A statement made by a participant in a voyage to authorities upon arrival, explaining the intended destination, is inadmissible hearsay against a co-accused. Such a statement is not part of the res gestae where there has been ample opportunity for concoction, and is not an utterance in furtherance of a common purpose under the co-conspirators principle where it is merely a narrative account of a concluded event. Jones v Dunkel directions in criminal proceedings will rarely be appropriate.
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