Trial
Adams was first tried for the murder of Morrell, with the Hullett charge to be prosecuted afterwards. The trial lasted 17 days, the longest murder trial in Britain up to that point. It was presided over by Mr Justice Sir Patrick Devlin. Devlin summed up the tricky nature of the case thus: "It is a most curious situation, perhaps unique in these courts, that the act of murder has to be proved by expert evidence.”
Hunnam was apparently shocked by the choice to try Adams for the murder of Morrell first. Morrell had been dead for a few years, her body had been cremated, and she was 81 at the time of her death. The much more recent death of Hullett, who died aged 50 without suffering from any somatic illness and whose body had not been cremated (and contained twice the fatal dose of barbiturates) would have made a much more convincing case.
The prosecution relied on three main bases: the amounts of opiate drugs prescribed by Adams for Mrs Morrell, Adams's verbal admission that he had himself injected almost all the amounts prescribed and statements taken from Mrs Morrell's nurses in August and November 1956. The statements of nurses Stronach and Randall suggested that Adams had increased the frequency of injections and the amount of each injection throughout the period they had nursed Mrs Morrell, and that many of the injections Adams gave were of drugs taken from his bag, which he had prepared himself rather than asking the nurses to prepare, and they were unaware of the contents of these injections. These two nurses repeated these allegations when questioned by Manningham-Buller, but under cross examination they were forced to admit that it was they and the other two nurses that usually made up the injections to be administered either by them or Adams, and that they had recorded the relatively few injections already prepared by Adams and had also recorded their nature on at least some occasions. Another nurse recalled that these were said to be vitamin injections, and it was also clear that the amounts of opiates injected were constant until September 1950, when another doctor first increased the dosage.
The leading Defence counsel Sir Frederick Geoffrey Lawrence, QC, had been briefed by the Medical Defence Union with the additional task of obtaining a ruling on whether medical treatments that might shorten the life of a terminally ill patient were legal. Lawrence, a "specialist in real estate and divorce cases [and] a relative stranger in criminal court", who was defending his first murder trial, convinced the jury that there was no evidence that a murder had been committed, much less that a murder had been committed by Adams. He emphasised that the indictment was based mainly on testimonies from the nurses who tended Mrs Morrell, and that there were discrepancies between the evidence given by different witnesses. Then, on the second day of the trial, he produced notebooks written by the nurses, detailing Adams's treatment of Morrell. The prosecution claimed not to have seen these notebooks: these differed from the nurses' recollection of events, and showed that smaller quantities of drugs were given to the patient than the prosecution had thought, based on Adams's prescriptions.
Furthermore, the prosecution's two expert medical witnesses gave differing opinions: Arthur Douthwaite was prepared to say that murder had definitely been committed (though he changed his mind in the middle of his testimony regarding the exact date), but Michael Ashby was more reticent. The defence witness and physician John Harman was adamant that Adams's treatment, though unusual, was not reckless. Finally, the prosecution was wrong-footed by the defence not calling Adams to give evidence, and thereby avoiding him "chatting himself to the gallows". This was unexpected, shocking the prosecution, causing commotion among the press and even surprising the judge. Devlin commented that the defence must have known this would cause prejudice against Adams, but the danger that Adams would be loquacious, or not able to keep to the point, would likely aid the prosecution. In addition, anything he might say could, if he were convicted, be used in a subsequent prosecution of the Hullett case.
Towards the end of his closing speech for the defence, Lawrence put the case for Adams's innocence and the faulty basis of the prosecution case, saying:
Trying to ease the last hours of the dying is a doctor's duty and it had been twisted and turned into an accusation for murder.
Mr Justice Devlin received a phone call from Lord Goddard, the Lord Chief Justice, at the time defence and prosecution were making their closing speeches. In the event of Adams being acquitted, Lord Goddard suggested that Devlin might consider an application to release Adams on bail before the Hullett trial, which was due to start afterwards. Devlin was at first surprised since a person accused of murder had never been given bail before in British legal history, but was willing to entertain the idea and, on consideration, saw its merit as showing strong judicial displeasure over the Attorney-General's plan to proceed with the second indictment. Goddard, as Lord Chief Justice, had a responsibility for the conduct of all courts in England and Wales, from magistrates' courts to the Court of Appeal and was entitled to give Devlin his views on the case.
