. A confession can only be in respect of a matter within the knowledge of

the person confessing. A confession is worthless if it relates to matters outside of that knowledge

or experience. He cannot confess to the acts of other persons which he has not seen and of which

he can only have knowledge by hearsay. In R v Hulbert it was held that the accused could

confess, on a charge of handling stolen goods, that she received the goods, knowing or believing

them to be stolen, but she could not confess that they were stolen, since this was something that

she had merely been told. In Comptroller of Customs v Western Lectric Co. Ltd it was held that

the accused could not confess as to the countries of origin of various goods because the

admission was made upon reading the marks and labels on those goods and was of no more

evidential value than those marks and labels themselves. The confession must be made by the

accused himself and not by any other person. A confessional statement must identify the

perpetrator of the offence. In the case of a bride burning a confession was made before the

village panchayat by a large number of peoples of whom the accused was only one. Who among

them had burned the bride was not mentioned. Such confession was held to be not capable of

being used against any person. Specifically it was not a confession in any sense of the word.

Under Indian Law, an affirmative nod in response to direct accusation of crime is no less a

confession than an oral statement. Acknowledgement of guilt by signs or gestures may strictly

come within confessions as they may be regarded as verbal statements. But the danger of

interpreting signs or gestures as confession lies in the fact that the maker may not be able to

communicate intelligence to another person and is liable to be misunderstood. The other person

may not be able to convey his meaning to the accused by signs or words intelligible to him.

There is also the danger of making acknowledgments of guilt in answer to leading questions

imperfectly understood. Confessions made while talking in sleep though not legal evidence may
 CONFESSIONAL STATEMENT IN CRIMINAL TRIALS 10

furnish indicative evidence. Confessions are of two types. Judicial or formal confession is made

in court in the course of the proceedings. Extra judicial or informal confessions are those made

outside the court. Telephone calls made to the media owning responsibility of crime (e.g. bomb

blast) amounts to extra judicial confession. Extra judicial confessions should be proved by the

evidence of the persons to whom they were made or who heard them made or by the document

(if any) in which they were recorded. Before a confession is relied upon it must be clear whether

it is to be put in the category of judicial or extra judicial confessions. An extra judicial confession

may properly be made to any person, or collection of or body of persons. But there must be

something to show that the accused had previous association with those people and that he could

repose confidence in them and make an extra judicial confession involving him in a crime. It is

not necessary that it be addressed to any definite individual. It may take the form of a prayer but

majority of confessions are received by persons in authority upon the arrest of the accused or

while in custody. Extra judicial confessions may or may not be weak evidence. For example, the

accused cannot be convicted on the basis of an extra judicial confession made to a person not

shown to be a friend of the accused who would be taken into confidence and was wholly

unconnected with the police. Extra judicial confessions may be oral or written though as a

practical matter police interrogators normally record confessional statements volunteered by an

accused person since these are generally viewed as more reliable. These statements are usually

tendered in court during trials. Confessional statements may be made before or during trial but

before judgment.

In the past, German Federal Court of Appeals held that confessions obtained by the police

without issuing required warnings cannot be used as evidence. But where it could be shown that

the suspect knew of his or her rights, the lack of warning did not necessarily lead to exclusion.17
 CONFESSIONAL STATEMENT IN CRIMINAL TRIALS 11

A confession already admitted by the Court can be excluded at a subsequent stage if found

involuntary or defective in any way.

2. Distinguish Admission from Confession.

ANSWER: According to Black’s Law Dictionary, the distinction between admissions in criminal

cases and confessions by the accused is the distinction in effect between admissions of fact from

which the guilt of the accused may be inferred by the jury and the express admission of guilt

itself. In some cases, silence may amount to an admission, especially when both parties are

speaking or are simply on the same and even terms i.e. no one occupies a superior position in

relation to the other. A person is entitled to refrain from answering a question put to him for the

purpose of discovering whether he has committed a criminal offence. There is no obligation to

comment when informed that someone else has accused him of an offence. If it is reasonable to

expect someone to make some response to an allegation made against him, his subsequent

silence can now be used as evidence against him. In some cases, a denial, ipso facto, may not

necessarily render the statement made in his presence inadmissible as he may deny the statement

in such a manner and under such circumstances as may lead a judge or jury to disbelieve him and

constitute evidence from which an acknowledgment may be inferred by them. In English Law,

the term admission is usually applied to civil proceedings and to those matters of fact, in criminal

cases, which do not involve criminal intent, the term confession being generally restricted to

acknowledgments of guilt. The Nigerian Evidence Act proceeds upon the same principle.

