John Bodkin Adams
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 as suspicious circumstances. Of these, 132 left him 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 Another count of murder was withdrawn by the prosecution in what was later described as "an abuse of process" by the presiding judge Sir Patrick Devlin, causing questions to be asked in Parliament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."
John Bodkin Adams
John Bodkin Adams in the 1940s
|Died||4 July 1983 (aged 84)|
|Known for||Suspected serial killer|
|Criminal penalty||Struck off the Medical Register in 1957 (reinstated in 1961)|
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, 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.
- 1 Early years
- 2 Eastbourne
- 3 Police investigation
- 4 Patients
- 5 Before the trial
- 6 Trial
- 7 Concerns of prejudice and political interference in the trial
- 8 Suspicious cases
- 9 After the acquittal
- 10 Death
- 11 Historical views on Adams
- 12 Legal legacy
- 13 See also
- 14 Notes and references
- 15 Sources
- 16 Further reading
- 17 External links
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.[i] 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.
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. Adams would frequently invite himself to the Mawhoods' residence at meal time, even bringing his mother and cousin. He also began charging items to their accounts at local stores without their permission. Mrs Mawhood would later describe Adams to the police as "a real scrounger". 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". He never visited her again.
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 was "furious" at not being deemed desirable by other doctors to be selected for a "pool system" where GPs would treat the patients of colleagues who had been called up. 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 and according to historian Pamela Cullen, this is the only "case where it can be considered that the doctor was 'easing the passing'".[dubious ]
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. After years of rumours, and Adams having been mentioned in at least 132 wills of his patients, on 23 July 1956 Eastbourne police received an anonymous call about a death. It was from Leslie Henson, the music hall performer, whose friend Gertrude Hullett had died unexpectedly while being treated by Adams.
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 solved the Teddington Towpath Murders in 1953. 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 deemed to be suspicious. The police took numerous statements from nurses that had treated Adams' patients. Some were generally favourable to him, but others claimed Adams had given patients "special injections" of substances Adams 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, 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 these in front of them were disproved by the contents of their own note-books.
On 24 August, in an "extraordinary move",[ii] 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. Hannam was not impressed, especially since any information gleaned would relate to dead patients. He, and 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,[iii] he passed Hannam's confidential 187-page report on Adams to Macrae. Macrae took the report to the President of the BMA and returned it the next day. In all likelihood, he also copied it and passed it on to the defence.[iv] Convinced of the seriousness of the accusations, Macrae dropped his opposition to doctors talking to the police. In the end two Eastbourne doctors gave evidence to the police.
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.
On 1 October 1956 Hannam bumped into Adams[v] 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.
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 major 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:
In the basement of Adams' house, the police found, "a lot of unused china and silverware. In one room there were 20 new motor car tyres still in their wrappings and several new motor car leaf springs. Wines and spirits were stored in quantity." Hallworth reports that Adams was stockpiling in case of another World War. On the second floor, "one room was given over to an armoury [:] six guns in a glass-fronted display case, several automatic pistols". He had permits for these. Another room was used "wholly for photographic equipment. A dozen very expensive cameras in leather cases" lay around.
In December, the police acquired a memorandum belonging to a Daily Mail journalist,[vi] concerning rumours of homosexuality between "a police officer, a magistrate and a doctor". The last 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 known to visit every day at 9am. They went on frequent holidays together and had spent three weeks in Scotland that September. The 'police officer' was the Deputy Chief Constable of Eastbourne, Alexander Seekings. Hannam ignored this line of inquiry (despite homosexual acts being a criminal offence in 1956), and the police instead gave the journalist a dressing-down. The memo is testament to Adams' close connections to those of power in Eastbourne at the time.
There were rumours of Adams having three "mistresses", but these were probably just "covers" to avoid suspicion. Adams became engaged around 1933 to Norah O'Hara[vii] 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. Cullen suggests that, apart from being homosexual, Adams also did not want his being married to interfere with his relationship with his elderly female patients. Adams remained friends with O'Hara his whole life and remembered her in his will.[viii]
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:
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 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.
Adams and EvesEdit
On 22 February 1957 the police were notified of a libellous and potentially prejudicial poem about the case titled Adams and Eves. It had been read at the Cavendish Hotel on the 13th by the manager in front of 150 guests. An officer spent ten days investigating and discovered a chain of hands through which the poem had passed and been recopied to be redistributed. The original author was not discovered; an unnamed Fleet Street journalist was suspected. The poem finished:
Send them down to sunny Eastbourne by the sea.
