Hearsay in Criminal Trials: A Disclosure-First Approach, Expanded “Testing Material”, and a Proactive s.125 Safeguard (Reformulated Riat Steps)

1. Introduction

In Naddi & Ors, R. v [2024] EWCA Crim 1874 (CA (Crim Div), 5 December 2024), the prosecution appealed (under the Criminal Justice Act 2003 framework for prosecution appeals against rulings) a Crown Court decision excluding, as inadmissible hearsay, multiple statements made by two complainant-witnesses who died before trial.

The appellant was the Crown. The respondents were four defendants (referred to in the proceedings as BOB, BYY, AEN and BEK). The hearsay comprised: (i) early and later accounts of a knife attack inside a flat, (ii) identification procedure evidence, and (iii) a later “change of account” by the second deceased witness as to the context and motive for the defendants’ presence (a “cuckooing”/drug-dealing arrangement).

The Court of Appeal (Edis LJ, Bright J and HHJ Morris) emphasised that the appeal did not create new statutory law, but it did restate and sharpen practical doctrine: it reformulated the well-known six-step checklist in R v. Riat into a seven-step approach, placing disclosure as an explicit first step, broadening what counts as material enabling a jury to test hearsay, and requiring courts to consider the section 125 “stop the case” safeguard proactively.

The judgment also records that a retrial subsequently took place (January 2026), resulting in convictions of all four respondents, with the most serious offence being inflicting grievous bodily harm contrary to section 20 of the Offences Against the Person Act 1861.

2. Summary of the Judgment

  • The Court of Appeal held that the trial judge’s exclusion of the deceased witnesses’ statements was wrong and not a reasonable ruling applying the statutory test (Criminal Justice Act 2003, s.67).
  • The judge’s central error was failing properly to take into account: (a) the issues actually in dispute (as revealed by the defence statements), and (b) the extensive independent dovetailing/supporting evidence corroborating large parts of the hearsay and reducing the risk of mistaken identification.
  • The Court allowed the appeal and ruled the hearsay statements admissible, while stressing that the trial judge must later consider section 125 (whether the hearsay is so unconvincing that conviction would be unsafe).
  • The Court criticised the prosecution’s disclosure approach and made clear that in important hearsay cases the prosecution must conduct “very full enquiries” into credibility and disclose relevant unused material, reflecting Riat.
  • The Court clarified that there is no impropriety in a judge ruling via multiple routes (e.g., admissibility then exclusion under PACE s.78 or CJA 2003 s.126); and if R v Ali [2024] EWCA Crim 77 had been read as discouraging this, that reading should be corrected.

3. Analysis

3.1 Precedents Cited (and How They Shaped the Decision)

R. v Horncastle [2009] UKSC 14; [2010] 1 Cr. App. R. 17 (and [2009] EWCA Crim 964; [2009] 2 Cr. App. R. 15)

The Court treated Horncastle as the constitutional and practical foundation for modern hearsay admissibility under the CJA 2003. It adopted the paired formulation highlighted in Riat: hearsay is acceptable where it is either “demonstrably reliable” or where its reliability is capable of proper testing and assessment. The present case fell into the second category: the statements were not “demonstrably reliable” on every issue (not least because of an inconsistency), so the correct question was whether the jury would have sufficient material to test and assess reliability safely.

R v. Riat [2012] EWCA Crim 1509; [2013] Cr. App. R. 2

Riat provided both the governing approach and the practical checklist. The Court of Appeal in the present case did not depart from Riat; rather, it recast the six steps to avoid the kind of “tunnel vision” that can arise if step (ii) (testing material) is treated too narrowly as “s.124 material only”, and to ensure disclosure is operationally foregrounded.

The Court relied particularly on Riat at [18] (the expectation of “very full enquiries” and disclosure where prosecution hearsay is important), and treated the prosecution’s failure to deploy obvious testing material (notably body-worn video first accounts) as a serious deficiency.

R v Ali [2024] EWCA Crim 77

The Court addressed a practical point: judges often rule on admissibility and, in the alternative, on exclusionary discretion. It confirmed this is legitimate and often desirable. Any contrary impression drawn from Ali should be corrected; the true difficulty in Ali was said to relate mainly to jury directions, not to the permissibility of alternative rulings.

R v.TM [2020] EWCA Crim 1343 [23]

TM reinforced that the section 125 evaluation must be conducted having regard to all the evidence. The Court used this to justify a more confident approach at the admissibility stage: the judge need not assume the worst about future testing at trial, because if—after all evidence and tailored directions—the hearsay remains so unconvincing that conviction would be unsafe, s.125 supplies a mandatory safety valve.

3.2 Legal Reasoning

(a) The appellate standard under CJA 2003 s.67

The Court reminded itself it could only reverse the hearsay ruling if satisfied it was: (a) wrong in law, (b) involved an error of law or principle, or (c) was not a ruling it was reasonable to make. It ultimately concluded the ruling failed both as a matter of legal approach and reasonableness.

(b) The “critical flaw”: underweighting independent support and the real issues

The trial judge focused on inconsistencies and credibility deficits in the deceased witnesses’ accounts—particularly the later “change of account” about why the defendants were at the flat. The Court of Appeal accepted the inconsistency was significant but held the judge misapplied the correct question: could reliability be properly tested and assessed by the jury, in light of all admissible material and the actual issues in dispute?