On 9 April 1957, the jury returned after 44 minutes to find Adams not guilty.
Use of the nolle prosequi
After the not guilty verdict on the count of murdering Morrell, the normal process would have been to bring the indictment regarding Mrs Hullett to trial—either a full trial or, in view of the acquittal in Mrs Morrell's case, a speedy one—so that Adams would plead not guilty. After such a plea, the Attorney-General would offer no evidence and the judge would direct the jury to bring in a not guilty verdict, which was the course Devlin expected. However the Attorney-General, as a minister of the Crown, had the power to suspend an indictment through a nolle prosequi, something which Devlin said had never been used to prevent an accused from an acquittal, suggesting this was done because Manningham-Buller did not want a second acquittal and adverse verdicts in both the cases he had indicted. Nolle prosequi could legitimately be used in cases to protect a guilty person granted immunity to turn Queen's evidence or to save the lives of the innocent, or sometimes on compassionate grounds.
Devlin later referred to Manningham-Buller action as "an abuse of process", saying: "The use of nolle prosequi to conceal the deficiencies of the prosecution was an abuse of process, which left an innocent man under the suspicion that there might have been something in the talk of mass murder after all".
Manningham-Buller later told Parliament after the Morrell trial that the publicity which attended the Morrell trial would make it difficult to secure a fair trial on the indictment relating to Mrs Hullett, and that the second case depended very greatly on inference, which was not supported by admissions, as in Mrs Morrell's case. This was a reference to Adams's admission that he had himself administered most of Mrs Morrell's opiate injections, whereas he had only said in his statements to the police that he had handed two barbiturate tablets to Mrs Hullett each day, and said nothing to link the total of barbiturates supplied to prescriptions he had issued.
Claims of prejudice and political interference in the trial
Cullen claimed that there was considerable evidence to suggest that the trial was "interfered with" by those "at the highest level", although the available evidence amounts at best to suspicion. For example, during the committal hearing for Adams in January 1957, Lord Goddard, the Lord Chief Justice, was seen dining with Sir Roland Gwynne (Mayor of Eastbourne from 1929 to 1931) and the Chairman of the local panel of magistrates, and ex-Attorney General Sir Hartley Shawcross, a member of the opposition, at a hotel in Lewes. As Lord Chief Justice, Goddard had a responsibility for the conduct of all courts in England and Wales, from magistrates' courts to the Court of Appeal and the subject of their conversation is unreported and unknown.
The reasons for this supposed interference alleged by Cullen include concerns of the effect on the medical profession of a doctor being sentenced to death for prescribing certain medication in the course of treating patients at a time when doctors were already disaffected with the NHS. The case was "very important for the medical profession", as the Attorney-General, a government minister, had created the threat of a death sentence by indicting Adams for two murders, an unusual practice in 1957. Other reasons suggested, with no direct relationship to the medical profession, were the Suez Crisis, which caused Anthony Eden to resign in January 1957, to be replaced by Harold Macmillan's initially insecure government, and links to Harold Macmillan personally, through the death on 26 November 1950, over six years before the trial, of The 10th Duke of Devonshire, Harold Macmillan's brother-in-law, who had been treated by Adams at the time of his death. Cullen's supposition that the Attorney-General deliberately sabotaged a trial, which the available evidence showed he wanted to win, to please his political masters, or that Macmillan's family affairs had any bearing on the trial, are dismissed by a later researcher as "ludicrous" and completely unsupported by credible evidence.
There is also considerable evidence of negative and prejudicial press coverage of the case. From the start of the Eastbourne Police investigation, in addition to rumours picked up from local residents, journalists had been briefed by the local Chief Constable about the suspicious nature of Mrs Hullett's death and possible links with other deaths. The Daily Mail in particular went so far as to link Bodkin Adams with what had become a murder investigation by stating that the police had interviewed him, and the Daily Mirror added that four other cases of Adams's were being investigated in connection with the Hullett's enquiry. Once the case had been passed to the Metropolitan Police, Percy Hoskins, who had resisted the general press condemnation of Adams, was contacted by an Assistant Commissioner of the Metropolitan Police on the basis that what had emerged from the Eastbourne investigation did not warrant the apparently concerted press campaign. Hoskins later exposed a police campaign to plant stories prejudicial to Adams in national newspapers, particularly the Daily Mail, whose reporter was briefed by Hannam personally. Hannam was asked by his police superiors in October 1956 to do what he could to deal with the gossip that had arisen and, at the time of Adams's arrest on 19 December 1956 (and aware of his superiors' criticisms of his relationship with the press), he attempted to distance himself from their activities.