Edith Alice MorrellEdit
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, who 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, he was only awarded outright a chest of silver cutlery worth £276, with a contingent right to the car and a Jacobean court cupboard if Mrs Morrell's son pre-deceased her. A codicil of 13 September 1950 cut Adams out of her will completely. She died on 13 November 1950 aged 81. 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.
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.[ix] 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.
Before the trialEdit
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. Hewett believed that there were other cases against the doctor, where traces of drugs had been found in exhumed remains, which were more compelling as proof. Cullen also describes Morrell as "the weakest" case of the four the police deemed most suspicious.
Hewett's view was not shared by Devlin. 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 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.
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.
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.
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.[x] 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 prosequiEdit
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, the Attorney-General would offer no evidence and the judge would direct the jury to bring in a not guilty verdict, 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 the loss 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 this "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 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 said he had never done more than hand two daily barbiturate tablets to Mrs Hullett.
Concerns of prejudice and political interference in the trialEdit
Cullen claimed that there was considerable evidence to suggest that the trial was "interfered with" by those "at the highest level", although the 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 but Cullen mentions the unproven assertion that Gwynne was suspected of being Adams lover as the basis for assuming interference in the trial
Loss of the nurses' notebooksEdit
Eight books of records made by nurses who had worked under Adams were recorded in pre-trial police records but disappeared before the trial started, depriving Manningham-Buller of the chance to familiarise himself with them. He was presented with only a copy of them by the defence on the second day of the trial. These books were then used by the fully prepared defence to counter the witness statements given the nurses who had originally written the notes. Comments in the 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 would have been sure to grant it.[xi]
Adams gave three conflicting explanations for how he came to have the note books in 1950: they were given to him by Morrell's son when he found them among her effects and filed away at his surgery; they were delivered anonymously to his door after she died; they were found in the air raid shelter at the back of his garden, although it is not disputed that he had them in 1956. His solicitor claimed later that they were found by the defence team in Adams's surgery shortly before trial, after a police search had failed to uncover them. This differs from 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, 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.
Disclosure of evidence to the BMAEdit
On 8 November 1956, the Attorney-General handed a copy of Hannam's 187-page report to the President of the British Medical Association, effectively the doctors' trade union in Britain. This document – the prosecution's most valuable document – was in the hands of the defence, a situation that led the Home Secretary, Gwilym Lloyd George, to reprimand Manningham-Buller, stating that such documents should not even be shown to "Parliament or to individual Members". "I can only hope that no harm will result" since "the disclosure of this document is likely to cause me considerable embarrassment".
Possible reasons for interferenceEdit
- NHS situation: The case was "very important for the medical profession". The NHS had been founded in 1948 but by 1956 was stretched financially to breaking point and doctors were disaffected. Indeed, a Royal Commission was set up in February 1957 to consider doctors' pay. A doctor sentenced to death would have led to "mass defections" from the service for fear of being hanged for prescribing medication. Moreover, it would have shaken public confidence in the service and in the government of the time as well.
- The Suez Crisis: On 26 July 1956 President Nasser of Egypt announced the nationalisation of the Suez Canal. This was opposed by Britain and France and an ultimatum was issued on 30 October. Bombardment began the next day. On 5 November, Britain and France invaded. Political and financial pressure from the US and NATO led to a withdrawal by 24 December. In January 1957 Prime Minister Anthony Eden resigned and was succeeded by Harold Macmillan. The situation was such that when Harold Macmillan became Prime Minister on 10 January 1957, he told the Queen he could not guarantee his government would last "six weeks". Adams's fate was therefore entwined with that of the reeling government.
- Harold Macmillan link: On 26 November 1950 His Grace The 10th Duke of Devonshire had a heart attack. Adams tended him and was by his side when he died, 13 days after the death of Morrell. The coroner should have been notified, since the Duke had not seen a doctor in the 14 days before his death. Because of a loophole in the law, Adams, though present at death, could sign the death certificate to state that the Duke died naturally. The Duke's sister was married to Harold Macmillan, and some have argued that Macmillan, who became Prime Minister during preparations for the trial, might not have wanted this case to be investigated further: The Attorney-General, Manningham-Buller, attended Cabinet meetings regularly.