Central to the Court’s reasoning was the interaction between:

  • Defence statements (used legitimately to define the disputed issues): the defendants largely accepted they had been in the flat for days and had travelled together. This dramatically reduced the live significance of “stranger identification” risk.
  • Independent dovetailing/supporting evidence (videos, forensic links, car evidence, and other case features) supporting key elements of the hearsay and enabling assessment of whether the inconsistent part was a lie, a correction, or contextual reframing.
  • The fact that the changed account went largely to motive/context rather than the core question in several defences (participation/duress/role), so its existence did not automatically render the identification/participation evidence incapable of assessment.

(c) Proper use of “weaknesses” in hearsay

The Court made a subtle but important point: the judge identified flaws that were apparent on the face of the statements. Such flaws are not necessarily a reason to exclude; they may be reasons why the hearsay is capable of being tested—because the jury can be directed on them and evaluate them. Exclusion is not the default response to credibility issues; section 124 exists precisely so credibility attacks can be deployed despite the maker’s absence.

(d) Disclosure failures and their correct procedural significance

The Court was critical of the prosecution’s failure to assemble and disclose obvious reliability-testing material, including first accounts captured on body-worn video and materials explaining the circumstances of the later statement. While acknowledging that such failures might, in an appropriate case, justify refusal of admission, the Court stressed that the correct course is often to consider whether the interests of justice require directions for a proper disclosure process rather than immediate exclusion.

(e) The error in the judge’s alternative exclusion reasoning (PACE s.78 / CJA s.126)

The judge said that if wrong about the core “testing and assessment” conclusion, he would nevertheless exclude for similar reasons under PACE s.78 / CJA s.126. The Court found this internally inconsistent: if the court is wrong and the hearsay can be safely tested and assessed, the judge must identify some additional, coherent basis for discretionary exclusion. Simply repeating the rejected reasoning is not a proper step (v) analysis.

(f) A court-driven s.125 safety culture

The Court emphasised that section 125 is a statutory duty and should be considered by the court even if not raised by the parties. It suggested it will commonly be best assessed at the end of the evidence (often close to when tailored directions are being finalised), so that “safety” is assessed in light of the full evidential picture and the actual directions the jury will receive.

3.3 Impact

  • Disclosure is operationally elevated: the Court’s reformulation makes explicit that a prosecution hearsay application in an important case should not be determined without the prosecution demonstrating it has gathered and disclosed the material that enables reliability assessment. Practically, this invites more robust case management at an early stage and reduces the risk of late collapse.
  • “Testing material” is broader than s.124: while s.124 remains central for credibility attacks, courts must also weigh independent dovetailing/supporting evidence and issue definition (including defence statements) when deciding whether hearsay can be safely assessed.
  • Greater emphasis on s.125 as a safety net: trial judges are encouraged to view admissibility as part of a continuum, with s.125 providing a mandatory backstop if the hearsay ultimately proves too unconvincing in context.
  • Clarification on alternative rulings: judges may rule through multiple routes (admission/exclusion), provided the reasoning is coherent and not circular; this should reduce unnecessary appellate debate about form and focus attention on substance.

4. Complex Concepts Simplified

Hearsay
A statement made outside the trial that is relied upon to prove the truth of what it asserts. Because the maker is absent, the opposing party cannot cross-examine in the usual way.
“Demonstrably reliable” vs “capable of proper testing and assessment”
The Horncastle/Riat pairing: some hearsay is so strongly supported that it is plainly reliable; more commonly, the question is whether the jury will have enough tools (contradictions, credibility material, supporting evidence, context) to judge reliability safely.
CJA 2003 s.124 (Credibility)
Allows the parties to adduce material that would ordinarily be used to challenge a witness’s credibility, even though the maker cannot be cross-examined. Its existence signals that credibility problems do not automatically make hearsay inadmissible.
PACE 1984 s.78 and CJA 2003 s.126 (Exclusion)
Even if evidence is admissible through a statutory “gateway”, the court may exclude it where fairness (PACE s.78) or other statutory considerations (CJA s.126) require it. But exclusion must be justified by reasoning distinct from a rejected “not capable of assessment” conclusion.
CJA 2003 s.125 (“Stop the case”)
A mandatory safeguard: if, after the prosecution case (or later), the hearsay is so unconvincing—given its importance—that conviction would be unsafe, the judge must withdraw the case (acquit or discharge for retrial). The Court stressed this should be considered by the court even if the parties do not ask.
PROMAT identification procedure
A structured identification process used by police (often video-based). Its reliability can be evaluated alongside other evidence, including whether the witness had prior familiarity with the suspect.
“Cuckooing”
A form of exploitation commonly associated with drug supply (“county lines”), where offenders take over a vulnerable person’s home to use it as a base for dealing.

5. Conclusion

[2024] EWCA Crim 1874 is best read as a rigorous application of Horncastle and Riat with a strong practical message: courts should not decide hearsay admissibility in a disclosure vacuum, should evaluate “testing material” broadly (including independent support and the live issues), and should treat s.125 as an ever-present statutory safety mechanism.

The reformulated seven-step checklist crystallises these points into a usable structure for trial judges and advocates, and—coupled with the Court’s criticism of inadequate credibility enquiries— raises expectations of prosecutorial preparation where hearsay is important to contested facts.

Appendix: The Court’s Reformulated “Riat Steps” (High-level)

  1. Disclosure sufficiency to assess reliability/testing; directions for proper disclosure if needed.
  2. Is there a gateway (CJA 2003 ss.116–118)?
  3. What material exists to test/assess (s.124 and also independent dovetailing/support)? Consider issues and importance.
  4. Is there a specific interests of justice test at admissibility stage?
  5. If no gateway, consider s.114(1)(d) interests of justice admission.
  6. Even if admissible, exclude under PACE s.78 and/or CJA s.126 if justified.
  7. After admission, consider mandatory s.125 (often best at conclusion of evidence, in light of tailored directions).