Discovery of the nurses' notebooks
On the second day of the trial, the defence introduced eight notebooks of the daily records made by nurses who had attended Mrs Morrell under Adams's directions. These were not available to the prosecution when the trial started, so that Manningham-Buller had no chance to consider their contents before the defense began to use them in the cross-examination of the first nurse appearing for the prosecution. He was, however, presented with a copy of them by the defense later in the second day of the trial. These books were then used by the defense to counter the witness statements and evidence in chief given by the nurses who had originally written the notes. Comments in the nurses' witness statements which were prejudicial to Adams were disproved by reference to their contemporaneous notes. Six years after the event, the notes could be said to be more reliable than the nurses' own memories. However, Devlin noted the witness statements that supported Hannam's theories were taken by Hannam and his team, and that doing this accurately may have been beyond Hannam's powers.
The defense was not required to explain how the books came into their hands, and the Attorney-General neither made any effort to pursue this matter nor asked for an adjournment to acquaint himself with the new evidence, although Devlin later said that he would have been willing to grant it, had Manningham-Buller requested one. His reticence was perplexing, since the Attorney-General was known for his doggedness. As Lord Devlin later said of him: "He could be downright rude but he did not shout or bluster. Yet his disagreeableness was so pervasive, his persistence so interminable, the obstructions he manned so far flung, his objectives apparently so insignificant, that sooner or later you would be tempted to ask yourself whether the game was worth the candle. And if you asked yourself that, you were finished." Manningham-Buller did, however, claim in his closing speech that Adams may have influenced or corrupted the nurses to ensure they had not made entries that might incriminate him, an issue that Devlin noted had not been suggested to any of the nurses when they gave evidence.
Robins was allowed access both to the archives of Herbert James, the friend and solicitor of Adams, and to Lord Devlin's private papers on the trial, which included Devlin's observation that James had found the notebooks after the police office that had conducted the search had failed to notice them. Herbert James' archives showed that he had found the nurses' notebooks in Adams's surgery on 24 November 1956, after the Eastbourne police had visited the surgery and carried out a search, after which they had taken Adams to Eastbourne police station for questioning. James' intention was to carry out his own search for anything that might either help or incriminate Adams and which had been missed by the police, and he found the notebooks.
Devlin criticized Hannam and his team for overlooking the nurses' notebooks, in a passage that confirms that he was aware how the notebooks were found, adding that Adams had said his records for Mrs Morrell were filed under "M" in his filing cabinet, but they had been moved later so that the police did not find them, whereas a more thorough search did. Cullen states that the notebooks were recorded in pre-trial police records but were not in the hands of the prosecution when the trial started, adding that Adams had given three conflicting explanations for how he came to have the notebooks in 1950, although he certainly had them in 1956. The first explanation was that they were given to him by Mrs Morrell's son, who had found them among her effects, and Adams then filed them away at his surgery; next that they were delivered anonymously to his door after she died; or, finally, they were found in the air raid shelter at the back of his garden. Cullen noted that a claim that the notebooks were overlooked in the police search on 24 November 1956 but found by the defence team in Adams's surgery on the same evening was inconsistent with the list of exhibits for the Committal Hearing given by the police to the DPP's office, which mentioned the notebooks. She suggests that the Attorney General must therefore have known they existed, and, according to her, that this showed "that there was a will at the highest of levels to undermine the case against Dr Adams." However, Devlin mentions that it was the responsibility of suitably qualified solicitors and barristers in the Director's office to prepare the brief from the police report, not the personal responsibility of the Attorney General, so basing such a serious claim of interference on discounting the only available account of their finding and a misunderstanding of the prosecution process shows its weakness.
