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John Bodkin Adams (21 January 1899 – 4 July 1983) was a British general practitioner, convicted fraudster and suspected serial killer. Between 1946 and 1956, more than 160 of his patients died in what could be deemed to be suspicious circumstances. In addition, 132 out of 310 patients had left Adams money or items in their wills. He was tried and acquitted for the murder of one patient in 1957. Another count of murder was withdrawn by the prosecution in what was later described as "an abuse of process" by the presiding judge Sir Patrick Devlin, causing questions to be asked in Parliament about the prosecution's handling of events. The trial was featured in headlines around the world and was described at the time as "one of the greatest murder trials of all time" and "murder trial of the century". It was also described at the time as "unique" because, in the words of the judge, "the act of murder" had "to be proved by expert evidence."

The trial had several important legal ramifications. It established the doctrine of double effect, whereby a doctor giving treatment with the aim of relieving pain may lawfully, as an unintentional result, shorten life. Secondly, because of the publicity surrounding Adams' committal hearing, the law was changed to allow defendants to ask for such hearings to be held in private. Finally, although a defendant had not been required within recorded legal history to give evidence in his own defence, the judge underlined in his summing-up that no prejudice should be attached by the jury to Adams not doing so.

Adams was found guilty in a subsequent trial of 13 offences of prescription fraud, lying on cremation forms, obstructing a police search and failing to keep a dangerous drugs register. He was struck off the Medical Register in 1957 and reinstated in 1961 after two failed applications.

Scotland Yard's files on the case were initially closed to the public for 75 years, and would have remained so until 2033. Following a request by historian Pamela Cullen, special permission was granted in 2003 to reopen the files, and these have since been used by several researchers.

Early years
Adams was born and raised in Randalstown, Ulster, Ireland into a deeply religious family of Plymouth Brethren, an austere Protestant sect of which he remained a member for his entire life. His father, Samuel, was a preacher in the local congregation and by profession was a watchmaker. He also had a passionate interest in cars, which he would pass on to John. In 1896 Samuel was 39 years of age when he married Ellen Bodkin, aged 30. John was their first son, followed by a brother, William Samuel, in 1903. In 1914 Adams' father died of a stroke. Four years later William died in the 1918 influenza pandemic.

After attending Coleraine Academical Institution for several years, Adams matriculated at The Queen's University of Belfast at the age of 17. There he was seen as a "plodder" and "lone wolf" by his lecturers and, partly because of an illness (probably tuberculosis), he missed a year of studies. He graduated in 1921, having failed to qualify for honours. In 1921, surgeon Arthur Rendle Short offered Adams a position as assistant houseman at Bristol Royal Infirmary. He spent a year there but did not prove a success. On Short's advice, Adams applied for a job as a general practitioner in a Christian practice in Eastbourne, Sussex.

Eastbourne
Adams arrived in Eastbourne in 1922, where he lived with his mother and his cousin, Sarah Florence Henry. In 1929, he borrowed £2,000 (equivalent to £104,247 at 2011 prices ) from a patient, William Mawhood, and bought an 18-room house called Kent Lodge, in Trinity Trees (then known as Seaside Road ), a select address. Mrs Mawhood advised the police that Adams would frequently invite himself to the Mawhoods' residence at meal time, even bringing his mother and cousin. She added that he began charging items to their accounts at local stores without their permission, and that when Mr Mawhood died in 1949, Adams visited his widow, uninvited, and took a 22-carat gold pen from her bedroom dressing table, saying he wanted "something of her husband's".

Gossip regarding Adams' unconventional methods had started by the mid-1930s. In 1935, Adams inherited £7,385 from a patient, Matilda Whitton; her whole estate amounted to £11,465, equivalent to £430,931 and £669,007 respectively at 2011 values. The will was contested by her relatives but upheld in court, though a codicil giving Adams' mother £100 was overturned. Adams then began receiving "anonymous postcards" about him "bumping off" patients, as he admitted in a newspaper interview in 1957. These were received at a rate of three or four a year until World War II, and then commenced again in 1945.

Adams stayed in Eastbourne throughout the war, and in 1941 he gained a diploma in anaesthetics and worked in a local hospital one day a week, where he acquired a reputation as a bungler. He would fall asleep during operations, eat cakes, count money, and even mix up the anaesthetic gas tubes, leading to patients waking up or turning blue. In 1943, his mother died, and in 1952 his cousin Sarah developed cancer. Adams gave her an injection half an hour before she died.

