R v Tindle [2011] EWCA Crim 2341, (2011) 175 JP 462 - Ss 114 and 116 CJA 2003.
1) s 116, enabling statement to be admissible in absence of witness, is circumvented if applied when attendance of witness could reasonably have been secured.
- not in interests of justice to admit such evidence under s 114(1)(d) having regard to s 114(2)(g).
2) having regard to s 114(2)(c) it would be rare for crucially important evidence to be adduced as hearsay when a failure to take reasonable steps to secure attendance of witness.
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