Suspicious cases
At an early stage in the investigation, Hannam believed he had found Adams's modus operandi: that he first made his victims drug addicts, then influenced them to change their wills in his favour and finally gave them a lethal dose of opiates. He concentrated on those cases where Adams had been left legacies or given gifts, or had apparently stolen items from the deceased, even when the medical evidence was doubtful. Hannam confided to a reporter at this time that he was convinced that Adams was a serial killer who had killed fourteen people. Between August and October 1956, Hannam collected a significant number of witness statements, mainly from relatives of Adams's deceased former patients who claimed that these had been heavily drugged by Adams, were injected with unknown substances and had become comatose or unresponsive.
By mid October 1956, Hannam had drafted his initial report for his Chief Superintendent. His interim report on his investigation of October 1956 includes his strong suspicions both of narcotic poisoning in several cases and of Adams inducing patients to make or change their wills in his favor. What Hannam considered were a significant number of suspiciously sinister events were bolstered, in his report by statements made by Adams about Mrs Hullett's death that Hannam regarded as incriminating. Hannam's Chief Superintendent was initially dismissive of the case he had presented, considering it was speculative, based on rumour and could not be proved; the Commander of 'C' Division agreed, and the Director of Public Prosecutions asked Hannam to obtain more evidence. In January 1957. Hannam obtained further statements from Nurse Stronach and Nurse Randal, later prosecution witnesses in the Morrell case, which were more specific and more damaging to Adams. The nurses claimed in particular that they were generally unaware of what he was injecting. The statements gathered both before and after Hannam's initial report have often been quoted in support of Adams's guilt, but in the Morrell case, the nurses' own notebooks showed that the testimony in their statements were at best misremembered, at worst untrue.
The police focused on cases after 1946, and statements were taken on oath only in four cases (Mrs Morrell, Mr and Mrs Hullet and one dealing solely with offences relating to prescriptions, cremation forms and dangerous drugs register). In other cases, Hannam had taken verbal statements, although Devlin doubted his ability to take statements that could be used in evidence without revision.
Principal cases
Cullen mentions Mrs. Morrell, Mr and Mrs Hullett, Clara Neil Miller and Julia Bradnum as cases that Hannam regarded as warranting prosecution. Details about Mrs Morrell and Mrs Hullett are given above: the case of Mr Hullett and the two cases where police suspicions led to exhumations indicate that there was insufficient evidence of the cause of death to warrant a prosecution.
11 May 1952 – Julia Bradnum died aged 85. The previous year Adams asked her if her will was in order and offered to accompany her to the bank to check it. On examining it, he pointed out that she had not stated her beneficiaries' addresses and that it should be rewritten. She had wanted to leave her house to her adopted daughter but Adams suggested it would be better to sell the house and then give money to whomever she wanted. This she did. Adams eventually received £661. While Adams attended to this patient, he was often seen holding her hand and chatting to her on one knee.
The day before Bradnum died, she had been doing housework and going for walks. The next morning she woke up feeling unwell. Adams was called and saw her. He gave her an injection and stated "It will be over in three minutes". It was. Adams then confirmed "I'm afraid she's gone" and left the room.
Bradnum was exhumed on 21 December 1956. Adams had said on the death certificate that Bradnum died of a cerebral hemorrhage, but Francis Camps examined her remains and was unable to find evidence either to prove or disprove this, stating that, because of the advanced degree of decomposition of the corpse, the brain was not in a condition to be assessed. Had the final injection given to Mrs Bradnum been morphine, heroin or barbiturates, this might have been apparent from the liver, but Camps did not order toxicology tests, considering he could not be sure in the state of the internal organs what comprised the remains of the liver.
22 February 1954 – Clara Neil Miller, died aged 87. Adams often locked the door when he saw her – for up to twenty minutes at a time. A witness, Dolly Wallis, asked Clara about this, and she said he was assisting her in "personal matters": pinning on brooches, adjusting her dress. His fat hands were "comforting" to her. Wallis also claimed that Clara appeared to be under the influence of drugs.
