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[1952] 2 QB 911 (CA). The defendant was tried and convicted of the murder of a young girl. His identification was at issue, because other people had been in the area in which the murder took place at the relevant time. However, the defendant had admitted to murdering two other young girls. When these admissions were revealed to the jury, it was almost inevitable that they would convict.

On appeal, the defendant argued that his previous crimes were not relevant to the present charge, in the terms set out in makin v agfor new south wales (1894), and should not have been revealed to the jury.

The Court of Appeal accepted that, in general, previous criminal behaviour was not relevant to the defendant's present guilt. However, where there was a 'striking similarity' between the crimes, it would be. In the present case, all the victims were killed by manual strangulation, with no apparent motive for the murders; the bodies were not concealed; there was no sign of a struggle, nor sexual attack on the victims. These points of similarity were held to be sufficient to make the defendants past crimes evidence of his disposition to commit the offence tried.

This requirement of 'striking similarity' was maintained by the courts until it was relaxed by Dpp v p (1991).