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.
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. His interim report on his investigation of October 1956 includes his strong suspicion of narcotic poisoning in several cases and 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. 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, claiming 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, as worst untrue.
It has been noted that these testimonies gathered by Hannam were never aired in court, so never subjected to cross-examination:
- August 1939 – Adams was treating Agnes Pike. Her solicitors were concerned at the amount of hypnotic drugs he was giving her and asked another doctor, Dr Mathew, to take over treatment. Mathew examined her in Adams's presence but could find no disease present. The patient was "deeply under the influence of drugs", incoherent and gave her age as 200 years. Later during the examination Adams stepped forward unexpectedly and gave Pike an injection of morphia. Asked why he did this, Adams replied "because she might be violent". Mathew discovered that Adams had banned all relatives from seeing her. Mathew withdrew Adams's medication and after eight weeks of his care, Pike was able to do her own shopping and had regained her full faculties.
- 24 December 1946 – Emily Louise Mortimer died aged 75. Afterwards, Adams took a bottle of brandy and a clock from her room. He claimed to the police that the clock had been loaned by him and that it was not "right to leave spirits in a nursing home". Adams received the residue from Mortimer's will and by 1957 had earned £1,950 in dividends from the shares he inherited.
- 23 February 1950 – Amy Ware died aged 76. Adams had banned her from seeing relatives prior to her death. She left Adams £1,000 of her total estate of £8,993, yet Adams stated on the cremation form that he was not a beneficiary of the will. He was charged and convicted for this in 1957.
- 28 December 1950 – Annabelle Kilgour died aged 89. She had been attended by Adams since July when she had had a stroke. She went into a coma on 23 December, immediately after Adams started giving her sedatives. The nurse involved later told the police she was "quite certain Adams either gave the wrong injection or of far too concentrated a type". Kilgour left Adams £200 and a clock.
- 3 January 1952 – Adams purchased 5,000 phenobarbitone tablets. By the time his house was searched four years later, none were left.[xii]
- 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. Francis Camps examined her brain and excluded this possibility. The rest of the body was not in a state to deduce the real cause of death. It was noticed that Adams, the executor, had put a plate on Bradnum's coffin stating she died on 27 May 1952. This was the date her body was interred.
- 22 November 1952 – Julia Thomas, 72, was being treated by Adams (she called him "Bobbums") for depression after her cat died in early November. On the 19th, Adams gave sedatives so she would feel "better for it in the morning". The next day, after more tablets, she went into a coma. On the 21st he told Thomas' cook; "Mrs. Thomas has promised me her typewriter, I'll take it now". She died at 3 am the next morning.
- 15 January 1953 – Hilda Neil Miller, 86, died in a guest house where she lived with her sister Clara. They had not been receiving their post for many months previously and were cut off from their relatives. When Hilda's long-standing friend Dolly Wallis asked Adams about her health, he answered her with medical terms she "did not understand". While visiting Hilda, Adams was seen by her nurse, Phyllis Owen, to pick up articles in the room, examine them and slip them in his pocket. Adams arranged Hilda's funeral and burial site himself.
- 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 was one of the two bodies exhumed during the police investigation on 21 December 1956. Francis Camps concluded that she had had bronchopneumonia possibly brought about by high drug doses – not a heart problem as Adams had said on the death certificate. According to prescription records, Adams had not prescribed anything to treat the bronchopneumonia.
- 30 May 1955 – James Downs, brother-in-law of Amy Ware (see above), died aged 88. He had entered a nursing home with a broken ankle four months earlier. Adams had treated him with a sedative containing morphia, which made him forgetful. On 7 April Adams gave his nurse, Sister Miller, a tablet to make him more alert. Two hours later, a solicitor arrived for him to amend his will. Adams told the solicitor he was to be made a legatee to inherit £1000. The solicitor amended the will and returned two hours later with another doctor, Dr Barkworth, who declared the patient to be alert. Barkworth was paid 3 guineas for his time. Nurse Miller later told police she had heard Adams earlier that April tell the "senile" Downs; "Now look Jimmy, you promised me... you would look after me and I see you haven't even mentioned me in your will." "I have never charged you a fee". Downs died after a 36-hour coma, 12 hours after Adams's last visit. Adams charged his estate £216 for his services and signed Downs' cremation form, stating he had "no pecuniary interest in the death of the deceased".
