Drugs, Money and Relevance: R v Yalman and R v Guney
| Author | Mike Redmayne |
| DOI | 10.1177/136571279900300204 |
| Published date | 01 March 1999 |
| Date | 01 March 1999 |
| Subject Matter | Case Note |
CASE
NOTE
Drugs,
money
and
relevance:
Rv
Va/man
and
Rv
Guney
By
Mike
Redmayne
BruneI
University
From
the
point
of
view
of
the
development
of
evidence
doctrine,
it is
difficult
to
claim
that
the
Court
of
Appeal's
judgments
in Yalman 1
and
Guney2
are
important.
The decisions are simply
part
of
the
rapidly
expanding
body
of
case law
concerning
the
relevance
of
various
types
of
evidence
when
defendants
are
charged
with
possessing,
supplying
or
import-
ing
drugs.
Neither
case establishes an
important
new
rule,
nor
even proposes
a
significant
re-interpretation
of
an
existing
rule.
Nevertheless,
these
cases
are
interesting
for
what
they
tell us
about
the
problems
the
courts
face
when
dealing
with
as basic
and
fundamental
a
concept
as relevance. Additionally,
because
the
cases
concern
the
admissibility
of
what
can
broadly
be
termed
lifestyle evidence, a
consideration
of
the
decisions
sheds
some
light
on
the
continuing
difficulties
caused
by
similar
fact evidence.
Va/man:
drug
use
and
importation
Yalman was
charged
with
being
knowingly
concerned
in
the
fraudulent
evasion
of
the
prohibition
on
importation
of
Class A
drugs.
He
had
met
his
elderly
father
at
Stansted
airport;
his
father's
suitcase
contained
packages
of
heroin,
and
the
prosecution's
theory
was
that
Yalman was
there
to
ensure
that
the
drugs
got
safely to
their
destination.
The
circumstances
of
the
~981
2 Cr App R 269.
I2 [19981 2 Cr App R 242.
128
THE
INTERNATIONAL
JOURNAL
OF
EVIDENCE
&
PROOF
To continue reading
Request your trial