R v Dobler - [1993] 1 NZLR 431

Criminal law — Evidence — Confessions — Admissibility — Accused contended at voir dire that he was not advised of his right to consult and instruct a lawyer without delay as required by New Zealand Bill of Rights Act 1990 - Whether onus of proof that the requisite advice was given rests upon the Crown — Whether standard of proof is beyond reasonable doubt or on balance of probabilities — Whether words of advice claimed to have been spoken as to the right to a lawyer were sufficient compliance with the Bill of Rights Act — Observations as to when rights will be held to have been waived — New Zealand Bill of Rights Act 1990, s 23(1)(b).