Adams' career was very successful, and Hallworth claimed that, by 1956, he was reputed to be the wealthiest doctor in England, although without citing any evidence. A similar, and similarly unsourced, claim that "he was probably the wealthiest GP in England" was made by Cullen. He attended some of the most famous and influential people in the region, including MP and Olympic medal winner Lord Burghley, society painter Oswald Birley, Admiral Robert Prendergast, industrialist Sir Alexander Maguire, the 10th Duke of Devonshire, Eastbourne's Chief Constable Richard Walker and a host of businessmen.

Police investigation
On the day Mrs Hullett died, 23 July 1956, the Eastbourne coroner notified the local Chief Constable that, from his post mortem, her death did not appear to be natural, and the police began to take statements from individuals that had been in contact with her shortly before her death, many of whom believed that she had committed suicide. One of Mrs Hullett's friends provided three letters she had written in April 1956 and placed with her will, indiciting she had contemplated suicide then. On the same day, the Eastbourne police received an anonymous call, actually from Leslie Henson the music hall performer, concerned about the death of his friend Gertrude Hullett while being treated by Adams. A second post mortem conducted by a Home Office pathologist concluded that the cause of death was barbiturate poisoning.

After the second post mortem, the investigation was taken over from Eastbourne police on 17 August 1956 by two officers from the Metropolitan Police's Murder Squad. The senior officer, Detective Superintendent Herbert Hannam of Scotland Yard, was known for having secured a conviction in the Teddington Towpath Murders in 1953, although the defence counsel, Peter Rawlinson, called Hannam's evidence on how the confession was obtained into question. In view of the opinion Hannam later expressed, that detectives must sometimes ignore the law, his methods are open to question. He was assisted by Detective Sergeant Charles Hewett. Hannam was in the unusual position that, instead of having to find a suspect for a known crime, he had a known suspect in Adams but needed to link him to more serious crimes than forging prescriptions, making false statements and mishandling drugs. Devlin suggests that Hannam became fixated on the idea that Adams had murdered many elderly patients for legacies, regarding his receiving a legacy as grounds for suspicion, although Adams was generally only a minor beneficiary.

Investigators decided to focus on cases from 1946 to 1956 only. Of the 310 death certificates examined by Home Office pathologist Francis Camps, 163 were considered by Camps to be worthy of further investigation. This was because, firstly, a very high proportion, some 42% of all 310 of Adams' deceased patients, were diagnosed as having died of cerebral thrombosis or cerebral haemorrhage against an average in the late 1950s of around 15% for elderly, bedridden patients. Secondly, the 163 certificates related to Adams' patients that had died while in a coma, which could be suggestive of the administration of a narcotic or barbiturate. The police took numerous statements from nurses that had treated Adams' patients and their relatives. Some were generally favourable to him, but others claimed Adams had given patients "special injections" of substances that he refused to describe to the nurses. The statements also claimed that his habit was to ask the nurses to leave the room before injections were given and that he would also isolate patients from their relatives, hindering contact between them. However, several of the witnesses who Hannam had questioned verbally refused to give sworn statements to confirm their allegations against Adams. During the trial, the assertions of Mrs Morrell's nurses that they did not know what Adams was injecting or that he did not give injections in front of them were disproved by the contents of their own note-books.

Obstruction
On 24 August, the British Medical Association (BMA) sent a letter to all doctors in Eastbourne reminding them of "Professional Secrecy" (i.e., patient confidentiality) if interviewed by the police. The police were frustrated by this move, although some local doctors ignored it and gave statements relating either to deceased patients or, in one instance one that was alive This action was part of a concerted attempt by the BMA to secure better terms for its members, whose pay had remained virtually static since the National Health Service had been set up in 1948, which later led to talk of an all-out strike.

The Attorney-General, Sir Reginald Manningham-Buller (who customarily prosecuted cases of poisoning or delegated it to the Solicitor General), wrote to the BMA secretary, Dr Macrae, "to try to get him to remove the ban". The impasse continued until on 8 November Manningham-Buller met with Macrae to convince him of the importance of the case. During this meeting, in a highly unusual move, he passed Hannam's confidential 187-page report on Adams to Macrae. His intention was to convince the BMA of the seriousness of the accusations and for the need to obtain cooperation from local doctors. Macrae took the report to the President of the BMA and returned it the next day. Convinced of the seriousness of the accusations, Macrae dropped his opposition to doctors talking to the police.