Early that February, the coldest for many years, Adams had sat with her in her room for forty minutes. A nurse entered, unnoticed, and saw Clara's "bed clothes all off... and over the foot rail of the bed, her night gown up around her chest and the window in the room open top and bottom", while Adams read to her from the Bible. When later confronted by Hannam regarding this, Adams said "The person who told you that doesn't know why I did it".
Clara left Adams £1,275 and he charged her estate a further £700 after her death, in addition to a £500 check he got from her earlier. He was the sole executor. Her funeral was arranged by Adams and only he and Annie Sharpe, the owner of the guest house, were present. Annie Sharpe received £200 in Clara's will. Adams tipped the vicar a guinea after the ceremony. Clara Neil Miller was one of the two bodies exhumed during the police investigation on 21 December 1956. Despite the poor condition of the corpse, Francis Camps found evidence of coronary thrombosis and bronchopneumonia. Small amounts of morphine and barbiturates were also found, but not in sufficient quantities to draw any conclusions. According to prescription records, Adams had not prescribed anything to treat the bronchopneumonia.
14 March 1956 – Alfred John Hullett died, aged 71. He was the husband of Gertrude Hullett. Sometime in the 1940s, Adams falsely claimed to Alfred Hullett that he (Hullett) needed an urgent operation; Hullett consulted another doctor and Adams's claim was revealed to be absolutely false.[190] Still, Adams remained Hullett's friend. In November 1955, Adams diagnosed Hullett with cancer in his abdomen (same diagnosis as in the case of Annie Sharpe). An operation by a doctor called in from London was attempted but "something went wrong" during the operation. Ten days later, Alfred's "whole abdomen burst"; Adams, and his partner in practice, operated immediately and "repaired the burst" (in Adams's words). Since then, Adams was giving Hullett large doses of morphine. "I am too full of dope to say anything sensible", Hullett said to one on his friends. Hullett started exhibiting heart problems, and in March 1956, a heart specialist opined that Hullett had been suffering from "some type of heart trouble" since childhood, and that the condition was now worsening. The specialist expected that Hullett would die within a few months and might die at any time; on 13 March, he had severe chest pains consistent with a heart attack. He died the next morning of what Adams described as cerebral hemorrhage.
Shortly after his death, Adams went to a chemists to get a 10 cc hypodermic morphine solution in the name of Mr Hullett containing 5 grains of morphine, and for the prescription to be back-dated to the previous day. The police presumed this was to cover morphine Adams had given him from his own private supplies. Mr Hullett left Adams £500 in his will. In cross examination during Adams's committal hearing, the defence forced an admission from the Crown's expert witness that Mr Hullett died of a coronary thrombosis.
Death of Annie Sharpe
Mrs Annie Sharpe was the proprietor of 'Barton', a boarding house where at least two of Adams's victims, the Neil Miller sisters (Hilda, died 1953; and Clara, died 1954) had lived; Adams had cut both of them off from their relatives and prevented them from receiving their mail. Sharpe herself tried to get the Neil Miller sisters to "invest £5,000 in her business"; she admitted only to receiving a £200 check from Clara Neil Miller. She and Adams were the only people present during Clara Neil Miller's burial.
After interviewing Sharpe, Hannam considered her a key witness and thought she was the key to the whole matter, suspecting she was money-grabbing and in collusion with Adams.
While the investigation was underway, Sharpe was suddenly "diagnosed" by Adams himself with cancer in her abdominal cavity and died a few days after this diagnosis, on 13 or 15 November 1956. Her body was cremated.
After the acquittal
In the aftermath of the trial, Adams resigned from the National Health Service and was convicted in Lewes Crown Court on 26 July 1957, on eight counts of forging prescriptions, four counts of making false statements on cremation forms, and three offences under the Dangerous Drugs Act 1951, and fined £2,400 plus costs of £457. His license to prescribe dangerous drugs was revoked on 4 September and on 27 November he was struck off the Medical Register by the GMC. Adams continued to see some of his more loyal patients, and prescribed over-the-counter medicine to them.
