Being arrested and taken into police custody can be an unsettling experience. Finding yourself in a police station unsure of what is happening or how long you may be kept there, can leave you feeling powerless and uncertain about what to do next. However, being in police custody does not mean that you are without rights. The police must follow specific rules when detaining and questioning you and understanding those rules can be important in protecting your position. One of the main protections is the Police and Criminal Evidence Act 1984 (PACE) and its accompanying Code C. Code C sets out the rules governing the detention, treatment and questioning of suspects in police custody in England and Wales. What is PACE Code C? PACE Code C is a Code of Practice that sets out how the police should deal with people who are detained at a police station. It covers a range of issues, including your right to legal advice, reviews of your detention, medical care, rest, police interviews and additional safeguards for children and vulnerable people.  The purpose of these rules is to make sure that people in police custody are treated fairly and that detention does not continue when there is no longer a need for it. Code C also makes clear that people in custody should be dealt with as quickly as possible and released as soon as the need for their detention no longer applies. How long can the police detain you without charge? In ordinary circumstances, the police can detain you for up to 24 hours without charging you. At that point, they must normally either charge you or release you. However, 24 hours is not a period that the police are automatically entitled to use. They must continue to have lawful grounds for keeping you in custody. For certain indictable offences, detention can be extended beyond 24 hours. A superintendent can authorise detention for up to 36 hours without charge, provided the legal requirements are met. Further detention requires a warrant from a magistrates’ court.  The exact calculation of the detention period can depend on the circumstances of the arrest. If you are unsure how long the police are entitled to keep you, a solicitor can advise you on your position. Can the police keep me at the station if I have not been charged? Yes, but there must be a lawful reason for continuing to detain you. Being arrested does not give the police an unlimited right to keep you at the station. They must continue to consider whether detention is necessary and should release you when there is no longer a need to keep you in custody. You should be told why you have been arrested and why you are being detained. Important decisions about your detention should also be recorded in the custody record. The fact that the police investigation is still ongoing does not, by itself, mean that you can simply be kept in custody indefinitely. What are my rights when I arrive at the police station? When you are taken into custody, the police should explain a number of important rights to you. These include: You should also be told what offence you have been arrested for and why you have been arrested and detained. If you are unsure about what you have been told, you can ask the custody officer or your solicitor to explain it. Do I have a right to a solicitor while detained? Yes. You have a right to free legal advice while you are detained at a police station. The advice is independent of the police. If you ask for legal advice, the police should arrange it without delay unless one of the limited exceptions allowing a delay applies. Importantly, the police should not try to discourage you from getting legal advice. Code C specifically states that officers should not do or say anything intended to discourage a person from exercising their right to legal advice.  A solicitor can speak to you privately before an interview, explain what you are accused of and advise you about how the interview should be approached. Speaking to a solicitor before answering questions is one of the most important steps you can take while at the police station. What if I am under 18 or vulnerable? Children and vulnerable adults have additional safeguards while in police custody. In relevant circumstances, the police must arrange for an appropriate adult to assist the detainee. The appropriate adult’s role is to help safeguard the person’s rights and welfare and to help them understand what is happening. An appropriate adult can also be involved during police interviews and detention reviews. If you are concerned that you or someone you know may be vulnerable, it is important to tell the custody officer. The police should consider whether additional support or medical assistance is required. Can the police question me while I am detained? Police detention will often allow officers to investigate an alleged offence, including by conducting a police interview. However, the interview must be conducted in accordance with PACE and the relevant Code of Practice. You should not assume that you must answer questions without first obtaining legal advice. A solicitor can explain the allegation; tell you what information the police have disclosed and advise you about the interview considering the circumstances of your case.If you have requested legal advice, Code C generally prevents the police from interviewing you until you have received that advice, subject to limited exceptions.  Can the police keep me after I have been charged? The position changes once you have been charged. In some cases, you may remain in custody after being charged. In others, you may be released on bail or otherwise released from the police station. The decision will depend on the circumstances and the applicable legal requirements. Being charged does not automatically mean that you will remain in a police cell until your first appearance at court. What happens if the police want to keep me for longer than 24 hours? If the police