It has been speculated that Macrae passed a copy the report to the defence, and conspiracy theorists have claimed that Manningham-Buller did so with the intention of assisting the defence case, but there is no evidence of this. However, the incident does call Manningham-Buller's competence into question, and he was strongly criticised at the time.

On 28 November 1956, opposition Labour Party MPs Stephen Swingler and Hugh Delargy gave notice of two questions to be asked in the House of Commons regarding the affair, one asking what "reports [the Attorney-General] has sent" to the General Medical Council (GMC) in the "past six months". Manningham-Buller replied that he had "had no communications" with the GMC, but only with an officer of it. He did not mention the report. Instead, he instigated an investigation into a leak, later concluding that Hannam himself had passed information regarding the meeting with Macrae to a journalist, probably Rodney Hallworth of the Daily Mail.

Meeting Hannam
On 1 October 1956 Hannam met Adams and Adams asked "You are finding all these rumours untrue, aren't you?" Hannam mentioned a prescription Adams had forged: "That was very wrong [...] I have had God's forgiveness for it", Adams replied. Hannam brought up the deaths of Adams' patients and his receipt of legacies from them. Adams answered: "A lot of those were instead of fees, I don't want money. What use is it? I paid £1100 super tax last year" Hannam later mentioned, "Mr Hullett left you £500". Adams replied, "Now, now, he was a life-long friend [...] I even thought it would be more than it was." Finally, when asked why he had stated untruthfully on cremation forms that he was not to inherit from the deceased, Adams said: "Oh, that wasn't done wickedly, God knows it wasn't. We always want cremations to go off smoothly for the dear relatives. If I said I knew I was getting money under the Will they might get suspicious and I like cremations and burials to go smoothly. There was nothing suspicious really. It was not deceitful."

Search
On 24 November, Hannam, Hewett and the head of Eastbourne CID, Detective Inspector Pugh, searched Adams' house with a warrant issued (in Pugh's name) under the Dangerous Drugs Act 1951. When told they were looking for, "Morphine, Heroin, Pethidine and the like", Adams was surprised: "Oh, that group. You will find none here. I haven't any. I very seldom ever use them", he said. When Hannam asked for Adams' Dangerous Drugs Register – the record of those ordered and used – Adams responded: "I don't know what you mean. I keep no register." He had not kept one since 1949. When shown a list of dangerous drugs he had prescribed Morrell, and asked who administered them, Adams said, "I did nearly all. Perhaps the nurses gave some but mostly me" – contradicting what the nurses' notebooks would show during his trial. Hannam then observed, "Doctor, you prescribed for her 75 – 1/6 grains heroin tablets the day before she died." Adams replied, "Poor soul, she was in terrible agony. It was all used. I used them myself [...] Do you think it is too much?"

Adams opened a cupboard for the police: amongst medicine bottles were "chocolates – slabs stuck – butter, margarine, sugar". While the officers inspected it, Adams walked to another cupboard and slipped two objects into his jacket pocket. Hannam and Pugh challenged him and Adams showed them two bottles of morphine; one he said was for Annie Sharpe, a patient and potential witness who had died nine days earlier under his care; the other said "Mr Soden". He had died on 17 September 1956 but pharmacy records later showed Soden had never been prescribed morphine. Adams was later (after his main trial in 1957) convicted of obstructing the search, concealing the bottles and for failing to keep a Dangerous Drugs register. Later at the police station, Adams told Hannam: "Easing the passing of a dying person isn't all that wicked. She [Morrell] wanted to die. That can't be murder. It is impossible to accuse a doctor."

