R v Straffen

Facts

John Straffen had killed two small girls. The killings had peculiar features: manual strangulation, no sexual assault, no attempt to conceal the body. He was detained in Broadmoor. He escaped for about four hours. During that time a five-year-old girl, Linda Bowyer, was found dead a short distance away, killed in the same way. On his trial for her murder the prosecution proved the two earlier killings.

Issue

Are earlier offences admissible to prove identity?

Held

Yes. The Court of Criminal Appeal held that the peculiar features made the earlier killings relevant to show that the same person committed the third. The evidence was not admitted merely to show that he was a killer.

Principle

Evidence of other offences may be admitted on identity where the features are so distinctive that they point to the accused rather than to coincidence.

Why it matters

It is the identity case, beside R v Thompson. Propensity alone would not have been enough.

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