Corrupt Police Officers and Unsafe Convictions: What Happens When an Officer Is Later Convicted? What happens when a police officer involved in securing a criminal conviction is later found to have been seriously corrupt or dishonest? A later conviction of the officer does not automatically make every case they worked on unsafe. However, if that officer played an important role in the investigation or prosecution, their misconduct may raise serious questions about the evidence used against the defendant, what information was disclosed to the defence and whether the conviction can still safely stand. Those issues are at the heart of “Trew’s Law”, a proposed reform launched on 10 September 2026 by criminal justice organisation APPEAL and researchers at the University of York. The proposal would create a system for automatically identifying and independently reviewing cases involving serving or former police officers who receive an immediate prison sentence, where they played a material role in previous cases. The case behind Trew’s Law The proposed law is named after Winston Trew, one of the “Oval Four”, who was wrongfully convicted in 1972 following an investigation involving British Transport Police detective sergeant Derek Ridgewell. Trew has spent decades seeking to clear his name, and the wider Ridgewell scandal has exposed how police misconduct and corruption can continue to affect convictions long after the officer involved has left the force or been imprisoned. Ridgewell was convicted in 1980 of conspiracy to steal goods in transit and sentenced to seven years’ imprisonment. Despite his conviction and imprisonment, no systematic review of the cases in which he had played a central role took place. Since 2018, 13 people have had convictions linked to Ridgewell overturned by the Court of Appeal. The CCRC has since referred two further Ridgewell-related convictions, bringing the total number of referrals to 15 by April 2026. The significance of the Ridgewell cases is therefore not simply historical. They demonstrate how the consequences of police misconduct can remain undiscovered in individual cases for many years. The central question behind Trew’s Law is whether the state, rather than individual defendants, should bear responsibility for identifying potentially affected convictions. What would Trew’s Law actually do? Trew’s Law is not currently law. It is a proposal for legislative reform which would require an automatic review process to begin when a serving or former police officer receives an immediate prison sentence. The proposed system would then identify finalised criminal cases in which that officer played a material role and subject those cases to independent triage or review. This would not mean that every conviction involving such an officer would automatically be overturned. The purpose would be to identify cases in which the officer’s integrity may have had a meaningful bearing on the safety of the conviction. That could include circumstances where the officer gave important evidence, handled significant evidence or investigative material, prepared important documents or was involved in matters relevant to disclosure. The distinction is important. A police officer may have had only a peripheral or administrative involvement in a case, in which event their later misconduct may have little or no bearing on the conviction. The proposed system is instead intended to identify cases where there is a genuine reason to examine whether the officer’s conduct could have affected the evidence, the fairness of the proceedings or the reliability of the conviction. Where a material risk to the safety of a conviction is identified, the proposal would provide for the affected person to be notified and for relevant information to be made available so that appropriate legal advice can be obtained. Does a corrupt police officer automatically make a conviction unsafe? No. The question is not simply whether the officer was later convicted of an offence, but what that misconduct means for the particular conviction. For example, if an officer was later convicted of dishonesty and had played a central role in obtaining evidence, giving evidence or dealing with material that was important to the prosecution case, the subsequent discovery of that misconduct could be highly significant. It may raise questions about the reliability of the officer’s evidence, the integrity of the investigation or whether relevant information about the officer should have been disclosed to the defence. The CPS’s current guidance recognises that information concerning police misconduct can be relevant to disclosure and that developments affecting the credibility or integrity of prosecution witnesses may need to be considered. By contrast, the mere fact that an officer was involved in a case will not necessarily justify reopening it. The nature of the officer’s involvement, the evidence they dealt with, the misconduct for which they were convicted and the effect, if any, on the defendant’s case would all need to be considered. There are already legal routes for challenging potentially unsafe convictions. The Court of Appeal can allow an appeal against a conviction where it considers the conviction to be unsafe, while the Criminal Cases Review Commission can investigate cases and, where the statutory test is met, refer convictions back to the appeal courts. The existence of a later police conviction does not itself overturn an earlier defendant’s conviction; the connection between the misconduct and the safety of that particular conviction still has to be established. Why does this matter now? The research behind Trew’s Law suggests that the issue extends well beyond the Ridgewell cases. The University of York and APPEAL report states that at least 64 serving or former police officers went to prison between 2023 and 2026 for offences including serious dishonesty, corruption, violence, sexual offending and abuse of position. The researchers also identified the absence of a central system recording when serving or former police officers are imprisoned and whether their previous cases are subsequently reviewed. That creates an obvious difficulty. A person convicted years earlier may have no reason to know that a police officer involved in their case was subsequently imprisoned for serious misconduct. Without a system for identifying those connections, the issue may only come to light if the

