SUCCESSIVE CONFESSIONS AND THE POISONOUS TREE

The English common law rejects, as a general rule, the doctrine known in the United States as the ''fruit of the poisonous tree''. Smith [19 59] 2 Q.B. 35, a case in which the court refused to exclude a later co nfession which was arguably the fruit of an inadmissible earlier confe ssion, is a leading exemplar of that rejection. This article examines recent authority, under the statutory regime for confessions, which re jects or undermines that decision.