american english - What's the equivalent phrase in the UK for "I plead the fifth"?


In the United States, a person under examination on the witness stand may "plead the fifth" to avoid self-incrimination. In other words, a person asserts his or her Fifth Amendment right.


Citizens of many English-speaking countries have the right to remain silent and laws to protect against self-incrimination (testifying against yourself). In the UK, how do witnesses or defendants respond in court? Do they literally remain silent, invoke a particular law, or say "no comment"?


Include the legal traditions of other English-speaking countries if relevant. However, with nearly one hundred such nations, I don't wish to promote giving an answer for each one.


To be clear: I am looking for the words a defendant might say on the witness stand. If there's no standard response, then that's an acceptable answer. If defendants would never say something like it because they wouldn't be on the stand unless they had waived their right to silence, then that's an acceptable answer.



Answer



There is no such equivalent phrase that I know of for any English-speaking country. However thanks to the prevalence of US media, the phrase "plead the fifth" or "take the fifth" is widely recognized outside the US, and is frequently used in general conversation


In most jurisdictions that derive from the British system, a defendant may decline to testify in court. However once they have agreed to testify they cannot then decline to answer some questions. Likewise, in Canada at least, testimony given as a witness in someone else's trial cannot be used against you. This means that there is no case where a witness can decline to answer a specific question, and so there is no equivalent phrase that is used in court.


Edit: Kudos to @AndrewLeach for pointing out the well-known "right to remain silent" in police interrogations, which also exists in the UK and most places with a British-derived system of justice. I believe in general conversation "I'm exercising my right to remain silent" would be understood in much the same way as "I plead the fifth".


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