When a criminal offence involves several people, it is easy to assume that everyone involved will be treated in the same way when they are sentenced. That is not necessarily the case. The courts recognise that people can have very different levels of responsibility within the same offence, and the role played by an individual can be an important part of assessing their culpability and determining the appropriate sentence. The terms “leading role”, “significant role” and “lesser role” are particularly important where offending has involved a group, gang or organised criminal activity. They are especially familiar in drug cases, including cases involving county-lines offending, but the underlying principle is much wider. Similar concepts appear in sentencing guidelines dealing with offences such as robbery, firearms offences and handling stolen goods. The precise approach depends on the offence and the sentencing guideline that applies. One point, however, is fundamental: being part of a group does not automatically mean that a defendant had a leading role. The Sentencing Council states that mere membership of a group should not itself be used to increase a sentence. The court must consider the defendant’s individual involvement and culpability. What do “leading role”, “significant role” and “lesser role” mean? At its simplest, the distinction concerns what the defendant actually did, the level of responsibility they had and their position within the offending. Someone who planned and directed an operation, exercised substantial influence and made important decisions will generally be viewed differently from someone who carried out a limited task under instruction. Between those two positions may be someone who had an operational or management function and played an important part in the offending without controlling the operation as a whole. The Sentencing Council’s General Guideline uses role as one of the factors relevant to assessing culpability. Its general model refers to a leading role at a higher level of culpability, a significant role at a middle level and a minor role as one factor indicating lower culpability. The Council makes clear, however, that these general models do not apply identically to every offence. That distinction in terminology matters. In its specific guidance on group offending, the General Guideline refers to a “lesser or subordinate role”, while a number of offence-specific guidelines use “lesser role” as the relevant category. The drug-supply guideline, for example, expressly uses the three categories of leading role, significant role and lesser role. The terms should therefore not be treated as universal statutory labels which apply in exactly the same way to every offence. The applicable sentencing guideline must always be checked. What is a leading role? A leading role generally indicates a high level of responsibility, influence or control within the offending. Depending on the offence, this can involve directing or organising other people, exercising substantial influence over participants, making important decisions, significant planning or occupying a key position within an organised criminal operation. In a drug-supply case, for example, a person who organises the buying and selling of drugs on a commercial scale, has substantial links to and influence over others in the supply chain, or has close links to the original source may have characteristics indicating a leading role. The expectation of substantial financial or other advantage can also be relevant. A leading role is not determined by one factor alone. A person does not automatically become the leader simply because they made money, knew other people involved or happened to have a particular title within the group. The court must assess the relevant characteristics together and reach a fair assessment of culpability. What is a significant role? A significant role generally falls below a leading role but can still involve substantial participation in the offending. The defendant might have an operational or management function, coordinate part of the activity, involve other people or exercise influence over what happens. They may be responsible for an important part of an operation without having overall control. For example, in a drug operation one person might control the overall supply while another manages several couriers, organises deliveries and communicates with customers. The second person may have a significant role even though they are not the person controlling the operation as a whole. The defendant’s knowledge can also be relevant. Someone who understands the scale and nature of a substantial operation may be viewed differently from someone carrying out an isolated task without understanding the wider activity. Under the drug guideline, an expectation of significant financial or other advantage can also indicate a significant role, although being paid does not automatically make a person’s role significant. What is a lesser role? A lesser role generally indicates lower culpability when compared with those who played a more substantial or influential part in the same offending. In the General Guideline’s group-offending provisions, this is described as a “lesser or subordinate role”. A typical example is someone who performs a limited function under the direction of others. They may have little influence over those above them, limited knowledge of the wider operation and little understanding of its overall scale. A lesser role may also be indicated where the defendant became involved through pressure, coercion, intimidation, grooming, control or exploitation. The circumstances in which someone became involved can therefore be highly relevant to sentencing. Importantly, “lesser role” does not mean “innocent”. A person can be guilty of a serious offence while still having played a lesser role in the offending. The issue at sentence is the defendant’s level of culpability, not whether they were involved at all. It is also important not to confuse “lesser role” with “minor role”. “Minor role” appears in the General Guideline’s general model of culpability. “Lesser role” is the terminology expressly used in a number of offence-specific guidelines and “lesser or subordinate role” is used when the General Guideline discusses group offending. The wording of the relevant guideline should therefore be followed. Does being part of a gang automatically mean a leading role? No. The Sentencing Council expressly states that mere membership of