Confessions are one species of admissions consisting of a direct acknowledgment of guilt by the

accused in a criminal case. Only voluntary and direct acknowledgment of guilt is a confession

but when a confession falls short of direct admission of guilt it may nevertheless be used as

evidence against the person who made it or his authorised agent as an admission under Section of
 CONFESSIONAL STATEMENT IN CRIMINAL TRIALS 12

the Indian Evidence (Amendment) Act, 2002 (4 of 2003). An oral confession by an accused is an

admission by an accused and is a relevant fact and may be proved at his trial. Proof of such

confession may be by the evidence of the person before whom it was made.

3. What is the probative value of confession?

ANSWER: Section 29(1) of the Nigerian Evidence Act provides that in any proceeding, a

confession made by a defendant may be given in evidence against him in so far as it is relevant

to any matter in issue in the proceedings and is not excluded by the court in pursuance of this

section. A confession is the best evidence in criminal proceedings. A confession made in judicial

proceedings is of greater force or value than all other proofs. If it is direct and true and

satisfactorily proved, it should occupy the highest place of authenticity when it comes to proof

beyond reasonable doubt. That is why such a confession by itself alone is sufficient without

further corroboration to warrant a conviction. And there cannot be such a conviction unless the

trial court is satisfied that the case has been proved beyond reasonable doubt. The denial or

retraction of a confession is a matter to be taken into consideration to decide what weight to be

attached to the confession. A confessional statement that is free, direct, positive and voluntary is

enough to ground a conviction. In addition, in this case, the appellant had expressly stated the

motive for the killing. A court only needs corroboration when there is any doubt as to the

voluntariness or the opportunity of making such statement.

The burden of proving that a confession was voluntarily made rests on the prosecution in

criminal proceedings. The burden involves the same standard as the proof of guilt, i.e. beyond

reasonable doubt.
 CONFESSIONAL STATEMENT IN CRIMINAL TRIALS 13

In the view of an author, the truth of the confession is irrelevant, so long as it proceeds

voluntarily from the maker and no law or rule laid down is breached. But in practice, in Nigeria,

a confession will only support a conviction without corroboration so long as the court is satisfied

of its truth. Where the issue is one of identity, where an accused by his confession has identified

himself, there is no need for any further identification parade.

A confessional statement must be voluntary and consistent with other evidence in court. Where a

confession is made voluntarily, it is deemed a relevant fact and admissible against the maker

under Section 27(2) of the Evidence Act.

Where the accused denies making the extra judicial statement, the court should look for some

independent evidence, that is to say, evidence outside the confession to make the confession

probable. The fact that the appellant took the earliest opportunity to deny having made the

statement may lend weight to his denial but it is not in itself a reason for ignoring the statement.

The proper time to object to it is at its point of being tendered. Under the Lagos State

Administration of Criminal Justice Law 2011, confessional statements are required to be video

recorded to avoid retraction by the defendant, often leading to a trial-within-a-trial which

occasions undue delays in the administration of criminal justice.

The court can convict an accused person on his uncorroborated confessional statement when

the following cumulative conditions are satisfied:

 There is something outside the confession which shows that it may be true

 The statements contained therein are likely to be true

 The accused had the opportunity to have committed the offence

 The facts stated by the accused are consistent with other facts which have been

ascertained and established at the trial.

Also, there are some questions a judge must ask himself on the weight to be attached to a

confessional statement:

 Is there anything outside the confession to show that it is true?

 Is it corroborated?

 Are the relevant statements made in it of facts true as far as they can be tested?

 Was the prisoner one who had the opportunity of committing the crime?

 Is his confession possible?

 Is it consistent with other facts which have been ascertained and have been proved?

Having satisfied the conditions for its admission and the weight to be attached to it, it is the best

and strongest evidence possible, short of eye witness account.