Sexuality
In December, the police acquired a memorandum belonging to a Daily Mail journalist, concerning rumours of homosexuality between "a police officer, a magistrate and a doctor". The "doctor" directly implied Adams. This information had come, according to the reporter, directly from Hannam. The 'magistrate' was Sir Roland Gwynne, Mayor of Eastbourne (1929–31) and brother of Rupert Gwynne, MP for Eastbourne (1910–24). Gwynne was Adams's patient and friend who went on frequent holidays with Adams. The 'police officer' was supposedly the Deputy Chief Constable of Eastbourne, Alexander Seekings. Hannam interviewed Gwynne on 4 February 1957, following which Gwynne severed all connection with Adams. Hannam's record of the interview makes no reference to any homosexual acts (which were a criminal offence in 1956),

Adams became engaged around 1933 to Norah O'Hara but called it off in 1935 after her father had bought them a house and furnished it. Various explanations have been suggested: Surtees suggests that it was because Adams' mother did not want him to marry "trade" though he also quotes a rumour that Adams wanted O'Hara's father to change his will to favour his daughters. Adams remained friends with O'Hara his whole life and remembered her in his will.

Arrest
Adams was first arrested on 24 November 1956 on 13 charges including false representation on cremation certificates and granted bail. He was arrested on 19 December 1956 and charged with the murder of Mrs. Morrell. When told of the charges, he said: "Murder... murder... Can you prove it was murder? [...] I didn't think you could prove it was murder. She was dying in any event."

Then, while he was being taken away from Kent Lodge, he reportedly gripped his receptionist's hand and told her: "I will see you in heaven."

Hannam considered he had collected enough evidence in at least four of the cases for prosecution to be warranted: regarding Clara Neil Miller, Julia Bradnum, Edith Alice Morrell and Gertrude Hullett. Of these, Adams was charged on one count: the murder of Morrell, but with the death of Mrs Hullett (and also that of her husband) being used to prove 'system'. Although it was usual in 1956 for only one count of murder to be indicted, evidence of other suspected murders not being tried could be given, provided each such instance would, on its own facts, be capable of proof beyond reasonable doubt and strikingly similar to the case tried.

Edith Alice Morrell
Morrell was a wealthy widow who suffered a stroke on 24 June 1948 while visiting her son in Cheshire. She was partially paralysed and was admitted to a hospital near Chester, where she received morphine injections for nine days from 27 June, prescribed by a Dr Turner. Cullen suggests that Adams, supposedly her usual doctor, arrived there on 26 June, the day before she was first prescribed morphine for the pain. However, the Attorney-General's opening speech states that Mrs Morrell was transferred to Eastbourne on 5 July 1948, only then becoming one of Adams' patients, and that he first prescribed morphine on 9 July, adding heroin on 21 July. Mrs Morrell was not expected to live more than six months or so, but survived her stroke for over two years, suffering also from arthritis. Between July 1948 and August 1950, she received routine evening injections of morphine and heroin and her condition was stable, but from then, as her condition deteriorated, the dosages increased. An expert witness for the prosecution claimed that Mrs Morrell would have become addicted, but the only apparent symptoms of this were attributed by the defence's expert to a second stroke.

Mrs Morrell left an estate of £157,000 and made eight cash bequests of between £300 and £1,000. Cullen claims that in some of the several wills she made Adams was bequeathed large sums of money and her Rolls-Royce Silver Ghost (valued at £1,500). This appears incorrect and, in her will of 5 August 1950, the only outright bequest Mrs Morrell made to Adams was a chest of silver cutlery worth £276. This will also awarded him a contingent right to the car and a Jacobean court cupboard, but only if Mrs Morrell's son predeceased her, which Devlin noted was unlikely. A codicil of 13 September 1950 cut Adams out of her will completely. and she died on 13 November 1950 aged 81. without any further changes to her will. Adams certified the cause of death as "stroke" and on inspecting the body, slit her wrist to ensure she was dead. Despite the last codicil, Mrs Morrell's son gave Adams the Rolls-Royce which was 19 years old, and the chest of silver cutlery. After Mrs Morrell's death, he also took away an infrared lamp she had bought herself, worth £60. Adams billed Morrell's estate for 1,100 visits, costing £1,674 in total. The police estimated that Adams had visited Morrell a total of 321 times during her treatment. On her cremation form, Adams stated that "as far as I am aware" he had no pecuniary interest in the death, thereby avoiding the necessity of a post-mortem.