Being released on bail can be a huge relief, particularly after spending time in police custody or appearing before a court. For some defendants, however, release comes with strict conditions, including a requirement to remain at home during certain hours and an electronic tag to monitor compliance. It is often at this point that an important question arises: does the time spent on curfew count towards any sentence I might receive? The answer depends on the type of curfew and the circumstances in which it was imposed. A bail curfew is not automatically a qualifying curfew, and simply wearing an electronic tag does not by itself guarantee sentence credit. The distinction can become particularly important where a defendant remains on bail for a lengthy period before their case is concluded. This article explains what a qualifying curfew is, how the credit is calculated, what can happen if a curfew is breached, and how a bail curfew differs from a curfew imposed as part of a sentence. What is a curfew on bail? When a defendant is released on bail, the court can impose conditions where the legal requirements for doing so are satisfied. One possible condition is a curfew requiring the defendant to remain at a specified address, or addresses, during particular hours. For example, a defendant might be required to remain at home between 9pm and 7am. That is a ten-hour curfew. A bail curfew is a restriction imposed while the criminal proceedings are still ongoing. It is not a punishment and does not mean that the defendant has been convicted. The defendant remains on bail and must comply with the conditions imposed by the court. A curfew can also be accompanied by electronic monitoring, with an electronic tag being used to check compliance with the underlying curfew condition; the tag itself does not create the curfew. There is no general statutory minimum or maximum number of hours for a bail curfew. The significance of the nine-hour threshold arises when considering whether the curfew can qualify for the statutory sentence-credit provisions. A defendant can therefore have a perfectly valid bail curfew which does not qualify for this particular form of credit. What is a qualifying curfew? A qualifying curfew is a bail curfew which satisfies the requirements of the law allowing certain periods on bail to count towards a later custodial sentence. One of the central requirements is that the bail condition requires the defendant to remain at one or more specified places for a total of at least nine hours in any given day. The bail must also be subject to the relevant electronic monitoring condition. The nine-hour requirement is therefore important, but it is not the entire test. For example, a curfew from 8pm to 4am is eight hours and does not meet the duration requirement, while a curfew from 10pm to 7am is nine hours and meets that particular requirement. A curfew from 9pm to 7am is ten hours and also meets the duration requirement. Whether a particular day ultimately produces credit depends on the wider legal calculation, including whether the relevant conditions applied and whether there were any breaches or other periods that have to be taken into account. This is why it is important not to reduce the law to the statement that “nine hours equals a qualifying curfew”. Nine hours is the minimum duration required by the relevant definition, but the entitlement to credit depends on the legal requirements as a whole. The actual bail order, the electronic monitoring arrangements and the history of compliance may all need to be examined. Does the curfew have to be electronically monitored? For the statutory credit against a subsequent custodial sentence, the qualifying curfew must be accompanied by the relevant electronic monitoring condition. Electronic monitoring allows compliance with the curfew requirement to be checked and provides information which can later be used when working out the qualifying period. Depending on the monitoring arrangement, this may involve a radio-frequency tag monitoring whether the defendant is at the specified address during the curfew hours. Other electronic monitoring technology can be used to monitor geographical conditions. The important distinction is that the electronic monitoring requirement monitors the bail condition; it does not replace the underlying condition imposed by the court. Electronic monitoring records can become particularly important when a defendant is sentenced. Information from the monitoring provider may be needed to establish the relevant days and any recorded non-compliance. The Ministry of Justice’s court bail protocol specifically provides for compliance information to be obtained where custody credit may be due. How does qualifying-curfew credit work? Where a defendant has been remanded on bail with a qualifying curfew and the relevant electronic monitoring condition, and the court subsequently imposes a determinate custodial sentence, section 325 of the Sentencing Act 2020 requires the court to specify the credit period. The calculation is more precise than simply counting the number of days between the start and end of the curfew. The law requires the court to identify the relevant days, deduct certain days covered by other electronic-monitoring requirements or temporary release, deduct relevant days on which the defendant breached the qualifying conditions, divide the resulting figure by two and, where necessary, round up to the nearest whole number. The result is the period which is directed to count towards the sentence. In practical terms, this means you cannot simply count the number of days you were tagged and divide that figure by two. The court first has to establish which days qualify, remove any days that the law says must be excluded, take account of relevant breaches and then apply the statutory calculation. This means it is not accurate to say that a defendant receives one full day of sentence credit for every day spent on a qualifying curfew. The law recognises the restriction imposed by a qualifying curfew, but the credit is calculated at half a day for each qualifying day, after the relevant deductions have been made. A worked

