The decision in the case of R Vs. Bedingfield was overruled in the case of ?

Actually the decision of Bedingfield case was too strict. However, this decision was overruled in the case of Ratten v.R 1972 where under common law, the doctrine of Res Gestae was defined in liberal and wider terms. In this case it was held that the mere fact that evidence of a witness includes evidence as to words spoken by another person who is not called is no objection to its admissibility. Words spoken are facts just as much as any other action by a human being. Such evidence may not be inadmissible, when it is not led, not to prove the truth of the statement but the fact that it was made.