"Out of court statements are not evidence of the truth of what is said unless the statement falls within an exception to the rule against hearsay. One such exception admits evidence of a confessional nature against the maker. Another renders admissible a statement made by a third party, since deceased, which is against his or her pecuniary or proprietary interest.
As the law stands in this country, there is no exception to the hearsay rule which renders admissible either against or in favour of an accused hearsay evidence of a confession by a co-accused or by a third party [See, eg, In re Van Beelen (1974) 9 SASR 163; R v Szach (1980) 23 SASR 504; Wade v Gilroy [1986] FamCA 6; (1986) 83 FLR 14; R v Greatorex (1994) 74 A Crim R 496]. No Australian court, at least in any reported decision, appears to have taken the approach adopted by the Court of Appeal in England in R v Beckford [[1991] Criminal Law Review 833] that if the consequences of inadmissibility are that the jury does not hear an alternative version of the events giving rise to the charge, the conviction of an accused may be unsafe and unsatisfactory and accordingly set aside. It should be noted that in Beckford the co-accused did not give evidence and the prosecution was unable to give evidence of the confession because the trial judge held that it was not given voluntarily [In R v Rogers [1995] 1 Cr App R 374 at 381 a differently constituted Court of Appeal refused to apply Beckford on the ground that the decision 'turns upon its own special facts'].
In Lobban v The Queen [[1995] 1 WLR 877; [1995] 2 All ER 602] the Privy Council said that a judge in a criminal trial had no discretion to exclude the exculpatory part of a mixed statement containing admissions as well as an exculpatory explanation on which a defendant wished to rely, notwithstanding that the exculpatory material was prejudicial to a co-defendant. Their Lordships said that where the admission of evidence which was admissible against one defendant but not against his co-defendant resulted in real risk of prejudice to the co-defendant, the judge should ensure that the interests of the co-defendant were protected by explicit directions to the jury to the effect that the statement of one co-defendant was not evidence against the other or, in the last resort, by ordering separate trials [See also Webb v The Queen [1994] HCA 30; (1994) 181 CLR 41 at 56, 62-67, 80-81, 92-95, where the Court discussed the warning to be given when an accused gives evidence implicating another accused].
The appellant submits that while support for his submission is lacking in decisions of the Australian courts, this Court should adopt the approach taken in Canada and the United States and hold that a third party confession, at any rate a confession by a co-accused which exculpates an accused, is an exception to the rule against hearsay. The appellant prays in aid statements in decisions of this Court that the hearsay rule should not be applied inflexibly [The appellant referred to Walton v The Queen [1989] HCA 9; (1989) 166 CLR 283 at 293-294; R v Benz [1989] HCA 64; (1989) 168 CLR 110 at 117-118, 121, 143-144; Pollitt v The Queen [1992] HCA 35; (1992) 174 CLR 558 at 593-596, 609-611, 620-621]."