Being stopped and searched by the police can be an unsettling experience. You may be unsure why you have been stopped, whether the officer is actually entitled to search you, or what you are expected to do. Even where you have done nothing wrong, having an officer search your clothing or belongings in a public place can feel intrusive and, understandably, you may want to know whether the police have acted within their powers. It is important to remember that the police have significant powers to stop and search people, but those powers are not unlimited. There are legal rules governing when a search can take place, what the officer must tell you, how the search should be carried out and how long you can be detained. Understanding those rules can make a significant difference. A lawful stop and search is not the same as an unlawful one, and being searched does not, by itself, mean that you have committed an offence or that you are under arrest. This article explains the main rules that apply in England and Wales and what you should know if you are stopped and searched by the police. What is a stop and search? A  stop and search is a police power allowing an officer to stop and detain a person, or in some circumstances a vehicle, in order to search for specified articles. There is an important distinction between being stopped and being searched, because the police do not automatically acquire a power to search simply because they have approached or spoken to you. Police officers can speak to members of the public without necessarily exercising a formal stop and search power. They may ask questions about who you are, where you are going or what you are doing. In general, you do not have to answer such questions simply because an officer has asked them. A search is different: if the police are exercising a statutory stop and search power, there must be a legal basis for doing so. When can the police stop and search you? There is no single stop and search power. Different legislation gives the police different powers to search for different things and under different circumstances. One of the principal powers is section 1 of the Police and Criminal Evidence Act 1984 (PACE). Where its statutory requirements are satisfied, this allows an officer to search a person or vehicle for certain stolen or prohibited articles. Other legislation provides specific powers to search for controlled drugs, weapons and other items. The important point is that the officer must be exercising an actual legal power that permits the search in the circumstances. For searches requiring reasonable suspicion, the officer must have a genuine suspicion that the relevant item will be found and there must also be an objective basis for that suspicion. PACE Code A describes this as a two-stage test: the officer must genuinely suspect that the item will be found, and that suspicion must be reasonable when assessed against the facts, information or intelligence available. This does not mean that the police need to prove that you are carrying something before searching you. A stop and search is an investigative power, so the question is whether the legal test for the particular search has been met. The police are not required to know that an item is present before searching for it; they must instead have the level of suspicion required by the particular statutory power. What does “reasonable suspicion” actually mean? This is one of the most important aspects of stop and search law. Reasonable suspicion is more than a feeling or a hunch. The officer should be able to explain why, in the circumstances, they suspected that they would find the particular item for which they were searching. The suspicion might arise from information or intelligence received by the police, or it might arise from particular behaviour or circumstances which, taken together, provide an objective basis for the suspicion. The suspicion must also relate to what the officer is legally entitled to search for. An officer cannot use a stop and search power simply as a general investigation into whether someone might have committed an offence. Similarly, a person’s appearance, the fact that they are known to the police, or previous convictions cannot by themselves provide reasonable grounds for a search. PACE Code A specifically prevents factors such as physical appearance, protected characteristics and previous convictions from being used as the basis for reasonable suspicion, subject to the limited situation where relevant intelligence or a description identifies a person by a particular characteristic. In practical terms, this means that two people behaving in exactly the same way should not be treated differently simply because of their background or appearance. There must be a genuine and objectively reasonable connection between the circumstances and the particular item the officer suspects will be found. Can the police search you without reasonable suspicion? Sometimes, yes – but only where a specific statutory power allows it. There are circumstances in which legislation permits suspicionless stop and search, meaning that an individual officer does not need to establish reasonable suspicion about the particular person being searched. One example is section 60 of the Criminal Justice and Public Order Act 1994, which can allow searches within an authorised area in circumstances involving anticipated serious violence, weapons or dangerous instruments. The Public Order Act 2023 also introduced additional powers in relation to certain protest-related offences. These are not general powers allowing the police to search anyone, anywhere, whenever they wish. They operate subject to specific statutory conditions and authorisations. The fact that an officer does not appear to have reasonable suspicion therefore does not automatically make a search unlawful; the question is whether the officer was relying on a different power and whether the statutory requirements for that power had been satisfied. This is an important distinction because different stop and search powers have different requirements. If you are concerned about the

