No it doesn't. That is the whole point.I know they are - they are very different, I`m not saying they aren`t. I`m just saying the basic right to silence and the right not to incriminate oneself applies in both countries.
The right of silence is very different in both jurisdictions .
At basic level in one jurisdiction adverse inferences may be drawn in certain circumstances, in the other no adverse inferences can be drawn.
Notice any difference yet?
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