- 14 March 1956 – Alfred John Hullett died, aged 71. He was the husband of Gertrude Hullett. 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.
- 15 November 1956 – Annie Sharpe, owner of the guest house where the Neil Millers died – and therefore a major witness – died suddenly of "carcinomatosis of the peritoneal cavity" while Hannam and Hewett were in London meeting with the DPP. Adams had diagnosed cancer five days earlier and made a prescription for Sharpe for hyperduric morphine and 36 pethidine tablets. The police were very disappointed: they had had two chances to interview her, and Hannam and Hewett felt she had been about to "crack". She was cremated hastily, precluding an investigation into her death.
Hannam also discovered that 4 members of Adams' household staff had been prescribed either morphine, heroin or pethidine by Adams. Adams obtained these on the NHS, leading Hannam to conclude that he was merely using their names and keeping the drugs for his own supplies – an act of fraud.
After the acquittalEdit
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 doubt his guilt. 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. He returned to Eastbourne, where he continued to practise privately despite the common 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.
Sir Roland Gwynne died on 15 November 1971. Adams signed his death certificate.
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.
Historical views on AdamsEdit
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.[xiii] 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.
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.[xiv] The police archives were opened in 2003 at the request of historian Pamela Cullen, who writes that Adams "may have had more victims than Shipman".[xv] In her view, 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.
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."[xvi]
- 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.
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.
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.
Notes and referencesEdit
- He left £500 in his will to Marine Hall, his local Brethren congregation.
- Cullen states it was "almost designed to frustrate the investigation".
- The Home Secretary, Gwilym Lloyd-George, wrote to Manningham-Buller that: "The disclosure of this document is likely to cause me considerable embarrassment. As you know, police reports have always been treated as highly confidential documents and it has been the invariable practice to refuse to disclose their contents to Parliament or to individual Members. Indeed I should have no hesitation in claiming privilege if their production were required in a court of law." He ended: "I can only hope that no harm will result."
- "It cannot be imagined that the Attorney General, a lawyer just one place below the rank of the Lord Chancellor of the realm could 'loan' a police report of such importance for Macrae to take it to his President and expect that only one particular paragraph would be read by them or that they would make no copy of the report." 
- In court, the defence would accuse Hannam of intentionally "waylaying" Adams in order to informally question him. Hannam denied this.
- Probably Rodney Hallworth.
- She was the sister-in-law of one of Adams's Brethren friends (Norman Gray), and her father owned six butchers in the town.
- He left her: "in gratitude and memories of our long standing friendship any one item of furniture or personal or household or domestic use ornament or consumption belonging to me at the time of my death".
- Over 80 days 1512 grains of the former and 6¼ grains of the latter were prescribed.
- When asked by Lawrence whether it was possible "to rule out the hypothesis that when the end came in that way at that time on that date, it was the result of natural causes?", Ashby replied "It cannot be ruled out".
- His reticence is especially perplexing since he 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: if you asked yourself that, you were finished."
- Documentation was found recording the purchase, though Adams denied it had taken place.
- "Whenever the name of Dr John Bodkin Adams comes up, I am asked, 'Did he do it?' 'Was he guilty?' And I always answer, 'No'". 
- Though Hoskins and Hallworth did visit Eastbourne in 1956 and talked to local residents and the police. Surtees interviewed many local residents and Adams himself, though decades after the events.
- He "may have had more victims than Shipman – and he had a far more successful career as a serial killer" 
- The summing up affirmed "that a doctor will be immune from criminal liability if his or her primary intention in these circumstances can be characterised as an intention to relieve pain, rather than an intention to hasten death."
- "The Case of Dr John Bodkin Adams". strangerinblood.co.uk. Retrieved 18 February 2010.
- Cullen, p. 636.
- Cullen, p. 537.
- Not Guilty, Time, 22 April 1957.
- Law and Literature, ed. Brook Thomas, p. 149 – quoting Rupert Furneaux
- The Times, 11 June 1985, p. 10
- Devlin (1985).
- Surtees, p. 132.
- Cullen, p. 7.
- Cullen, p. 554.
- Cullen, pp. 19–23.
- Cullen, pp. 23,608.
- Cullen, p. 24.