Mobile phones can provide an important source of evidence in criminal investigations. Police may obtain records showing when a particular phone was being used, the communications made from it and which part of the mobile network handled those communications. In some cases, this information can help establish the general area in which a phone was being used at a particular time. This is known as cell site analysis. It can be relevant in many different types of criminal case, particularly where the prosecution seeks to establish a person’s movements or suggest that their phone was in the area of an alleged offence. However, cell site evidence is often misunderstood. It is not the same as GPS tracking, it does not necessarily show the exact location of a phone and it does not automatically prove that the defendant was the person carrying the phone. Understanding those distinctions is important when assessing both the strength and the limitations of mobile phone evidence. What is cell site analysis? Mobile phone networks are divided into areas of coverage called cells. These are served by physical cell sites, commonly referred to as mobile phone masts. A single site can serve more than one area because it may have different antennas or sectors pointing in different directions. When a phone communicates with the mobile network, the network can record information about that activity. Depending on the type of communication and the records available, this can include the date and time, the phone number or other identifying information and the particular cell or sector through which the communication was handled. Cell site analysis involves examining those records to consider where the phone was likely to have been operating. The current Forensic Science Regulator’s statutory Code of Practice specifically covers cell site analysis for geolocation as a recognised forensic activity. More detailed examinations can involve analysing the network records, mapping the relevant cells and carrying out technical surveys to understand the coverage provided by them. Not every piece of mobile phone analysis is necessarily a full forensic cell site examination. Police may also use communications data simply to investigate a case or establish a chronology. The current forensic framework distinguishes this investigative analysis from a formal cell site analysis undertaken to provide a geographical opinion for evidential purposes. Does a phone always connect to the nearest mast? No. This is one of the most common misconceptions about cell site evidence. A mobile phone does not simply connect to whichever mast happens to be physically closest. The connection can be affected by the strength of the signal, the way the network has been designed, buildings, hills and other geographical features, as well as the amount of traffic being handled by the network. A phone can therefo re connect to a cell which is not the nearest physical site. This does not mean that cell site evidence is unreliable. It means that the evidence has to be understood properly. The fact that a phone connected to a particular cell can be useful evidence, but what that connection tells us about the phone’s location depends upon the particular network and the technical evidence available. What information can the police obtain? Cell site analysis commonly involves communications data, including information often referred to as Call Data Records or CDRs. These are records held by communications providers which can contain information about communications and the network connections involved. The precise information available depends upon the provider, the type of communication and the relevant period. Records can include information relating to telephone calls, text messages and certain forms of data activity, together with the relevant times and network information. The acquisition of communications data is governed primarily by Part 3 of the Investigatory Powers Act 2016, together with the applicable Communications Data Code of Practice. The legislation and Code provide an important framework for the lawful acquisition and disclosure of communications data and set out safeguards governing its acquisition. Other forms of lawful authority may also apply in particular circumstances. It is important to distinguish network records from information taken directly from a phone. If police seize a handset, it may contain messages, photographs, application data, location information and other material which is not contained in the network provider’s records. Communications made through applications or over Wi-Fi can also produce different types of evidence. The CPS recognises that the information available from a provider may differ where communications are made through applications such as WhatsApp or where Wi-Fi is being used. What can cell site analysis actually show? At its most basic level, cell site analysis can help establish the general area in which a phone was operating at a particular time. A sequence of records can sometimes also help investigators examine whether a phone appears to have moved between different areas. In appropriate cases, the records from two phones can be compared when considering whether their movements may have been connected. The amount of information that can be obtained from the records will vary considerably from case to case. The CPS explains that cell site analysis can determine the general location of a SIM-enabled device, but that it may not identify a specific location such as a particular address or street. The current Forensic Science Regulator Code likewise recognises the uncertainty involved and makes clear that cell site analysis cannot pinpoint the precise location of the device. This distinction is important. Evidence that a phone used a cell which served an area containing the location of an alleged offence is not automatically evidence that the phone was at the precise location of that offence. There is an even further step between showing where a phone was operating and proving that the defendant was physically there. Similarly, a series of cells used by a phone may support an inference that the phone travelled between areas, but it will not necessarily establish the precise route taken or every location at which the phone stopped. The conclusion must reflect what the underlying evidence can properly