Immediately following the trial, Percy Hoskins, chief crime reporter for the Daily Express, whisked Adams off to a safehouse in Westgate-on-Sea, where Adams spent the next two weeks recounting his life story. Hoskins had befriended Adams during the trial and was the only major journalist to act on the presumption of his innocence. Adams was paid £10,000 (£246,500 today) for the interview, though he never spent the proceeds. The notes were found in a bank vault after his death, untouched. Adams then successfully sued several newspapers for libel. Adams returned to Eastbourne, where he continued to practice privately, despite the widespread belief in the town that he had murdered people. That belief was not shared by his friends and his patients in general. One exception was Sir Roland Gwynne, who distanced himself from Adams after the trial.
After two failed applications, Adams was reinstated as a general practitioner on 22 November 1961, and his authority to prescribe dangerous drugs was restored the following July. He continued to practice as a sole practitioner, not resuming his partnership with the town's "Red House" practice. In August 1962, Adams applied for a visa to America but was refused because of his dangerous drug convictions.
Adams later became president (and honorary medical officer) of the British Clay Pigeon Shooting Association.
Sir Roland Gwynne died on 15 November 1971. Adams signed his death certificate.
Death
Adams slipped and fractured his hip on 30 June 1983 while shooting in Battle, East Sussex. He was taken to Eastbourne Hospital but developed a chest infection and died on 4 July of left ventricular failure. He left an estate of £402,970 and bequeathed £1,000 to Percy Hoskins. Hoskins gave the money to charity. Adams had been receiving legacies until the end. In 1986, The Good Doctor Bodkin Adams, a television docudrama based on his trial, was produced with Timothy West in the lead.
Historical views on Adams
Before 2003
Opinion regarding Adams has been divided, though in recent years has tended to the view that he was a murderer. The writer Sybille Bedford, present at Adams's trial, was adamant that he was not guilty. Many publications were sued for libel during Adams's lifetime, showing the prevalence of the rumors that surrounded him.
After Adams's death, writers were more free to speculate. In 1983, Rodney Hallworth and Mark Williams concluded Adams was a serial killer and probably schizophrenic: "In the opinion of many experts Adams died an unconvicted mass-murderer". Percy Hoskins, writing in 1984, was of the opposite opinion, adamant that Adams was not guilty but merely "naive" and "avaricious". In 1985, Sir Patrick Devlin, the judge, stated that Adams may have been a "mercenary mercy killer" but, though compassionate, he was at the same time greedy and "prepared to sell death": "He did not think of himself as a murderer but a dispenser of death [...] According to his lights, he had done nothing wrong. There was nothing wrong in a doctor getting a legacy, nor in his bestowing in return [...] a death as happy as heroin could make it." He also "could be convinced that Dr Adams had helped to end Mrs Hullett's life". In 2000, Surtees, a former colleague of Adams, wrote a more sympathetic account of him as being the victim of a police vendetta.
After 2003
These writers, other than Devlin, who read and based his account on the papers from the committal proceedings and the case papers for the Hullett case before it was discontinued, based their opinions almost entirely on the evidence given in court regarding Morrell. The police archives were opened in 2003 at the request of Pamela Cullen, who speculates that Adams was acquitted more due to the way the case "was presented than [to] Doctor Adams' lack of guilt". She also highlights the fact that Hannam's investigation was "blinkered" from the perspective of motive: Hannam assumed monetary gain was the driving force because during the 1950s, little was known of what really motivated serial killers, i.e. "physical needs, emotions and often bizarre interpretations of reality".
The apparently incompatible accounts of Adams as a barely competent doctor lavish in his use of heroin and morphia with his successful and lucrative medical practice may be explained by the medical profession's attitude to end-of-life care in the period. Between the 1930s and 1960s, the medical profession in general regarded a death as a failure and subjected dying patients to treatments aimed at prolonging life rather than relieving suffering, an attitude prevalent in the post-war National Health Service, which failed to make adequate provision for the dying. Increasingly, patients feared suffering before death and, although a few doctors were prepared to advocate the use of opiates in palliative care openly, published medical commentary on care of the dying was rare before the 1960s. However, a 1948 article observed that "purely medical treatment" for the dying could "almost be written in one word—morphine" and a 1957 British Medical Association meeting heard the use of heroin to induce euphoria and oblivion and relieve pain advocated. Although doctors were aware that hastening a patient's death was illegal, one suggested in 1944 it was something "the law forbids in theory but ignores in practice": he added it was something only the doctor could judge and it should not be discussed with patients, their families or medical colleagues.