- Bank of England inflation calculator, "Archived copy". Archived from the original on 4 December 2013. Retrieved 5 February 2014. Cite uses deprecated parameter
|deadurl=(help)CS1 maint: archived copy as title (link)
- Cullen, p. 55.
- Guilty on 14 Charges – TIME
- "Kelly's Directory of Eastbourne (1929)". Kelly's Directories Ltd. Cite journal requires
- Cullen, p. 56.
- Cullen, p. 59.
- Surtees, p. 24.
- Hoskins (1984).
- Cullen, p. 536.
- Cullen, p. 32.
- Surtees, pp. 32,37–38.
- Cullen, p. 203.
- Robins, p. 15.
- Surtees, p. 33.
- Cullen, p. 42.
- Cullen, pp. 15–17.
- Cullen, p. 40.
- Devlin, p. 181.
- Robins, pp. 77–83.
- Cullen, p. 593.
- Cullen, p. 588.
- Devlin, pp. 63–5, 69–70.
- Cullen, p. 587.
- Cullen, p. 224.
- Devlin, p. 124.
- Jones, p. 48.
- Cullen, p. 230.
- Cullen, p. 232.
- Cullen, p. 227.
- Cullen, p. 228.
- Cullen, p. 369.
- Cullen, p. 189.
- Cullen, p. 190.
- Cullen, p. 235.
- Cullen, p. 236.
- Cullen, p. 238.
- Cullen, p. 237.
- Cullen, p. 551.
- Cullen, p. 594.
- Hallworth, 1983
- Cullen, p. 610.
- Cullen, pp. 243–244.
- Cullen, pp. 622–635.
- Cullen, p. 188.
- Cullen, p. 47.
- Cullen, pp. 591,641.
- Cullen, p. 611.
- Surtees, p. 23.
- Cullen, p. 553.
- Devlin, p. 24.
- Cullen, p. 240.
- Devlin, p. 25.
- Cullen, p. 250.
- Devlin, pp. 29–30.
- Devlin, pp. 112–113.
- Cullen, p. 560.
- Devlin, pp. 2–3.
- Devlin, pp. 83,127.
- Devlin, pp. 113–114,149.
- Cullen, p. 94.
- Devlin, p. 97.
- Cullen, p. 93.
- Cullen, p. 564.
- Devlin, pp. 97, 105.
- Cullen, p. 96.
- Cullen, p. 563.
- Cullen, p. 565.
- Cullen, pp. 156–159.
- Cullen, p. 158.
- Devlin, pp. 12–13, 16.
- Cullen, p. 569.
- Cullen, p. 568.
- Cullen, p. 585.
- Cullen, p. 571.
- Cullen, p. 153.
- Cullen, p. 161.
- Cullen, p. 185.
- Cullen, p. 184.
- Devlin, p. 16.
- Cullen, p. 577.
- Devlin, pp. 122–123.
- Devlin, p. 123.
- Cullen, pp. 250,636.
- Devlin, p. 31.
- Cullen, p. 143.
- Devlin, pp. 13–14, 218.
- Devlin, pp. 25, 179.
- Devlin, pp. 198, 218.
- Cullen, p. 249.
- Devlin, pp. 31,33.
- Devlin, pp. 43,47–48.
- Devlin, pp. 48–49.
- Cullen, p. 281.
- Furneaux, pp. 72–3.
- Cullen, pp. 597–598.
- Cullen, pp. 423–424.
- Cullen, p. 448.
- Surtees, p. 122.
- Devlin, pp. 178.
- Cullen, p. 633.
- Devlin, pp. 36–37.
- Cullen, p. 526.
- Devlin, pp. 179–180.
- Devlin, pp. 180–181.
- Devlin, p. 180.
- Cullen, p. 596.
- Cullen, p. 599.
- Devlin, p. 80.
- Devlin, p. 72.
- Cullen, pp. 598–599.
- Devlin, p. 35.
- Macmillan, Harold. The Macmillan Diaries, The Cabinet Years, 1950–1957, ed. Peter Catterall (London, Macmillan, 2003).
- Cullen, pp. 97–101.
- Cullen, p. 648.
- Robins, p. 146.
- "John Bodkin Adams - Criminalia, la enciclopedia del crimen".
- Robins, pp. 82, 85.
- Robins, pp. 136-9.