4. What are the factors that affect the admissibility of a confessional statement?

ANSWER: Under Section 29(2) of the Nigerian Act, where it is represented that the confession

was or may have been obtained by oppression of the person who made it or likely in the

circumstances existing at the time to render unreliable any confession which might be made by

him in such consequence, the court shall not allow the confession to be given in evidence against

him except in so far as the prosecution proves to the court beyond reasonable doubt that the

confession (notwithstanding that it may be true) was not obtained in a manner contrary to the

provisions of this section. The court may of its own motion require such proof.
 CONFESSIONAL STATEMENT IN CRIMINAL TRIALS 15

Section 24 of the Indian law provides as follows: a confession made by an accused person is

irrelevant in a criminal proceeding if the making of the confession appears to the court to have

been caused by any inducement, threat or promise, having reference to the charge against the

accused person, proceeding from a person in authority and sufficient, in the opinion of the court,

to give the accused person grounds, which would appear to him reasonable, for supposing that by

making it he would gain any advantage or avoid any evil of a temporal nature, in reference to the

proceedings against him.

It is generally assumed that no reasonable human being will make admissions prejudicial to

his interests and safety if the facts confessed are not true. Confessions are generally in writing

but can also be made orally. Sometimes, there are allegations of inducement, threats or duress in

the making of a confessional statement under investigation. A confessional statement does not

become inadmissible merely because the accused denies having made it. If the voluntariness is in

issue, the trial court has a duty to conduct a trial within a trial to determine the voluntariness of

the confession. Proof, by the prosecution, of the voluntariness of the confession is beyond

reasonable doubt before the confession can be admitted.

According to Obaseki, JSC, it has long been established as a positive rule of law which has

found a healthy place in our statutes ... ... that no statement by an accused is admissible in

evidence against him unless it is shown by the prosecution to have been a voluntary

statement ... ... Once a confession is admitted as evidence, it becomes part of the case for the

prosecution. The voluntariness of a confessional statement is a test of admissibility and not of the

truth or veracity of the statement.

1 . Duress, Undue influence, Use of Threats and violence

It is not possible to lay down any rule as to what constitutes inducement or threat. Each case is

decided on its own peculiar circumstances. Section 28 of the Nigerian Evidence Act provides

that a threat of disadvantage or of an avoidance of evil expressed in bare and plain terms or

obliquely by implication renders the statement inadmissible. Under the Indian law, a

confessional statement cannot be used against an accused unless the court is satisfied that it is

voluntary. It must be shown to be voluntary and free from police influence.

It should also be in unequivocal term admitting the commission of the crime. Where it is

probable that it was not voluntary, the court would be justified in rejecting it.

Oppression includes torture, inhuman or degrading treatment, use of threat and violence.

2 . Persons in authority

For inducement to make a confessional statement inadmissible, it must have proceeded from a

person in authority. It is not clear whether the confession would be admissible when the

inducement is made by a person not in authority and the confession is made to him. A person in

authority has been defined as someone engaged in the arrest, detention, examination, prosecution

or punishment of the accused i.e. anyone capable of influencing the course of prosecution and

conclusion of the offence.54 The accused must believe that he will gain an advantage or avoid an

evil by confessing. A person in authority also includes anyone who has control over the accused.

The term includes all persons to whom the accused must surrender if he wants to find a favour of

a kind in relation to the whole criminal proceedings (from point of arrest till conclusion of any

appeals made against judgment). In some cases inducements are vague and it is difficult to make

it out. In such cases, the benefit is usually resolved in favour of the accused person who raises
 CONFESSIONAL STATEMENT IN CRIMINAL TRIALS 17

the objection. Many of the so-called inducements have been so vague that no reasonable men

would have been influenced by them but one must remember that not all accused are reasonable

men and women ... It may have been right to err on the safe side.

Under Section 28 of the Evidence Act, inducement includes any inducement to speak. The

inducement must refer to an inducement to make a statement. It need not be an inducement to

confess the truth. Any promise/inducement must have a causal link with what was said and done

which made the accused confess against his wish. Inducement usually consists of a threat of

disadvantage or a promise of advantage. What constitutes inducement depends on the

circumstances of each particular case.

For inducement to render a confessional statement inadmissible, the advantage to be gained or

the evil to be avoided must be of a temporal nature. Moral exhortation does not amount to

inducement. Inducement may be direct or indirect.

The laws do not say the person to whom the inducement is directed. It is enough if it reached

the accused no matter how or through what channels. Thus, if the inducement is offered not

personally to the accused but to someone on his behalf, the result would be the same.