In Adams's case, the court did not ignore the suggestion that he had hastened death and, as Devlin makes clear, he needed to clarify for the jury, and incidentally the medical profession, the extent to which the law allowed the orthodox doctor to go in easing the passing of the dying. Mahar regards Adam's statements to Hannam on Mrs Morrell as less about his guilt or innocence than a disconnection between the medical and legal views on assisted dying: Adams never denied giving his patients large doses of opiates, but denied it was murder. This was not simply Adams's idiosyncratic view, as appears from the evidence of Dr. Douthwaite for the prosecution, who accepted that a physician might knowingly give fatal doses of pain relieving drugs to a terminally ill patients, adding it was not his business to say whether it was murder. Devlin's directions to the jury confirmed that it was a medical issue, not a legal or moral one, whether Adam's treatment was designed to promote comfort. Devlin's view was that Adams may have been guilty of mercy killing or even perhaps finishing off a troublesome patient, but was one who cared for his patients to the best of his ability. Adams eased the passing of Mrs Morrell, but his greed brought his motives into question. Mahar notes an editorial in a medical journal following the case suggested that the publicity it caused might hamper medical discretion, but claimed the use of opiates in terminal cases was essential. Adams may be seen as an extreme case in their use, but other doctors also used them to ease the passing.
Legal legacy
Adams's trial had many effects on the English legal system.
The first was establishing the principle of double effect that if a doctor "gave treatment to a seriously ill patient with the aim of relieving pain or distress, as a result of which that person's life was inadvertently shortened, the doctor was not guilty of murder."
Owing to the potentially prejudicial evidence that was mentioned in the committal hearing (regarding Mrs Hullett, evidence that was not subsequently used in Adams's trial for murdering Mrs Morrell) the Tucker Committee was held, which led to the law being changed in the subsequent Criminal Justice Act 1967 to restrict what might be published about committal hearings to avoid pre-trial publicity
Though a defendant had never been required to give evidence in his own defence, Judge Devlin underlined in his summing-up that no prejudice should be attached by the jury to Adams not doing so.
The case also led to changes in Dangerous Drugs Regulations, meaning that Schedule IV poisons required a signed and dated record of patient details and the total dose used. Previously, the record need only have recorded such drugs obtained.
It has been suggested by a number of professionals in biomedical law that Devlin's proposition that a doctor whose primary intention is to relieve pain, even if life is incidentally shortened, provides a special defence in law for doctors only, and may be an example the reluctance of courts to convict doctors. Although it is frequently asserted by, for example the British Medical Association, that UK law does not distinguish between doctors and non-doctors, the way that intention to kill is interpreted in medical cases shows that the law treats the bona fide exercise of a doctor's clinical judgment as precluding a guilty mind.
Subsequent cases
It was 25 years before another doctor in Britain, Leonard Arthur, stood trial for murder arising from treatment. Arthur was tried in November 1981 at Leicester Crown Court for the attempted murder of John Pearson, a newborn child with Down syndrome. Like Adams, on the advice of his legal team he did not give evidence in his defence, relying instead on expert witnesses. He was acquitted.
More recently, the double effect principle figured in two British murder trials. In 1990, Dr Cox, a rheumatologist was convicted of the murder of a terminally ill patient who had begged him to kill her. Once pain killers had proved ineffective, he injected her with twice the lethal dose of potassium chloride and she died within minutes. Cox's claim that his intention was to relieve suffering was not accepted, as potassium chloride had no analgesic properties. In the same year, Dr Lodwig gave a terminal cancer patient an injection of lignocaine and potassium chloride which proved rapidly fatal. However, as lignocaine is a pain-killer, his claim that potassium chloride could accelerate the analgesic effect of recognized pain killers was not disputed by the prosecution. Although Dr Lodwig was charged with murder, the prosecution offered no evidence at his trial.
In 2000, Harold Shipman became the only British doctor to be successfully prosecuted for the murder of his patients. He was found guilty on 15 counts and the Shipman Inquiry concluded in 2002 that he had probably murdered a further 200.
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