- Robins, pp. 124-6, 138. 232..
- Cullen, p. 589.
- Cullen, pp. 61–65.
- Cullen, pp. 72–73.
- Cullen, pp. 124–126.
- Cullen, pp. 109–111.
- Cullen, p. 273.
- Cullen, pp. 102–108.
- Cullen, pp. 80–81.
- Cullen, pp. 132–144.
- Cullen, pp. 143–144.
- Cullen, p. 144.
- Cullen, p. 142.
- Cullen, p. 141.
- Cullen, p. 140.
- Cullen, pp. 126–131.
- Cullen, pp. 145–147.
- Cullen, p. 547.
- Cullen, p. 548.
- Eric Ambler's 1963 book The Ability to Kill originally contained a chapter on Adams. 50 promotional copies were produced before the publishers got cold feet and removed the chapter for fear of being sued. The book was finally published with an alternative chapter included (jimbooks.com)
- Cullen, p. 634.
- Cullen, p. 549.
- Cullen, pp. 550–552.
- Profile of Adams Archived 10 August 2004 at the Wayback Machine at shycyberchamber.com
- Cullen, p. 635.
- Cullen, pp. 553–554.
- Bedford, p. vii.
- Hallworth, p. 217.
- Hallworth, p. 243.
- Devlin, p. 199.
- Quoted in Surtees, p. 165
- Cullen, p. 556.
- Cullen, p. 637.
- Devlin, pp. 10, 199.
- Mahar, pp. 159–160.
- Mahar, pp. 161–162.
- Mahar, pp. 163–164.
- Mahar, p. 166.
- Mahar, p. 167.
- Devlin, pp. 124,170.
- Devlin, p. 218.
- Mahar, pp. 169–170.
- Treat Me Right: Essays in Medical Law and Ethics
- Australian Euthanasia Laws Bill 1996 Archived 13 November 2008 at the Wayback Machine
- Killing the Willing ... And Others! Legal Aspects of Euthanasia and Related Topics Archived 28 August 2007 at the Wayback Machine
- Bedford, Sybille (1989). The Best We Can Do. London: Penguin. ISBN 0-14-011557-9.
- Cullen, Pamela V. (2006). A Stranger in Blood: The Case Files on Dr John Bodkin Adams. London: Elliott & Thompson. ISBN 1-904027-19-9.
- Devlin, Patrick (1985). Easing the passing: The trial of Doctor John Bodkin Adams. London: The Bodley Head. ISBN 0-571-13993-0.
- Furneaux, Rupert (1957). Famous Criminal Cases (4). London: Allan Wingate.
- Hoskins, Percy (1984). Two men were acquitted: The trial and acquittal of Doctor John Bodkin Adams. London: Secker & Warburg. ISBN 0-436-20161-5.
- Hallworth, Rodney; Williams, Mark (1983). Where there's a will... The sensational life of Dr John Bodkin Adams. Jersey: Capstan Press. ISBN 0-946797-00-5.
- Jones, Elwyn (1969).The Office of Attorney-General.The Cambridge Law Journal, Vol. 27, No. 1
- Mahar, Caitlin. (2012). "Easing the Passing: R v Adams and Terminal Care in Post-war Britain". Social History of Medicine. 28 (1).
- Robins, Jane (2013). The Curious Habits of Dr Adams: A 1950s Murder Mystery. John Murray. ISBN 978-1-84854-470-3.
- Surtees, John (2000). The Strange Case of Dr. Bodkin Adams: The Life and Murder Trial of Eastbourne's Infamous Doctor and the Views of Those Who Knew Him. Seaford. ISBN 1-85770-108-9.
- Ambler, Eric, The Ability to Kill, 1963 (promotional edition with chapter on Adams only – subsequent editions had it removed due to libel fears)
- Bedford, Sybille, The Trial of Dr. Adams, 1958. Simon and Schuster, Inc. Mrs. Bedford "contributes the reporter's arts of observation, selection and emphasis."—From the 1962 editor's preface.
- Cavendish, Marshall. Murder Casebook 40 Eastbourne's Doctor Death, 1990.
- Chapman, D. 'Jill's Letter' in The Postmodern Malady, Concept, 2010. ISBN 978-1477645062.
- Gaute, J.H.H. and Robin Odell, The New Murderer's Who's Who, Harrap Books, London, 1996.