Gertrude Hullett
On 23 July 1956 Gertrude Hullett, another of Adams' patients, died aged 50. She had been depressed since the death of her husband four months earlier and had been prescribed sodium barbitone and also sodium phenobarbitone. She had told Adams on frequent occasions of her wish to commit suicide. When questioned by the coroner, Adams said that he personally gave Mrs Hullett two barbiturate tablets each morning, initially of 7½ grains each, a normal dose, later reduced to two tablets of 6 grains each, then 5 grains. However, he did not ensure that she took both tablets daily and no attempt had been made to retrieve any that had been prescribed to the late Mr Hullett but unused when he died.

On 17 July Hullett wrote out a cheque for Adams for £1,000 – to pay for an MG car her husband had promised to buy him. Adams paid the cheque into his account the next day, and on being told that it would clear by the 21st, asked for it to be specially cleared – to arrive in his account the next day. On 19 July Hullett is thought to have taken an overdose and was found the next morning in a coma. Adams was unavailable and a colleague, Dr Harris, attended her until Adams arrived later in the day. Not once during their discussion did Adams mention her depression or her barbiturate medication. They decided a cerebral haemorrhage was most likely. On 21 July Dr Shera, a pathologist, was called in to take a spinal fluid sample and immediately asked if her stomach contents should be examined in case of narcotic poisoning. Adams and Harris both opposed this. After Shera left, Adams visited a colleague at the Princess Alice Hospital in Eastbourne and asked about the treatment for barbiturate poisoning. He was told to give doses of 10 cc of Megimide every five minutes, and was given 100 cc to use. The recommended dose in the instructions was 100 cc to 200 cc. Dr Cook also told him to put Hullett on an intravenous drip. Adams did not.

The next morning, at 8.30, Adams called the coroner to make an appointment for a private post-mortem. The coroner asked when the patient had died and Adams said she had not yet. Harris visited again that day and Adams still made no mention of potential barbiturate poisoning. When Harris had left, Adams gave a single injection of 10 cc of the Megimide. Hullett developed broncho-pneumonia and on the 23rd at 6.00 a.m. Adams gave Hullett oxygen. She died at 7.23 a.m. on 23 July. The results of a urine sample taken on 21 July were received after Hullett's death, on the 24th. It showed she had 115 grains of sodium barbitone in her body – twice the fatal dose.

An inquest was held into Hullett's death on 21 August. The coroner questioned Adams' treatment and in his summing up said that it was "extraordinary that the doctor, knowing the past history of the patient" did not "at once suspect barbiturate poisoning". He described Adams's 10 cc dose of Megimide as another "mere gesture". The inquest concluded that Hullett committed suicide: it was described as a "travesty" as, in the opinion of Cullen; with an ongoing police investigation, the inquest should have been adjourned until the investigation had concluded. However, the coroner asked Superintendent Hannam whether the police wished him to adjourn the inquest, to which Hannam replied that he had no application to make. After the inquest, the cheque for £1,000 disappeared.

Hullett left Adams her Rolls-Royce Silver Dawn (worth at least £2,900) in a will written five days before her overdose. Adams sold it six days before he was arrested.

Case selection
Charles Hewett, Hannam's assistant, was quoted as saying that both officers were astounded at Manningham-Buller's decision to charge Adams with the murder of Morrell, since her body had been cremated and therefore there was no evidence to present before a jury. This assertion was published after the deaths of both Hannam and Manningham-Buller. This shows a misunderstanding of the principle of corpus delicti, and his assertion that traces of drugs found in exhumed remains were more compelling as proof against Adams was disputed by Devlin, as the exhumations and subsequent post-mortems yielded nothing of interest. and as the pathologist concerned did not consider that the levels found were significant. Cullen also describes Morrell as "the weakest" case of the four the police deemed most suspicious. although Devlin, who regarded none of the cases mentioned by Hallworth as being as strong as the Morrell case, despite it being six years old, suggesting that, in an investigation covering a ten-year period, the police were unable to find a better case than the Morrell one.

In 1957, it was the job of the police to investigate reported crimes, to determine if one had been committed and arrest a suspect. It was then the job of the Director of Public Prosecutions, or in very serious cases of the Attorney-General or Solicitor-General, to review the police case and decide whether to prosecute and, in more serious cases, what offences to prosecute. What to prosecute depends on legal issues and Devlin states that, to succeed in the murder case against Adams, the prosecution had to show, firstly, there had been an unnatural death, secondly, an act by Adams was capable of being murderous (such as an injection so large as to cause death) and finally Adams’ intent to kill. The Attorney-General thought he had evidence that Adams had prescribed large quantities of opiates to Mrs Morrell, Adams' own admissions that he had used them all on Mrs Morrell and injected all or almost all of them himself, and a medical expert's testimony that the only possible reason to inject so much over a short time was to kill her.

