I think the 2002 appeal was JBs own fault. Unlike an appeal referred by the single judge, a referral by the CCRC allows other points to be thrown in without permission. I doubt any QC would have annoyed the court with the idiotic and ultimately self defeating nonsense that only Bamber could have insisted upon.
I think any defence that brings up evidence of a body being moved post mortem when his client is accused of staging the scene would likely be struck off - a point emphasised by the CoA regarding the bible issue.
The evidence is there in black and white that SC was moved at soc after first respondents entered: A/PS Woodcock's wit stat and testimony from forensic scientist Martyn Ismail.
Other officers also thought SC had been moved at soc when shown soc images which were different from their initial recollections. Blood stain analyst, Prof Herb Macdonnell also thought SC had been moved at soc.
Blood test results for the bible were not made available to the defence which begs the questions why and why didn't the defence pursue? Although heavily blood stained and found at centre of crime noone knows whose blood?!