Any attempts by persons in authority to bully a person into making a confession or any threat

or coercion would at once invalidate such a confession if the fear was operating on the mind of

the accused at the time he claimed to have made the confession.

The mere fact that a confession is made to a person in authority does not render it involuntary

or inadmissible. It must be further shown that it was caused by any inducement, threat or

promise. For a confession to be relevant it must be shown that it was made by the accused
 CONFESSIONAL STATEMENT IN CRIMINAL TRIALS 18

person, and that its making was voluntary. Again, for it to be the foundation for conviction, it

must be further shown that it is true.

According to Sarkar, to make a confession irrelevant, strict proof of the existence of the non –

validating causes ( i.e. duress, inducement threat torture) is not necessary; it becomes so if it

“appears” to the Court from the surrounding circumstances to have been caused by inducement

and C (sic.)

Where an accused during trial retracts, denies or resiles from the extra judicial statement he

had earlier made to the police immediately after the event giving rise to the charge or

arraignment against him, he owes it a duty to impeach his said earlier statement.

An accused who desires to impeach his extra judicial statement must satisfy any of the

following:

 That he did not in fact make any such statement as presented.

 That he was not correctly recorded.

 That he was unsettled in mind at the time he made the statement.

 That he was induced to make the statement.

An accused can be convicted on a confession which is voluntary and true even if not

consistent with his evidence in court. The court can admit and convict on a retracted confessional

statement where satisfied that the accused made the statement and the circumstances surrounding

the confessional statement are credible. Extraneous evidence outside a confessional statement is

however desirable.
 CONFESSIONAL STATEMENT IN CRIMINAL TRIALS 19

When an interpreter is used in recording the statement of an accused, such statement is

inadmissible unless the person who was used in the interpretation is called as a witness in the

proceedings as well as the person who recorded same, failing which such a statement should be

taken as hearsay evidence and the accused entitled to an acquittal. Such evidence can only be

confirmed by the evidence of the interpreter as to the questions put to the accused by the

interpreter and the answers given to him by the accused person whose statement was being taken

in the language understood by him.

The question of the voluntariness of a confessional statement is tested at the time the

statement is sought to be tendered in evidence. In Oseni v. State, the confessional statements

were tendered without any objections from the defence. None of the prosecution witnesses were

cross examined as to their involuntariness. It was not until the prosecution had closed its case

and the appellants were testifying in their own defence that the issue was belatedly raised. In the

opinion of the Supreme Court, the trial judge was right to dismiss this aspect of the defence’s

case as an afterthought. It was too late to raise the issue on appeal.

5. What is the role of the court?

ANSWER: The trial court has an important role to play in determining the admissibility or

otherwise of any confession, especially where an inducement is alleged. Firstly, the court

determines whether the inducement, threat or promise is sufficient to constitute any of the

vitiating factors. The court also clothes itself with the mentality of the accused to see whether the

ground would appear reasonable for a supposition that he would gain any advantage or avoid any

evil. The court then judges as a Court if the confession appears to have been caused in

consequence of the inducement, threat or promise.

Searching questions should be put by the Court to such witness as had anything to do with the

confession. The court should ask questions like: Why is the accused confessing? In whose

custody did he confess? How did he express his willingness to confess? What are the

circumstances in which the question of the confession first arose? ‘Is it relevant’ is the question

and not ‘is it true?’

6. What are the facst discovered in consequence of an inadmissible confession?

ANSWER: Under Section 30 of the Nigerian law, facts discovered in consequence of

information given by an accused defendant may be given in evidence where such information

itself would not be admissible in evidence. Facts discovered as a result of a confession which is

inadmissible are admissible. Where incriminating facts discovered in consequence of an

inadmissible confession are admitted in evidence, the question is whether, notwithstanding that

the confession itself must be excluded, evidence is admissible to show that the discovery of the

facts in question was made as a result of the confessional statement. The law in this area is not

settled. It is submitted that the circumstances of each case will be taken into consideration in

deciding this issue. In Musa Sadau & ano v. The State the court stated that the test to be applied

in such cases in considering whether evidence is admissible is whether it is relevant to the matter

in issue. If it is, it is admissible and the court is not concerned with how the evidence was

obtained.
 CONFESSIONAL STATEMENT IN CRIMINAL TRIALS 21

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