Cullen mentions Mrs. Morell, Mr and Mrs Hullett, Clara Neil Miller and Julia Bradnum as cases that Hannam regarded as warranting prosecution. However, in the cases of Mr Hullett, Clara Neil Miller and Julia Bradnum there was no certainty of an unnatural death, as there was evidence in the committal hearing that Mr Hullett died of a heart attack and, at their exhumations, the pathologist concluded Miller had died from pneumonia, and the condition of Bradnum's body did not allow a cause of death to be stated, so none of these were good cases. Mrs Hullett had died an unnatural death, of a barbiturate overdose, but there was no evidence or admission that Adams had persuaded her to take that overdose and, had Mrs Hullett's case been brought to trial after Adams’ first acquittal, Devlin believed that a second acquittal was virtually certain. In these five cases, Adams may have contributed to the deaths in some way, but this would not have been sufficient for a capital murder conviction.

Committal hearing
The committal hearing opened in Lewes on 14 January 1957. In accordance with the legal rule applying in 1957, Adams was charged on the single count of murdering Mrs Morrell, but the prosecution also alleged he had killed Mr and Mrs Hullett in a similar fashion, and introduced evidence relating to them as evidence of system, which the prosecution also wished to refer to in the Morrell trial. Despite the objections of the defence that this evidence was inadmissible, the magistrates allowed it but, in cross examination, the defence forced an admission from the Crown's expert witness that Mr Hullett died of a coronary thrombosis. The hearing concluded on 24 January when, after a five-minute deliberation, Adams was committed for trial on the Morrell charge.

Melford Stevenson, who led the crown's case at this hearing, made an explicit claim that Adam's instructions to specially clear Mrs Mrs Hullett's cheque two days before her death showed that he knew she would be die very soon, using her wealth and foreseen death as evidence of critical similarities to the deaths of with Mrs Morrell and Mr Hullett. Devlin considered the police case that there were similarities in deaths of Mrs Morrell and Mrs Hullett was not well founded, as the claimed similarities were not distinctive. Had the police found two recent cases similar to Mrs Hullett's, where a patient had died of an overdose of pills prescribed by Adams, that might have shown system, but the police found no such cases.

The Chairman of the magistrates was Sir Roland Gwynne, but he stepped down because of his close friendship with Adams. A vital piece of evidence, a cheque written out for £1000, went missing after the hearing, instigating a further police investigation. While the culprit was not found, Scotland Yard suspected the local Deputy Chief Constable of Eastbourne, Seekings, of having misplaced it to help Adams. Seekings was known to have taken holidays with Adams and Gwynne, and looked after Gwynne's finances while he was in hospital in January 1957.

Following the committal hearing, the Attorney-General advised Devlin that he would not be using the evidence regarding the Hullets in the Morrell trial, but seeking a second indictment relating to Mrs Hullett, which he did on 5 March 1957. Had this been proceeded with, a second committal hearing would have been required. The trial on the indictment relating to Mrs Morrell started on 18 March 1957 at the Old Bailey, with that relating to Mrs Hullett held back for a possible second separate trial. Three days later, a new Homicide Act came into effect; a single murder by poison became a non-capital offence. Adams, having been indicted on both charges before this date, would still face the death penalty if convicted. The Home Secretary would be less likely to grant clemency in the case of a second murder conviction in the Hullett case, as this would make it far more difficult politically to sentence Adams to life imprisonment, particularly as a double murder could still be capital under the 1957 Homicide Act, and Devlin considered that the Attorney-General's aim in bringing forward a second indictment was to make it more likely that Adams would hang.

Trial
See also: R v Adams.

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."

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 Morrell – and that none of the witnesses' evidence matched the others'. Then, on the second day of the trial, he produced notebooks written by the nurses, detailing Adams' treatment of Morrell. The prosecution claimed never to have seen these notebooks (even though they are recorded in pretrial lists of evidence). 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' 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 the loquacious Adams to give evidence, and thereby avoiding him "chatting himself to the gallows". This was unexpected, shocking the prosecution and the press, and even surprising the judge.

