And ignore the nonsense about fresh evidence. Open by thundering this paragraph from Lord Kerr in Lundy.
120. The Board considers that the proper basis on which admission of fresh
evidence should be decided is by the application of a sequential series of tests. If the
evidence is not credible, it should not be admitted. If it is credible, the question then
arises whether it is fresh in the sense that it is evidence which could not have been
obtained for the trial with reasonable diligence. If the evidence is both credible and
fresh, it should generally be admitted unless the court is satisfied at that stage that, if
admitted, it would have no effect on the safety of the conviction. If the evidence is
credible but not fresh, the court should assess its strength and its potential impact on
the safety of the conviction. If it considers that there is a risk of a miscarriage of
justice if the evidence is excluded, it should be admitted, notwithstanding that the
evidence is not fresh.