Evidence of a police officer's dishonesty committed many years after a trial, and relating to matters unconnected with the officer's investigative duties at the time of the trial, lacks the materiality and cogency required to constitute fresh evidence capable of overturning a conviction. The closer the suggested adverse conduct is in subject matter and time to the events of the trial, the more persuasive the appellant's position; conversely, the further removed, the harder it is to demonstrate a miscarriage of justice. The discretion to reject confessional evidence on grounds of unfairness does not extend to cases where the allegation is fabrication rather than impropriety in inducing admissions.
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