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. During the committal hearing prior to the trial, Goddard had been seen dining with Sir Roland Gwynne at The White Hart Hotel in Lewes: there is no indication of what they discussed. Goddard, as Lord Chief Justice, appointed Devlin to try the Adams case shortly after the end of the committal hearing and, in a meeting of 19 February 1957, 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, 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 of 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 Adam'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.

Concerns 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 an 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.

On the other hand, there is also considerable evidence of negative and prejudicial press coverage of the case. From the start of 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' 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' 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.

Loss of the nurses' notebooks
Eight books of daily records made by nurses who had worked under Adams were recorded in pre-trial police records but were not in the hands of the prosecution when the trial started, so that Manningham-Buller had no chance chance to consider their contents before the trial started. He was, however, presented with a copy of them by the defence on the second day of the trial. These books were then used by the defence to counter the witness statements given 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 defence was not required to explain how the books came into their hands, and the Attorney-General made no effort to pursue this matter, despite his nickname of "Sir Bullying Manner". He also failed to ask for an adjournment to acquaint himself with the new evidence – despite the fact that the judge later said that he would have been willing to grant it. Cullen states that Adams gave three conflicting explanations for how he came to have the note books in 1950, although it is nevertheless the case that he 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 Adms then filed 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. His solicitor later claimed that after a police search in 24 November 1956 had failed to uncover them, they were found by the defence team in Adams's surgery in the same night. This was said to have been inconsistent with the police records: in the list of exhibits for the Committal Hearing given to the DPP's office, the notes are mentioned. Cullen suggests that Attorney General therefore must have known they existed. and according to her, this shows "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 startling claim of interference on a misunderstanding of the prosecution process shows its weakness.

Police archives
Scotland Yard's files on the case and also those of the DPP, were to be closed until 2033. This was an unusual decision, considering the advanced age of the suspect, witnesses and others involved in the case. The files were opened to the public after special permission was granted in 2003.

Suspicious cases
At an early stage in the investigation, Hannam believed he had found Adams' 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' 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 favour. What were a significant number of suspiciously sinister events were bolstered, in Hannam's report by what he considered were incriminating statements about Mrs Hullett's death. The Chief Superintendent was initially dismissive of the case Hannam 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, 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' guilt, but in the Morrell case the nurses' own notebooks showed that the testimony in their statements were at best misremembered, at worst untrue.

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. Cullen mentions Mrs. Morrell, Mr and Mrs Hullett, Clara Neil Miller and Julia Bradnum as cases that Hannam regarded as warranting prosecution. Details Mrs. Morrell and Mrs Hullett are given above: the case of Mr Hullet and the two cases where police suspicions led to exhumations indicate that there was insufficient evidence if 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 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 haemorrhage, but Francis Camps examined her remains and found no evidence of this, stating that in view if 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 was 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. When Dolly Wallis asked about this, Clara said he was assisting her in "personal matters": pinning on brooches, adjusting her dress. His fat hands were "comforting" to her. She also 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. He was the sole executor. Her funeral was arranged by Adams and only he and Annie Sharpe, the guest house owner, were present. She 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 and had been diagnosed with cancer in November 1955, underwent an unsuccessful operation in Dececember and was diagnosed in March 1956 by a heart specialist as suffering from a lifelong heart condition 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.
 * 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' committal hearing, the defence forced an admission from the Crown's expert witness that Mr Hullett died of a coronary thrombosis.

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 licence 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.

Right after the trial, Percy Hoskins, chief crime reporter for the Daily Express, whisked Adams off to a safehouse in Westgate-on-Sea, where he 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 innocence. Adams was paid £10,000 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 practise privately despite the widespread belief in the town that he had murdered people. This belief was not shared by his friends and patients in general. One exception was Sir Roland Gwynne, who distanced himself from Adams after the trial.

Adams was reinstated as a general practitioner on 22 November 1961 after two failed applications, and his authority to prescribe dangerous drugs was restored the following July. He continued to practise 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 £1000 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 starring Timothy West.

Before 2003
Opinion regarding Adams has been divided, though in recent years has tended to the view that he was a killer. 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 rumours 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’ 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' 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 Hullett – evidence that would then not be used in Adams's first trial for murdering 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.

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 recognised 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.